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 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 8 – Cultural Heritage
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

The proposed IFC loan to the project is a Category B project because a limited number of specific environmental and social impacts may result, which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. Potential impacts in construction activities besides being mitigable are likely to be limited to project site; short term; and not expected to impact environmentally sensitive areas. Further, it is possible to readily design and implement engineering and management measures to mitigate adverse impacts during construction and operations.

There will be no physical or economic displacement related to this project thus Performance Standard 5 is not applicable. The wind farm is mainly located on government-owned land that is sub-leased to RP Global (one turbine will be located at privately-owned land based on longterm lease agreement). The land is not currently in use for any purpose by its owners.

Performance Standard 7 (PS 7) is not applicable as there are no indigenous peoples residing in the project area.

IFC’s appraisal considered an Environmental Management and Monitoring Plan (EMMP) for the Project and gaps between these plans 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) disclosed in this review summary. Through implementation of the EMMP and the ESAP the Project is expected to be designed and operated in accordance with Performance Standards objectives.

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.

Identification of risks and impacts

The regulatory requirements of Croatia stipulate conditions and procedures for Environmental Impact Assessment (EIA) including a definition of projects that are subject to EIA’s. The Project EIA and consultation activities were conducted in 2006 in compliance with the Croatian Environmental Protection Act and, in accordance with Croatian administrative procedure. The EIA includes analysis of geological, meteorological and social conditions and baseline flora and fauna data. Environmental impacts were analyzed and relevant mitigation measures were developed for both construction and operation stages. The EIA report and supportive materials were submitted to advisory expert committee for expert review. The committee evaluated environmental impacts associated with the project, its value and acceptability as part of the state review process. After the assessment procedure was finalized, a positive decision of the Ministry of Environmental Protection, Physical Planning and Construction on the project’s acceptability to environment was issued providing legal basis for obtaining a location permit. The EIA was developed based on technical solutions planned in 2006 and doesn’t include the current turbine type and wind farm layout. Legally the EIA is not required to be amended due to the change of turbine type (2.85 MW type instead of 2.5-2.75 MW type) and subsequent modification of the WPP layout. RPG has obtained location permit issued by the Ministry of Construction and Physical Planning. The amended location permit was issued in 2013 for the full-scope Rudine project (70MW with 24 wind turbines 2.85MW each).



Selection of the project site was a result of alternative site analysis including (i) availability of wind resources, (ii) assessment on landscaping and visual impact, (iii) noise impact to local communities, (iv) access to the site and relative vicinity of the National electric grid station point, (v) vicinity to human settlement, (vi) location of protected areas or water courses in the Project’s area and (vii) the community’s interest in exploring the use of renewable.



The Dubrovnik - Neretva County plans to get involved in renewable energy projects according to the Strategy for Energy development of Croatia. As stipulated by the Spatial plan of the County an important factor for the development would be the construction of a new business-production zone, airport and wind power plant in Rudine (near future nodes of the Adriatic highway and high-speed road Ploče – Pelješac – Rudine). Plan for use of renewable sources of energy in the Dubrovnik – Neretva County is being developed currently by OIKON Ltd and Rudine is considered as one of WPP location in the region as confirmed by the plan developer. Project location was identified by the Regional Spatial Plan in accordance with the following principles: (1) wind power plants should be located out of coastal area, protected and planned for protection parts
of nature, planned construction sites, infrastructural corridors, high woods and agricultural land, zones exposed to views of valuable landscape and from sea and protected cultural and historical complexes, known bird''s flyby corridors and corridors of bats migration; (2) wind power plants should be located at least 500 m away from settlements and other objects and level of noise should not exceed 40 dB(A) to coordinate setting of wind power plants regarding telecommunications devices (radio and TV transmitters, navigation devices) to avoid electromagnetic disturbances.

According to the existing Spatial Development Plan for the County a wider project area is planned for both wind farm development and for a small airport; however given that Rudine project is in very advanced phase of development i.e. location permit obtained, any other projects like the airport project or the Golf Course, which has not been initiated yet, will have to take into consideration the current status of the wind project and accordingly change its sitting and/or modify its design, if necessary.



In addition to the legally required EIA, RPG has developed a Supplemental EIA which provides updated information on turbines, summarizes potential impacts based on the updated project scope, includes mitigation plan and monitoring program during construction and operation.



Key stakeholders have been identified by RPG and methods of communication and frequency have been defined as part of the supplemental EIA.



For any future extension i.e. development of the second stage of up to 70 MW, RP Global will ensure that cumulative impacts at this site are assessed and mitigated in a manner consistent with the IFC Performance Standards.



Management and Monitoring Program

As part of the Supplemental Report, an EMMP was developed consisting of the mitigation plan and monitoring plans. The mitigation plan is a key component of the EMMP. It summarizes key potential impacts during the project construction, operation and decommissioning and defines necessary measures to mitigate identified impacts. The Mitigation plan also specifies responsible parties for the implementation of planned mitigation measures and defines timeline. RPG will regularly review the EMMP to ensure mitigation measures are amended when required.. Relevant mitigation measures will be translated into environmental and social development requirements and made part of the contracts for the construction activities. The EMMP will be modified and amended by construction contractor and O&M operator. Major mitigation measures for identified potential impacts are summarized under relevant PS sections below.



Organizational Capacity

RP Global will formalize the EHS management system to ensure adequate management of EHS risks associated with the Rudine WPP construction and operation. Environment, health and safety roles will be defined for day-to-day support on EHS risk management. At a minimum there will be an in-h
ouse specialist responsible for overseeing and monitoring the entire implementation of the mitigation measures as defined in the EIA and EMMP. The EMMP as well as environmental management requirements and specifications will be included in all contracts with contractor(s), which will be required to appoint a dedicated field EHS manager at the project site.



Environmental and social training plan will be developed and implemented by RP Global, as per ESAP, to ensure that the key environmental and social requirements are clearly understood and followed by all project personnel including contractors throughout the entire project cycle. The environmental, health and safety training program will be finalized and delivered before the commencement of the project for the project staff. The scope of the trainings will cover general environmental awareness and the requirements of the EIA and the EMMP, including (i) general environmental, health, safety and social awareness; (ii) environmental and social sensitivity of the project area; (ii) key findings of the EIAs; (iv) mitigation measures; (v) social and cultural values of the area with special emphasis on sensitizing the project staff to the environmental and social aspects of the area. RPG will ensure that the contractor provides similar training to its workforce before the construction begins. During the O&M phase of the project, these trainings will continue to be conducted by RP Global, as needed.

RPG has a written HR Policy and procedures for both employee and non-employee workers. The RP Global HR policy and procedures are in line with Croatian Labor Law and IFC Performance Standard 2 (Labor and Working Conditions) i.e. to address workers’ rights related to contracts and terms of employment, working hours and overtime, training, leaves, grievance redress, retirement, employee welfare, disciplinary action, health and safety, and benefits wages and benefits, the principle of equal opportunity, fair treatment and non-discrimination and grievance mechanism. No retrenchment is planned by RP Global in relation to the project realization.



A very comprehensive OHS legislative system has been developed in Croatia and RP Global will implement various mitigation measures to ensure compliance with this. Health and safety staff will be appointed and present on the construction site during working hours and will include an on-site first aid emergency capacity.



Occupational Health and Safety

A Balance of Plant (BOP) contractor will be contracted by RP Global for the realization of construction works in Rudine, and its EHS plan should be integrated into the EMMP. EHS performance of tenderers should be considered during the tender process and proof of its good OHS practices should be submitted in order to be shortlisted for the work and similar practice should be implemented by the chosen contractor for further selection of subcontractors.



All employees will be provided with the necessary EHS training and personal protective equipment as required for their responsibilities. Safety & health plan, including emergency response and hazardous material/waste management plans are obligatory under National OHS law and will be part of the EMMP plan.



All contracts with contractors and subcontractors will include a clause requiring compliance with the EMMP and PS2.



During the construction phase RP Global will have the primary responsibilities for managing EHS risks through its own EHS staff and via an ongoing coordination with the contractors’ EHS managers to ensure that the project is in compliance with the EIA and EMMP throughout the project construction. RP Global will also coordinate with relevant government departments and other stakeholders on any matters related to the EHS aspects of the wind farm construction.



During the operation phase of the project, management of EHS and social development aspects will become a routine function, as an integral part of the O&M activities. RP Global through its EHS staff will be the focal point for all matters relating to EHS aspects during the routine operations of the power plant. General Electric, an equipment supplier and O&M operator, maintains a corporate EHS Management System and will be required to apply the EMMP with regard to occupational safety (including usage of PPEs, safe behavior).

Construction

Existing local roads will be expanded and used for the project i.e. truck loads of construction material, ready-mix concrete, turbine parts, etc. New access roads to individual turbines will be established. Road construction and expansion, digging or blasting for turbine foundations and transformer station will require proper drainage and erosion management; for this a specific contractor actions and responsibilities list will be set in the EMMP. Excavated material generated during construction of the wind farm will be reused for local landscaping and internal roads construction. Any land that will be disturbed and excavated during construction will be re-contoured and returned to its original state as much as possible. Existing roads, if used for underground cabling purposes (between turbines and the substation) will be reclaimed to their original state after cable installation.



A limited quantity of waste will be generated during construction and maintenance (packaging, metals, plastics, filters, oils etc.), which will be disposed of in designated places, collected by licensed contractors and/or recycled where possible. Oily contaminated water from parking area will be passed through an oil separator before discharge in the perimeter canals.

As part of the contractor’s construction management plan a hazardous materials management procedure will be established for appropriate selection, purchasing, storage and handling of fuels and chemicals which will be used on the site. There will be no on-site maintenance of vehicles so to avoid accidental soil pollution. Fuel storage will be fully contained and spill response equipment will be present on site. The Contractor will prepare a fuel management plan and a spill control, prevention, and countermeasure plan as a specific component of their Emergency Preparedness and Response Plan.



Temporary on-site sanitary facilities will be established and domestic wastewater will be collected by the licensed contractor. Diesel generators will be used for power to operate the construction equipment and for any other on-site requirements, like welding. Emissions from the generators will be minimized by ensuring that the engines are always properly tuned and maintained. Construction machinery and vehicles will use low sulfur content diesel fuel.



There can be some dusting on the area due to construction machinery and traffic on roads to the location. These impacts have a local character, reduced time length and are without permanent after effects.



During the wind farm construction period noise in the environment will occur as a result of construction machinery operation and heavy goods vehicles related to operations at construction site.

Environmental impacts during the construction works will be temporary in nature (total duration of construction should not exceed one year). During the construction phase RP Global through its main contractor(s) will ensure that the project is develop
ed according to National Guidelines for Wind Farm development, EMMP, IFC EHS Guidelines for Wind Project and good industry practices.



Operational Phase

The project is a net benefit from air pollution perspective as it will generate electricity from renewable resource.

Annual greenhouse gas (GHG) emission reduction is estimated at 24,241 ton CO2 per year, based on the Croatian’s combined margin GHG grid emission factor per unit of electricity generation of 0.32 ton CO2/MWh (2010).



O&M activities will not be very extensive. This will include mainly normal periodic maintenance activities. There will be no residential staff at site.

In the project area there are few existing facilities as follows: asphalt plant, hunter''s lodge, house located just next to the main road / opposite the asphalt base. Asphalt plant is a temporary (mobile) facility, which is planned to be moved once work is finished on building sites in proximity. Hunters lodge was constructed illegally (the nearest turbine is 300 meters away from the lodge). House on the main road (appr. 500 meters from the nearest turbine) has no permanent residents. The nearest settlement Doli is located in 500 meters from the planned WPP.



The main risk to the communities relates to the transport of heavy equipment and parts on local roads. RP Global will be responsible for notifying the communities and verifying that contractors enforce mitigation measures. The turbines will be transported from the port of Ploce to the project site. As required by law RP Global will develop a Traffic Management Plan for the contractors involved in construction activities to ensure that the movements are phased and the hours of movement limited to the working day. In addition, the movement of construction vehicles will be routed to avoid residential areas where possible, thereby minimizing potential noise and dust impacts.



During the wind farm construction period noise in the environment will occur as a result of construction machinery operation and heavy goods vehicles related to operations at construction site. Noise impact may at times be significant on the surrounding household, located approx 500 meters from the site, during the construction activities and from traffic generated by the construction machines and trucks passing through local roads on their way to and from the project site. During construction the contractor will develop procedures to control ambient noise at nearest receptors through selection of adequate low-noise producing land-based equipment, including compressors and generators.



Due to the big distance between the turbine and the closest settlement (500 meters) noise impact during operation phase is expected to be below maximum levels as per Croatian requirements established for residential areas (40dBa/50dBa during night/day). In accordance with the EMMP, RP Global will conduct measurements during the first year operation to confirm conducted noise modeling. Furthermore, in case of complaints RPG will carry out similar measurements and will discuss any mitigation requirements with the affected persons.



The project will influence the landscape of the local communes and could be considered visually intrusive. Modelling was conducted to assess the visual impact during the project design. The wind turbines will create large elements, contrasting with the existing character and be partly visible from nearby villages and houses. To mitigate the impact RP Global will use wind turbines in a gray-white color and a transformer station was designed in a way to fit into the landscape.



Magnitude of shadow flicker imp
acts is expected to be low i.e. based on calculations conducted in 2006 a maximum 4.5 hours during a year (based on the 2.5-2.75 turbine type). Considering the change of turbine type (GE2.85) the exposure to shadow flicker is not expected to be significantly different. Should impacts occur adversely affected communities will be identified and relevant mitigation measures will be included in the EMMP and implemented.

Natura 2000 is an EU wide network of nature protection areas established to assure the long-term survival of Europe''s most valuable and threatened species and habitats. It is comprised of Special Areas of Conservation (SAC), and also incorporates Special Protection Areas (SPAs). Natura 2000 applies to birds and habitats sites. In the framework of NATURA 2000 network, Croatian obligation is to implement two EU nature protection directives (Bird and Habitats Directive). In October 2013 Government of Croatia adopted new Regulation on ecological network (OG, No. 124/13). In accordance with the recently adopted Regulation wind farm Rudine is planned outside special protection and conservation areas. The nearest Natura 2000 area is locality HR2001490 Dubrovačko Primorje – Doli. Qualifying species is an orchid plant Himantoglossum adriaticum which is included in the national Red List. Other Natura 2000 special areas are located 5 km away from the WPP site, therefore it is expected that the project will not have any impact on these areas. During construction works RP Global should ensure that contractor’s activities are performed within the designated boundaries to avoid any potential impact on the protected species.



At the project location there are no protected areas or areas proposed for protection in one of the categories under the Nature Protection Act (OG, No. 80/13). The nearest especially protected area (4821.4 ha) is located between the coast and the peninsula of Peljesac along the Mali Ston Bay in the Adriatic Sea protected in the category of special marine reserve.

Ornithological field survey was conducted from November 2001 to November 2002 to ensure all seasons are covered. The expert who was involved in the original ornithological survey program in 2001 – 2002 has confirmed that the current ornithological baseline doesn’t differ significantly from the original (2001-2002) baseline data. Based on the survey the avifauna of wider area of Rudine is represented with 51 bird species out of which 27 are nesting birds. Distribution of species in time has shown highest number in time of autumn migration and nesting time and in time of spring migration and lowest in wintering. Two recorded bird species (Gallinago gallinago i Scolopax rusticola) are known to be in in category of critically endangered. This two species are recorded only in one location. RP Global will carry out monitoring of impact of project''s related activities on bird population as minimum during the first two years after the WPP commencement in accordance with the detailed scope of work as provided in the Supplemental EIA. Monitoring will include scanning of Rudine wind turbines’ surrounding area and recording of injured birds; observation of flights from permanent observation points; monitoring of nesting population of prey birds on surface of 2 km around the WPP; monitoring of potential impact on community of smaller birds and song birds through transect. The construction c
ontractors will be instructed by the Sponsor to avoid excessive and prolonged construction activities during the period between March and July to avoid disturbances to the nesting birds.



Based on conducted desk study review 27 bat species which are all in the category of strictly protected indigenous species are determined. In accordance with the Supplemental EIA RP Global will carry out bats survey programme including pre-construction and post-construction monitoring (during first two years of operation). RP global has developed comprehensive program for bat fauna monitoring in accordance with national and UNEP/EUROBATS Agreement on the Conservation of Populations of European Bats. The first year of pre-construction/construction monitoring will be carried out through a detailed one-year preliminary study of bat populations in the wider area around the planned construction site. Field survey will be conducted in total of 24 field days during one year, throughout a timescale which reflects the full cycle of bat activity. Post construction bat fauna monitoring will be conducted for two years and it will include bat mortality monitoring as well (4 days per month in a period from the beginning of March to the end of October).



Birds/Bats monitoring data will be analysed and if an increase in birds or bats population mortality is recorded the EMMP will be amended in cooperation with qualified specialists to ensure decrease of mortality to acceptable level. The corrective measures should be developed and implemented in compliance with IFC EHS Guidelines for Wind Energy (30 April 2007).

Archaeological Study was conducted as part of EIA process in 2006 and archaeological objects were identified in Rudine area. There is an archaeological zone Podimoc within the project area which mainly consists of stone piles (tumuli). Taking into consideration findings on cultural heritage and mitigation measures determined by the Archaeological Study, the Project Layout was changed in order to minimize the impact on cultural- historical heritage (to ensure turbines are located at least 250 meters away from the endangered archaeological sites). RP Global will develop a chance find procedure as part of its EMMP in accordance with IFC Performance Standard 8. In the event that cultural heritage is subsequently discovered all works should be stopped and competent conservatory department should be notified which will then give instructions on further actions.

After the original EIA was finalized in 2006, a public consultation process was conducted, and consequently granted location permits. During this legal process no negative feedback on the project was received by the company or MoEnv. IFC’s appraisal of the project confirmed the Dubravacko Primorje municipality officials supported the project.

RP Global has developed a simple Stakeholder Engagement Plan (SEP) that describes the key stakeholders and the ongoing information and communications plans relating to the project. The SEP will be reviewed periodically before and during construction and operation and will be updated as necessary; contact will be maintained with the communities, their views and concerns solicited. The outcome of these consultations will be discussed during periodic meetings with affected stakeholders. Public announcements through newspapers, radio and other appropriate channels to inform the affected villages regarding construction commencement will be made; additional announcements and, if needed, public meetings will be planned in relation to the full set of EIA, including Supplemental Report and any new EHS related information.

As part of SEP a grievance redress mechanism (GRM) is designed to address concerns that the communities living in the vicinity of the project may have in relation to the project activities, their impacts, compensation and other mitigation measures. The main objective of the GRM will be to provide a mechanism to mediate conflict. It will also facilitate people who might have objections or concerns regarding the project activities, provide a public forum to raise their objections and through conflict resolution, to address these issues adequately. 
RP Global will make available the original EIA, Supplemental Reports, EMMP and SEP to all the stakeholders before the commencement of construction. This will ensure that the local communities are brought up to date and made aware of the project, its key impacts, the mitigation measures and the implementation mechanism.

The following documents are disclosed as attachment to this ESRS:
Environmental Impact Assessment report for “Rudine” wind farm, prepared in 2006;
Supplemental Report to EIA, prepared in November 2013, including SEP and EMMP;
Environmental and Social Action Plan, January 2014.

The Company will also locally disclose the above listed documents at the Company’s offices in Zagreb, Dubravacko primorje Municipality and the project site office. Also, for more information, enquiries and comment about the Project and local access of documentation please contact:

Mr. Bojan Rescec, Country Manager
RP Global Projekti d.o.o.
Bijenicka 21, HR 10000 Zagreb
(t) +385 1 463 64 63
mailto:mailto:b.rescec@rp-global.com
http://www.rp-global.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
Define EHS roles and responsibilities and designate responsible personnel for implementing the project EMMP and day-to-day support on EHS performance of the project, including activities undertaken by contractors and other third parties	06/30/2014	Completed	Completed	07/29/2014 12:00:00 AM
Formalize an Environmental, Health and Safety Management System: (i) Develop EHS training plan for own personnel and contractors; (ii) Update EMMP based on identified EHS risks and impacts of the project.	06/30/2014	Completed	Completed	09/26/2014 12:00:00 AM
Incorporate relevant EHS obligations in the contracts with BoP/Turbine Supply/O&M contractors on implementation of mitigation measures based on the EMMP.	12/31/2014	In Progress	Under discussion with IFC client
Develop and implement a Traffic Management Plan (TMP).	06/30/2014	In Progress	Under discussion with IFC client
Retain an Independent Expert and develop and implement a detailed birds/bats monitoring program in consultation with the ornithological society of Croatia.	06/30/2014	Completed	Completed	09/26/2014 12:00:00 AM
Develop a Chance Find Procedure (CFP) in accordance with the IFC Performance Standard 8. EPC Contractor should be trained on required actions.	06/30/2014	Completed	Completed	09/25/2014 12:00:00 AM