While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This is a category A project primarily due to the potentially significant and diverse environmental and social impacts and risks associated with some of CSAIL’s prospective business activities in Pakistan, particularly development and operation of large-scale greenfield hydro power projects (e.g. Karot 720 MW and Kohala 1,100 MW on Jhelum River) and wind power projects (e.g. 300MW Third Wind Farm Project in Sindh Province).

The key environmental, health and safety, and social risks and issues associated with this proposed investment include: CSAIL’s environmental and social management system supported by CTGC and CWEI, CSAIL’s commitment and capacity to conduct environmental and social impact assessments for projects under development /to be developed (large scale hydropower projects and wind/solar power projects). IFC’s appraisal considered CSAIL’s environmental and social management system and gaps, if any, between this system and IFC requirements. Where necessary, corrective measures intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and in the agreed Environmental and Social Action Plan (ESAP). Through implementation of this management system and ESAP, CSAIL is expected to operate its facilities in accordance with IFC Performance Standards objectives.

Based on IFC’s understanding of the current portfolio of projects under development by CSAIL, no impacts on indigenous peoples or cultural heritage have been identified and therefore IFC Performance Standards 7 and 8 are not applicable at this stage. Under Performance Standard 1, CSAIL’s assessment of any future projects will include determination of applicability of all of the Performance Standards, including PS7 and 8, and procedures for assessing and managing these impacts if they arise in future projects developed by CSAIL.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Environmental and Social Assessment and Management System:

CTGC, one of the largest hydropower generating companies in the world with total generating capacity of 66,415 MW (including assets under operation, in construction and at feasibility review stage), has a well-established corporate wide E&S management system. Especially as a result of the mitigation and monitoring activities to address various E&S issues associated with CTGC?s largest Three Gorges hydropower project (22,500MW) on the Yangtze River in China, CTGC has been strengthening its E&S management system over the last decade. One aspect of this effort was CTGC?s E&S management system, which received ISO14001 certification in 2013 (China Certification Center Inc. or CCGI, http://www.ccci.com.cn, a member of Multilateral Recognition Arrangement ? International Accreditation Forum for CTGC?s project management for hydro power and associated facilities). Each group company of CTGC is responsible to establish a relevant E&S management system in line with the CTGC system. CSAIL is a newly established company and as such does not yet have an E&S management system in place. CSAIL will establish its E&S management system at both the corporate and project level incorporating IFC Performance Standards (ESAP Action No.1).

Policy:

CTGC has a ?Quality, Environment, and Occupational Health and Safety Management Manual? dated December 28, 2012, and approved by CTGC?s President. This manual includes CTGC?s E&S policy statement addressing CTGC?s guidelines for the quality, environment and occupational health and safety management. Based on this CTGC?s manual and policy statement, CSAIL plans to develop its own E&S policy statement (ESAP Action No. 2).

Identification of Risks and Impacts:

To meet the project development process requirements by the Government of Pakistan, and also to meet CTGC?s and CWEI?s internal requirements, CSAIL conducts a feasibility study (FS) for each new project that includes an environmental and social impact assessment (ESIA). Following the FS stage, as technical design specifications are being finalized, CSAIL updates the ESIA prepared during the FS prior to formal submission to relevant Pakistan environmental authorities for approval. Key E&S issues typically identified through ESIAs include land acquisition and resettlement of people and assets (for greenfield renewable energy projects), noise, shadow flicker and bird and bat impacts for wind farm projects, securing water supply needed for panel washing for solar power projects located in desert areas, cumulative impact assessment of multiple hydropower projects developed in cascade on the same river system, seismic consideration and dam safety, and determination of minimum ecological flow to sustain ecosystem services for run-of-river hydropower projects. For projects where ESIAs were prepared prior to CSAIL?s involvement, CSAIL will update these documents based on the final project design and in line with IFC Performance Standards. For all new projects, CSAIL will conduct ESIAs in line with IFC Performance Standards.

Management Programs:

Each project?s ESIA will include an environmental and social management and monitoring plan (ESMMP) that describes identified E&S issues, mitigation measures and monitoring programs aligned with IFC Performance Standards and Pakistan regulations. CSAIL will work with the engineering, procurement and construction (EPC) contractor and the operation and maintenance (O&M) team to manage the implementation of the ESMMP. For the existing project under construction (the 50MW TGF wind farm project), the project company is implementing the environmental and social mitigation and monitoring programs. If needed, CSAIL will implement additional programs in order to ensure the project meets IFC Performance Standards.

The EPC contractors selected by CSAIL will all be experienced in the design and construction of similar projects internationally. Key to the construction phase management program will be the management and monitoring of the EPC contractors. Contractual obligations to comply with the ESIA including E&S management commitments and management planning will be included in all EPC contract agreements. Alignment of the EPC contractor planning (and other project sub-contractor plans) with project requirements will be managed and monitored closely by CSAIL through a series of contractor control plans that detail the specific control and mitigation measures to be implemented by the contractor in accordance with their contractual obligations.

Organizational Capacity and Competency:

(i) CTGC?s Science & Technology and Environmental Protection Department is a centralized management department with responsibilities to establish and manage CTGC?s group-wide E&S management system. Various departments within CTGC have responsibilities to implement certain aspects of the corporate E&S management system. Specifically: Strategic Development Department is responsible for the management of environmental protection in project planning phase;
(ii) Assets and Finance Department is responsible for the budget arrangement and fund appropriation of the environmental protection fund of CTGC;
(iii) Engineering Construction Administration is responsible for environmental protection in the early period of hydroelectric power construction project (e.g. Pre-Feasibility and Feasibility phases);
(iv) Engineering Construction Department is responsible for the environmental protection during the construction period of projects;
(v) Three Gorges Hydro Project Construction and Operation Administration is responsible for the environmental protection management of reservoirs and relevant areas of Three Gorges Reservoir;
(vi) International Department is responsible for coordination of environmental protection management of overseas projects;
(vii) Information Center is responsible for establishing and maintenance of environmental protection management information system;
(viii) Press Center is responsible for publicity of environmental protection management works;
(ix) Supervision Department is responsible for supervision on environmental protection management tasks; and
(x) Audit Department is responsible for environmental protection management audit.

In addition, Quality & Safety Department, HR Department, and Resettlement Management Administration of CTGC provide E&S support to CWEI and CSAIL. For example, the existing CSAIL project (Three Gorges First wind farm project) under construction received an occupational health and safety (OHS) audit team from CTGC in 2013 which evaluated OHS performance as satisfactory.

CSAIL?s business activities are currently supported by officers and engineers from CWEI and CTGC. The proposed organizational structure of CSAIL includes shareholder meetings, board of directors, and a management team consisting of five departments (Sales & Marketing, Project Management, Administration, Finance, and Technology). At this early stage in the development of most projects, CSAIL has been relying on third party E&S consultancies to undertake early E&S analysis. Once an individual project starts to be developed, a special purpose vehicle (SPV) company will be established to implement the project, including relevant E&S management. To assist these SPV companies, and to manage the E&S risks of CSAIL?s overall portfolio, CSAIL will appoint dedicated Environmental, Health and Safety and Social Officers to manage E&S risks of CSAIL?s projects, which will eventually be strengthened to be an EHSS Unit of CSAIL (ESAP Action No. 3).

Emergency Preparedness and Response:

CSAIL will prepare a relevant emergency preparedness and response plan for the construction phase of each project in coordination with the selected EPC contactor, and for the operational phase, with the project O&M team. Work at height risks at wind farm projects, occupational injury risks for dam construction and potential emergency incidents related to reservoir sediment flashing activities for hydropower operations, results of dam safety studies and needed response arrangements will be fully addressed in project specific emergency preparedness and response plans. The existing plant currently under development by CSAIL (Three Gorges Wind plant) has a relevant and robust emergency preparedness and response plan in place.

Monitoring and Review:

Through CTGC?s E&S management system, implementation status of the E&S protection measures; compliance with relevant host country environmental, health and safety regulations; compliance with CTGC?s internal E&S management system requirements, compliance with relevant EHS technical standards, and construction and operational phase environmental, health and safety performance are all regularly monitored, audited, and reported to CTGC?s management. CTGC?s overall E&S performance, including that of group subsidiaries, is published in two annual reports: (i) Annual Report of Environmental Protection; and (ii) Annual Social Responsibility Report. The reports are available in English at http://www.ctg.com.cn. The Social Responsibility Reports are prepared using Global Reporting Initiative (GRI)?s sustainability reporting framework. CSAIL?s E&S performance and implementation of management programs will be monitored through CSAIL?s E&S management system.

As part of IFC?s regular E&S monitoring program, CSAIL will submit annual E&S monitoring reports confirming compliance of CSAIL?s business activities including each individual projects with IFC Performance Standards and the agreed ESAP described in this ESRS. For individual projects with potentially significant adverse E&S impacts, such as large scale hydro and wind farm projects, CSAIL will engage relevant independent third party E&S experts to verify E&S m

Working Conditions and Management of Worker Relationship:

CSAIL?s business activities are currently supported by managers and engineers from CWEI. CSAIL has offices in Karachi and Islamabad currently each staffed by 5-6 CWEI employees designated to manage project related activities on a day-to-day basis. The Karachi office is responsible for managing activities undertaken for the preparation and development of wind/solar projects, including overseeing EPC construction contractors for the construction of its first wind project and preparation work for the two additional projects in the pipeline. The Islamabad office is responsible for hydro project development, currently at exploration and surveying stage. CSAIL will be relying on seconded CWEI staff members to staff its Pakistan offices for the foreseeable future. The number of CWEI staff in CSAIL offices is expected to increase to keep pace with their development program. CWEI and CSAIL will continue to rely on EPC contractors for construction and therefore will retain a relatively small number of staff in Pakistan. CSAIL?s human resources management and practice follow CWEI?s policy and practices, which are applied internationally, including in Pakistan. Moving forward, CSAIL will ensure its labor policy and practices are in compliance with IFC?s PS2 Labor and Working Condition (ESAP Action No. 4).

CWEI currently employs 120 China-based staff working globally. Its Human Resources policy, procedures and terms of employment for both CWEI?s employees and EPC contractors follow national labor laws include regulations of working hours, overtime payments, national holidays, annual leave, maternity leave, medical leave, pension, and other benefits and compensation policies. Individual employment contracts are signed at the time of employment and may be either open-end or fixed-term, depending on the nature of the assignment and the skill level of the employee. Individual ID cards are used for age screening both for CWEI own employees and non-employee workers. Certain CWEI staff are hired though reputable labor agents who are known to comply strictly with Chinese laws and regulations.

CWEI employees working on overseas projects are all covered under a standard rotation program of six months in project country and two weeks paid leave. To meet its growing business needs and heavy reliance on EPC contractors, CWEI/CSAIL will develop a supplemental policy and procedures with respect to staff rotation in compliance with international good practices.

Workers unions in Pakistan are recognized by national labor law. Pakistan workers have viable options if they decide to form or join a workers union. CSAIL does not restrict employees? freedom of association. Grievance channels are built into CSAIL?s existing management practices, which are replicated from CWEI; issues can be escalated to higher levels within the organization as and when needed. As a part of CSAIL?s corporate level ESMS, a worker/contractor grievance mechanism will be established at corporate and project levels to allow free flow of grievances from contracted workers and staff to the relevant line managers for a mutually acceptable resolution. CSAIL?s contractors will be held responsible for the fair and appropriate handling of employee grievances and this will be subject to monitoring by CSAIL.

TGF is the only CSAIL project currently under construction in Pakistan with a total of 660 staff on site, inclusive of CWEI and its EPC contractor and subcontractors. The workforce are 75% (500 staff) Pakistanis and 25% (160) Chinese, the latter mainly civil engineers. Meanwhile, a Pakistan senior advisor to the CEO and eleven Pakistani core technical staff have been hired as TGF employees for the construction and operation phases. A two-month technical training was attended by all eleven engineers; the training program including technical training courses in academies and visits to large wind projects in China.

The most advanced hydro project is Karot, the EPC contract for which is due to be tendered in October 2014 and construction to be commenced in February 2015. The construction contractors? workforce is expected to be predominantly male with a total number of contracted workers ranging from approximately 2,000 to 3,000 at any one time, including indirect workers hired through contractors to perform construction tasks.

CSAIL will work closely with their EPC contractors to promote local access to project employment in both the construction and operational phases of the project. Top priority in hiring will be given to those members of local communities affected by the project development. Early indications suggest that the necessary technical skills required for the project construction program may be scarce in the communities closest to the project site. However, it is expected that the majority of its construction workforce will be made up of Pakistan nationals with a target of 30% of these individuals to be sourced from the local area. During operations the workforce will be made up of greater than 70% Pakistan nationals. CSAIL will work with local NGOs to develop training needs and vocational training programs for the local community that will assist the EPC contractor in achieving the community employment targets.

Contractor Workers and Workers Accommodation Camps:

CSAIL?s current arrangement holds the EPC contractor independently responsible for ensuring their labor practices are in line with national requirements. As a large number of construction workers working for multiple contractors and sub-contractors are expected, a centralized evaluation system therefore will be in place at CSAIL to monitor that labor laws are being followed by all project contractors and sub-contractors.

The most advanced TGF project has developed a workers accommodation camp site with concrete structured offices and workers accommodations that are very well managed, with sufficient space for individuals and adequate access to water and sanitation. A mosque was built for workers. TGF has also rented out rooms to contractors and subcontractors at reasonable rates. However, the number of worker accommodations the project will be able to provide will not meet the demand from construction teams. As a part of CWEI?s overall process to ensuring CSAIL is in compliance with IFC?s Performance Standard 2, CSAIL will establish an overarching accommodation standard in line with international standards and create a project level monitoring mechanism to ensure that all workers requiring accommodation are housed in camps that meet these standards. Workers camps will be monitored regularly and any deficiencies raised to CWEI/CSAIL management.

Protecting the Workforce (Child Labor, Forced Labor):

The minimum age for construction work under international standards and Pakistan and China labor laws is 18 years. Individual ID card are used for age screening both for CWEI/CSAIL employees and non-employee workers, CSAIL does not use child or forced labor. Contractors are required to strictly follow the national labor law and hire only employees older than 18 year of age for construction works. Moving forward, CSAIL will extend the minimum age requirement to all workers working for CSAIL?s projects including its main service providers.

Occupational Health and Safety:

CTGC strives to achieve objectives of ?Four Zero?, namely, ?zero quality accidents?, ?zero safety accidents?, ?zero environmental accidents? and ?zero unplanned outage of the unit?. CTGC?s Quality & Safety Department is in charge of operating the safety management system, and provides trainings on safety management and conducts regular health and safety audits at CTGC?s and its subsidiaries? construction and operation sites. CSAIL?s first project site under construction (Three Gorges First Wind Farm Project, or ?TGF?) was audited in 2013, and its health and safety performance was evaluated as satisfactory against CTGC?s management standards. CSAIL will incorporate internationally recognized health and safety guidelines from IFC Performance Standards and IFC/WBG Environmental, Health and Safety Guidelines for their management standards in Pakistan. As of December 2013, TGF had achieved a zero lost-time injuries record. TGF has both a safety management system and a security management system in place. Safety inspections are conducted on a daily basis, and relevant OHS trainings are provided to workers. At the construction site, there are two safety engineers (TGF and CSAIL). CSAIL will establish a detailed Occupational Health and Safety procedures manual that outlines all requirements to ensure compliance with its own standard practices, IFC Performance Standard 2 and IFC/World Bank Group Environmental, Health and Safety Guidelines (ESAP Action No. 4). This manual will be made available in Chinese, Urdu and English to all contractors, subcontractors and individual workers.

Resource Efficiency:
CTGC has been active in having their hydropower and wind farm projects registered as UNFCCC Clean Development Mechanism projects. CSAIL aims to develop a large portfolio of renewable energy projects (hydro, wind and solar) in Pakistan and is also planning to have their renewable energy projects registered as CDM projects. For example, according to the Project Design Documents currently available, the 720 MW Karot Hydropower Project is estimated to have annual average GHG emission reductions of about 1.6 million ton CO2 per year, and the 50 MW Solar Project in Cholistan is estimated to result in a 50,000 ton CO2 per year reduction. In selecting wind turbines for wind farm projects, solar panels for Photovoltaic solar projects, and in designing technical features of wind, hydro, and solar projects, CSAIL considers the resource efficiency performance (electricity generation, water utilization) in harmonization with environmental sustainability as one of the key criteria. Wind and solar sites of CSAIL tend to be in desert or semi-arid area, and CSAIL aims to design the project in due consideration of this aspect to achieve high water utilization efficiency. IFC will monitor the overall resource efficiency performance of CSAIL?s projects (e.g. greenhouse emission reduction effects, water utilization efficiency performance) through IFC?s regular E&S monitoring activities.

Pollution Prevention:
Each project?s ESIA and ESMMP will incorporate various pollution prevention measures relevant to wind farm projects (e.g. shadow flicker, noise), solar power projects (e.g. hazardous and non-hazardous waste management), and hydropower projects (e.g. excavated soil and rocks management, reservoir sediment flashing procedures to minimize downstream water quality impacts, ecological flow to minimize downstream water quality impacts). CSAIL ensures that wastewater treatment facilities are installed at every construction and operation site, as has already been done at TGF?s existing construction site, and will be done for future projects to be developed. At every hydropower construction site, CSAIL will ensure that separate rainwater and sewage systems are installed. Through strengthening CSAIL?s E&S management system, CSAIL will establish its environmental procedures that ensure that such pollution prevention measures are built into every ESMMP, and in line with relevant IFC/WBG Environmental Health and Safety Guidelines (e.g. General EHS Guidelines, EHS Guidelines for Wind Energy) (ESAP Action No. 5).

CSAIL?s current and proposed wind and solar developments in Pakistan are along the same wind corridor in the southern part of Pakistan, distanced from populated areas along the national irrigation channel, and are located in desert areas and thus not expected to result in economic or physical displacement.

Most of CSAIL?s developments, especially the hydro projects, in Pakistan are at an early stage. The proposed hydro projects are two cascades located at high attitude in very steep valleys along the Jhelum River. Despite the large size of these proposed projects, requirements for physical relocation and agricultural land acquisition have been minimized through adoption of run-of-river designs. Based on existing local EIA documentation, there is no evidence that people living in the vicinity of the project sites depend on the river as a source of fish or irrigation water. Land acquisition to date is limited to facilitating exploration and is under temporary leasing terms through market-based transactions.

CSAIL?s project-level land acquisition and resettlement process in Pakistan will be undertaken via a government-led process in accordance with the Land Acquisition Act. Local government will be responsible for identifying land for project development, negotiating with all affected people, and relocating and compensating project affected people and communities. The legal framework on land acquisition and involuntary resettlement in Pakistan is comprehensive, with articulated requirements on replacement cost, establishment of socio-economic baselines and livelihood restoration. This legal framework is based on one law and two supplemental governing/reference documents: 1) Land Acquisition Act 1894, 2) Project Implementation and Resettlement of the Affected Persons Ordinance 2001, and 3) National Resettlement Policy Draft 2002. The Land Acquisition Act comprises 55 sections pertaining to area notification and surveys, acquisition, compensation and apportionment, awards and disputes resolution, penalties and exemptions. The Ordinance is a supplemental standard procedure to incorporate specific local conditions into resettlement and compensation considerations. However, the interpretation and implementation of the Act can vary at the Provincial level, leading to variable compensation and resettlement packages and procedures on the ground. The National Resettlement Policy and its supplemental guidelines drafted in 2002 provide a more consistent approach and inclusive measures to address adverse social impacts result from land acquisition and detailed planning and implementation.

The potential for physical relocation and land acquisition is first identified in the EIA process through site survey and modeling, and a socio-economic baseline and legal framework are established in the EIA. As part of IFC?s investment, a Resettlement Action Plan (RAP) will be developed for each project expected to result in physical and/or economic displacement. All RAPs will be prepared by competent resettlement practitioners in compliance with IFC?s PS 5 on Land Acquisition and Involuntary Resettlement and will be finalized prior to permanent land disturbance. The RAP will outline resettlement and entitlement determination and will lay out clearly defined roles and responsibilities for implementing the RAP. It is likely that a land acquisition & resettlement committee will be formed for each project with key members representing relevant governmental agencies, local community representatives and Project personnel. These committees will oversee land acquisition, compensation disbursement, and resettlement throughout the process of planning, implementation and monitoring of land acquisition and resettlement.

CSAIL?s future compliance with IFC PS5 will be achieved through the development and implementation of such project-specific RAPs as well as any supplemental actions required to bridge potential gaps between Pakistani and IFC resettlement requirements, for example the establishment of resettlement monitoring and evaluation programs.

The two proposed CSAIL hydropower projects have local EIAs developed in 2009 and 2010, respectively, i.e. before CWEI?s engagement in those projects. The project at the most advanced stage is the 720 MW Karot Hydro power project in Rawalpindi district, Punjab province. Findings from the socio-economic baseline in the 2009 EIA for the Karot project concluded that there is no industrial activity in the project area; the predominant household income is from male household members working as unskilled laborers in the construction and transport sectors outside the valley, supplemented by subsistence farming of maize, vegetables, wheat, fruits and domestic animals. CSAIL have been conducting several detailed surveys since it took over ownership of the Karot project in July 2013. Data collected from these surveys in late 2013 suggested that a total of 40 acres of agricultural land in Gorah Village and residential land in Karot village will be impacted, resulting in physical and/or economic displacement of up to 100 households including shop owners, and local infrastructure such as roads and bridges. The detailed engineering study will be completed for Karot by the end of January 2014, and the result will be used to update the socio-economic baseline. Construction is expected in February 2015, for a total of 6 years. Requirements for physical relocation are mainly related to the development of a complex comprising of a construction camp, laydown area and power house. Completion of physical relocation is planned before the completion of EPC tendering. CWEI has commenced a process with the local government of finding alternative relocation sites and has planned to engage with competent resettlement specialists throughout the resettlement process. As part of IFC?s investment, the Karot RAP will be finalized before the commencement of the construction of the complex (in late 2014).

The Karot RAP will also be used to develop a Resettlement Action Framework (RAF). The RAF is a part of CSAIL?s E&S management plan to provide principles, guidance, and tools to develop CSAIL project specific RAP (ESAP Action No. 8).

The second possible hydro project in the pipeline is 1,100MW Kohala located at 174 km from Islamabad, which is at a relatively early stage of development. This project is a public-to-private transfer project and currently is in the process of EIA preparation. It is estimated at this stage that a total of 100-200 households will need to be physically relocated mainly for the development of a power house and project camp site. Earliest construction is expected in 2016, for a total of 6 years.

[As outlined in PS1, for each project that CSAIL develops, a full ESIA that meets the requirements of the Performance Standards and with supporting implementation documents will be required as part of IFC''s financing conditions. This includes screening for PS6 and the production of biodiversity action plans or similar to ensure that, where indicated, the required outcomes of PS6 are met.

The analysis below relates to the asset already under development (TGF) and the two hydro sites that were visited as part of the appraisal.

Protection and Conservation of Biodiversity:

CSAIL?s TGF project (a 50MW wind farm project in Sindh Province) under construction is in the Jhimpir Wind Corridor located about 8 to 15 km north of the Kheenjar Lake Wildlife Sanctuary, a designated Ramsar wetland and Important Bird Area. The E&S assessment document (Initial Environmental Examination, July 2010) prepared for TGF concluded that the project site is not a migratory route and thus there will be no effect on birds of the area, and its proposed Environmental Management Plan (EMP) therefore does not include a bird impacts monitoring for operational phase. Based on IFC?s appraisal of other two projects by other developers in the Jhimpir Wind Corridor conducted in 2010 (Zorlu Pakistan #29251 ESRS), and 2013 (Metro Power #33496 ESRS), and monitoring results from Zorlu Pakistan (which is under operation), no significant impacts on birds by other wind farm projects in the Jhimpir Wind Corridor have been observed. The monitoring and analysis has been under taken in collaboration with the World Wide Fund for Nature (WWF) Pakistan. CSAIL will consult with the developer of Zorlu Pakistan and through that, with WWF Pakistan and other stakeholders as required to ensure that the operational plans for TGF include procedures or other measures to minimize the impact of bird populations. (ESAP Action No. 9).

CSAIL is planning to develop a 100MW wind farm project (Wind Eagle Limited, or WEL) in the same Jhimpir Wind Corridor. In conducting the detailed ESIA for this second project, CSAIL will review the cumulative impacts of both TGF and WEL and propose initial operational phase bird monitoring programs, as a precautionary principle (ESAP Action No. 9).

CSAIL?s two current proposed hydro power projects (720 Karot and 1,100MW Kohala) will be developed on Jhelum River. Initial review indicates that neither of these projects is located in an ecologically sensitive or protected area. The closest one identified is Machiara Reserve (National Park) located in Neelum Valley, several kilometers away from Kohala site. IFC has invested in one hydro project upstream on the Jhelum (Star Hydro #26229 ESRS) and one downstream (Laraib Energy #28010 ESRS). CSAIL?s updated ESIAs of Karot and Kohala will address potential impacts of Machiara Reserve and any other areas of biodiversity significance in line with IFC Performance Standard 6.

Management of Ecosystem Services:

Both Karot and Kohala HPPs will be run-of-river, whereby inundation upstream of the dam is approximately for 27 km for Karot and for 6 km for Kohala. Both divert from and discharge back to the Jhelum River. Based on the current design, Karot HPP will reduce the river flow for about 0.7km between the intake and discharge points, whereas Kohala HPP will reduce river flow for about 60 km between the intake and discharge. Considering the significant length of affected river for Kohala and also that its affected river reach includes a large city with a population of 700,000 and other villages on the 60km stretch, a careful determination of guaranteed ecological flow is important to minimize adverse impacts of the Kohala project on the ecosystem services of the Jhelum River..

Both projects had preliminary proposed ecological flow levels set as part of the feasibility studies prior to CSAIL?s involvement in the projects. CTGC?s team of hydropower experts visited Kohala and Karot sites in December 2013, and advised CSAIL to carefully review the current preliminary proposed ecological flow levels taking into consideration of cumulative impacts of multiple projects developed on Jhelum River and other relevant studies ongoing, as described in the paragraph below.

Pakistan Water and Power Development Authority (WAPDA) is constructing the Neelum Jhelum Hydroelectric Power Plant project (969 MW) diverting water from Neelum River and discharging to Jhelum River, and, as such, the cumulative impact assessment of Neelum Jhelum HPP and Kohala HPP will affect the determination of ecological flow for Kohala. In a broader context, the recent final order of December 20, 2013 by Permanent Court of Arbitration or ?PCA? (http://www.pca-cpa.org) on the issue of Indus Waters Kishenganga will also need to be considered in the ecological flow determination for the Kohala HPP since that order by PCA may also affect the river flow regime of both Neelum and Jhelum rivers. Finally, the results of the current study by the Government of Pakistan and International Union for Conservation of Nature (IUCN) on Strategic Environmental Assessment for hydropower projects as part of National Impact Assessment Program (http://www.niap.pk) will need to be taken and integrated in the Kohala ESIA and supporting documentation.

In accordance with Pakistan EIA regulations, CSAIL will update the ESIAs for both Karot and Kohala HPPs based on the revised design specifications with proposed minimum ecological flows, and submit them to relevant environmental authorities for approval. CSAIL is now committed to conduct the ESIA for these projects, as well as for future hydro projects, to ensure that ecological flow determination is adequate in line with not only Pakistan EIA regulations, but also IFC Performance Standards and Good International Industry Practices (GIIP).

CWEI’s perspective portfolio projects, three solar/wind power projects and two large HPPs, are at an early development stage with limited project development activities on the ground. CWEL’s current engagement with local communities and stakeholders are being conducted by the engineering consultant and mainly to facilitate temporary land lease for geological survey activities with limited footprint.

CWEI has a policy to establish and maintain active engagement and harmonious relationships with project local community/ stakeholders. This policy is based on developing project level commitment to maximize local procurement and contribute to local economic development, which includes: 1) providing at least 30% of contract value to local; 2) ensuring that 70% of unskilled jobs are given to local residents; 3) contributing to the improvement of local infrastructure and better housing; and 4) providing electricity at a reduced cost to stimulate local industrial development.
As outlined in PS5, requirements for physical relocation are mainly related to the development of a complex that includes a construction camp, laydown area and power house. Completion of physical relocation is planned before the completion of EPC tendering.

As part of IFC’s investment, CWEI will develop a Stakeholder Engagement Plan (SEP) for Karot HPP based on the Good Practice Handbook on Stakeholder Engagement published by IFC in 2007 and that meets Pakistan mandatory requirements on Stakeholder Engagement. The Karot SEP will include identification of local stakeholders such as affected communities, local government authorities, non-governmental and other civil society organizations, local institutions and other interested or affected parties. The SEP will propose an engagement program that will take place beginning with the process of socio-economic survey and continuing through the land acquisition, compensation, physical relocation, design and constructing of replacement housing, and community program development. CWEI will monitor the effectiveness of the SEP throughout the life of the project. The Karot SEP will be updated to manage dynamic situations that may arise (ESAP Action No. 10).

The Karot SEP will also be used to develop a Stakeholder Engagement Framework (SEF). The SEF is a part of CSAIL’s E&S management plan to provide principles, guidance, and tools to develop CSAIL project specific SEP.

CSAIL’s office in Islamabad:
Name and Title of the contact person: Kang, Shengzu, Commercial Manager
Address: House No.5, St.72, F-8/3, Islamabad
Telephone: +92-51-8439605
Email: mailto:shengzu.kang@gmail.com

CSAIL’s office in Karachi:
Name and Title of the contact person: Gu, Dongxu, Administration Manager
Address: House No. 75/I, H Street, Phase 6, DHA, Karachi
Telephone: +92-21-35842285
Email: mailto:gudongxu@live.com

Broad Community Support is not applicable for this project

CSAIL(34062) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Action No. 1 to meet IFC PS1: CSAIL will establish an E&S Management System (ESMS) at corporate level incorporating IFC Performance Standards, including the following: (a) CSAIL’s corporate E&S Policy incorporating IFC Performance Standards; (b) CSAIL’s procedure to establish project level ESMS; (c) CSAIL’s corporate E&S organizational structure; (d) CSAIL’s stakeholder engagement framework, including community grievance mechanism template; (e) CSAIL’s reporting and communication procedure on E&S information (e.g. ESIA, E&S performance), both internally within individual project companies, CSAIL, CWEI and CTGC; and (f) CSAIL’s chance find procedure of cultural heritage during construction of projects (PS1, but related to PS8).	30-Oct-2014	Completed	Completed	10/30/2014
Action No. 2 to meet IFC PS1: CSAIL will (i) obtain CSAIL’s board approval of the CSAIL’s corporate E&S Policy, (ii) publish the Policy internally within CSAIL and its project companies, and (iii) incorporate the Policy into the CSAIL’s E&S management system.	31-Dec-2014	Completed	Completed	12/31/2014
Action No. 3 to meet IFC PS1: CSAIL will initially appoint dedicated Environmental, Health and Safety and Social officers to manage the E&S risks of CSAIL’s projects, and establish an Environmental, Health and Safety and Social (EHS&S) Unit within CSAIL.	31-Dec-2014	Completed	Completed	12/31/2014
Action No. 4 to meet IFC PS2: CSAIL will establish: (a) a Human Resources policy for employees and contractor workers; (b) a supplemental policy and procedures with respect to staff rotation in compliance with international good practices (c) an Accommodation Policy Standards for workers camps; (d) a Worker/Contractor Grievance Mechanism procedure; and (e) an Occupational Health and Safety procedures manual to describe CSAIL and its invested individual companies’ requirements to establish and maintain occupational health and safety management system aligned with IFC Performance Standard 2 and IFC/World Bank Group Environmental, Health and Safety Guidelines.	31-Oct-2014	Completed	Completed	10/31/2014
Action No. 5 to meet IFC PS3: CSAIL will establish an Environmental, Health and Safety Procedure that ensures that pollution prevention measures are built into every project’s Environmental and Social Management and Monitoring Plan (ESMMP).	31-Jul-2014	Completed	Completed	7/31/2014
Action No. 6 to meet IFC PS4: CSAIL will establish a Dam Safety Review Procedure to engage external competent experts with dam safety review experience, separate from those responsible for design and construction, to conduct a review of dam safety for each hydropower project development.	31-Jul-2014	Completed	Completed	7/31/2014
Action No. 7 to meet IFC PS4: CASIL will establish standard contractual provisions, procedures and training requirements to ensure the appropriate conduct of security personnel, consistent with the United Nation’s code of Conduct for Labor Enforcement Officials, and UN Basic Principles on the Use of Force and Firearms by Law Enforcement Officials, and the Voluntary Principles on Security and Human Rights.	30-Sep-2014	Completed	Completed	9/30/2014
Action No. 8 to meet IFC PS5: CSAIL will develop a Resettlement Action Plan (RAP) for the Karot project and use the Karot RAP to develop a CSAIL’s Resettlement Action Framework (RAF).	31-Dec-2014	Completed	Completed	12/31/2014
Action No. 9 to meet IFC PS6: CSAIL will: (a) consult with developer of Zorlu Pakistan and through that, with WWF Pakistan and other stakeholders as required to ensure that the operational plans for TGF include procedures or other measure to minimize the impact of bird populations; and (b) assess the cumulative impacts of both TGF and WEL and propose initial operational phase bird monitoring programs, as precautionary principle.	31-Dec-2014	Completed	Completed	12/31/2014
Action No. 10 to meet IFC Stakeholder Engagement Requirement (PS1): CSAIL will develop a Stakeholder Engagement Plan (SEP) for the Karot project and use the Karot SEP to develop a CSAIL’s Stakeholder Engagement Framework (SEF).	31-Dec-2014	Completed	Completed	12/31/2014