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 IFC's 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

The proposed project is to develop a 50 MW wind farm plant in a semi-desert area and mostly barren land with sparse vegetation with limited potential adverse E&S risks and impacts that are few in number, generally site-specific, largely reversible, and readily addressed through mitigation measures, and therefore, it is a category B project. Key E&S risks and impacts include effectiveness of the mitigation measures for noise and shadow flicker, cumulative impacts of the project and other wind farm projects being developed in the same wind corridor, disturbance by migration of workers during construction phase, land use change of the area, and stakeholder engagement.

Performance Standard (PS) 5 is not considered applicable to this Project as it will not require any acquisition of land or relocation of people. PS7 is not considered applicable as no Indigenous Peoples are located in the project area. PS8 is not considered applicable due to the lack of cultural heritage features and stakeholder engagement processes.

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.

Policy:



GAWPL has a Social Environment Health & Safety Policy, dated December 2013. This policy describes GAWPL’s commitment to conducting all their operations in compliance with the applicable laws, regulations, and international guidelines and best practices in order to meet their E&S contractual obligations to investors, lenders, customers and other relevant stakeholders. GAWPL also has Code of Business Conduct and Ethics, dated December 2013, which states GAWPL’s commitment to conduct its business in compliance with the GAWPL Social Environment Health & Safety Policy. As per the agreed ESAP, the signed policy will be displayed at the corporate office, the project operation site and at the website of the Company by January 31, 2015 (ESAP Action No. 1).



Identification of Risks and Impacts:



In 2009, the Company conducted an Initial Environmental Examination (“2009 IEE”) and obtained an environmental approval from the Sindh Environmental Protection Agency (“Sindh EPA”) on June 1, 2009. The Company obtained a further extension of this approval from Sindh EPA on December 24, 2012. In 2013, the Company retained an international environmental consulting firm (ERM) to perform a gap assessment of the 2009 IEE report and to update the IEE report to comply with IFC 2012 Performance Standards. The scope of updating the 2009 IEE included: (i) revisiting the E&S baseline data presented in the 2009 IEE report; (ii) updating impact assessment and mitigation measures; (iii) developing an Environmental and Social and Management Plan (“ESMP”); (iv) undertaking stakeholder mapping and developing management framework for stakeholder engagement and grievance redress, emergency preparedness and response, health and safety management, labor management, and community development / corporate social responsibility; (v) upgrading mitigation plan for flora and fauna; and (vi) developing framework for E&S monitoring and reporting. The updated IEE report (“2013 IEE Update”) was further supplemented with additional reports including the Shadow flicker Study conducted by ERM, and Stakeholder Engagement Plan prepared by Tekcellent (a local E&S consulting firm that worked with ERM on the 2013 IEE Update), both dated August 2014. All these reports were the basis of IFC’s review, and are disclosed as attachments of this ESRS.



Key E&S gaps identified by the 2013 IEE Update included formal E&S Management System (or “ESMS”) and linkages with subcontractors responsible during construction and operational phases, organizational structure of GAWPL for effective implementation of ESMS and linkage with EPC / O&M Contractors’ organizational structure, stakeholder engagement plan during the entire project lifecycle, addressing social and community health and safety impacts including any livelihood and land issues, staff accommodation, community health and safety issues during construction phase, shadow flicker and noise impact assessment, lack of attention with respe
ct to environmental, health and safety aspects in labor camps, cumulative impacts from the other wind farm projects in the same corridor, inadequate mitigation measures for flora & fauna in terms of site clearance, movement of vehicles, cutting of trees for fuel by laborers etc., lack of information on continuous plan of stakeholder engagement to ascertain the consultation activities that have taken place since 2009. All these were addressed in the 2013 IEE Update.



Cumulative Impacts:



Cumulative impacts were considered in the 2013 IEE Update for visual impacts, shadow flicker and noise, birds and bat collision, and social aspects. On the visual impacts, currently, the entire project area is semi-arid barren lands with rock outcrops and sparse vegetation. In total 11 wind farm projects are planned to be developed in the Jhimpir Wind Corridor, and the WTGs visible against the skylines are predicted to reduce the sense of remoteness or wilderness among the villagers and the travelers crossing the area. The distance between each WTGs, the color of the turbines towers and blades will play a role in the overall landscape quality. Due to the unavailability of the WTGs information of other future wind farm projects, adequate cumulative visual impacts could not be made in the 2013 IEE Update.



Shadow flicker cumulative impacts were assessed and evaluated as negligible in the 2013 IEE Update because most of the wind farms will be located more than 1 km south of the GAWPL site. Cumulative shadow flicker impacts of GAWPL and MPCL projects were also determined as negligible.



Noise cumulative impacts were assessed from GAWPL and MPCL projects and the cumulative impacts were evaluated as negligible during the day time, whereas during night time, the cumulative noise levels at one of the receptors (Qasim Burfet Goth) was predicted to be in the range of 46 to 48 dBA, slightly exceeding the night time noise criteria of 45 dBA, and therefore evaluated as minor. The Company, in coordination with MPCL, will conduct a periodical noise monitoring and implement additional noise attenuation measures (e.g. constructing noise barriers) in case of complaints received from the local population.



As described under PS6 section, the Keenjhar Lake Wildlife Sanctuary is about 15 km from the GAWPL project site. As recommended by the 2013 IEE Update, the Company initiated a detailed bird study to assess the Project’s impacts on birds. This will help in identifying whether the GAWPL project site lies in the route of migratory birds requiring potential WTGs operational mitigation measures such as turbine shut-off. Cumulative impacts of multiple wind farm projects on birds could not be assessed due to the unavailability of data on number, height and location of WTGs from other wind farms. For further information and the proposed approach by the Company, please see the paragraphs under PS6.



Associated Transmission Lines and Grid Stations:



NTDC
has a plan to expand the grid system of the project area so that the electricity generated from the wind farm projects being developed in the Jhimpir Wind Corridor can be transmitted to the national grid without delay. According to the latest grid connection scheme (Interconnection Schemes for Power Evacuation of 11 No. WPPs at Jhimpir Cluster and 6 No. WPPs at Gharo/Bhambore Cluster) obtained during the appraisal visit in July 2014, several new 220 kV and 132 kV transmission lines and two new grid stations are required to be developed. These transmission lines and grid stations are subject to Environmental Impact Assessment according to Pakistan Environmental Agency (Review of the IEE and EIA) Regulations, 2000. Some of these transmission lines and grid station(s) are considered as associated facilities which are needed for the successful implementation of the Project. The implementation of the EIAs is the responsibility of NTDC. Nevertheless, as per the agreed ESAP, the Company will monitor the progress of the EIAs for the identified associated facilities by keeping close contact with NTDC (ESAP Action No. 2).



Social Impacts – Villages in the Affected Area:



The 2013 IEE Update identified that the project site does not have any villages within the project site boundary, but there are six villages (Haji Lakhano Goth, Haji Walloo Goth, Murad Ali Chang, Muhib Chang Goth, Ragho Chang Goth and Allah Dino Chang Goth) that are located close to the project site boundary. Further it identified that a primary school of the Muhib Chang Goth and a mosque (Al-Makkah) fall within the GAWPL site boundary. Noise and shadow flicker assessment in the 2013 IEE Update covered all these receptors. Micro-setting of WTGs locations (as part of the energy assessment) was adjusted considering the sensitivity of nearness to the villages especially that of Haji Lakhano Goth, Haji Waloo Goth and Muhib Chang Goth.



The economic poverty, gender sensitivities, lack of essential infrastructure (e.g. health infrastructure, drinking water supply, vocational training, all-weather and motorable access roads), and the need to protect cultural norms from the influx of workers and job seekers from outside the project area, are important issues in the project area. The Company and the Sponsors took these into consideration when conducting the stakeholder engagement activities, and most recently when planning the stakeholder engagement meeting of June 2014. The IEE approval of 2009 and its extension in 2012 issued by Sindh EPA clearly stated “Benefits to local people will be offered under Corporate Social Responsibility (CSR) policy, community development schemes will be decided in consultation with local communities and may be facilitated by involving direct/local Government Office.” The Sponsors have been providing support to the local communities since 2009, and as per the agreed ESAP, The Company will update the CSR activities based on the recommendations of
the 2013 IEE Update (ESAP Action No. 3).



Management Programs:



As part of the 2013 IEE Update, an Environmental and Social Management Plan (“ESMP”) was prepared as a consolidated list of mitigation measures and commitments from the impact assessment. The ESMP sets out the arrangements that will be put in place by the Project to manage the E&S performance of the GAWPL project, outlines further studies and surveys that are required to redefine predicted impacts and design appropriate mitigation strategies, describes the monitoring programs required to assess accuracy of predicted impacts and adequacy of mitigation strategies, and provides a framework for compliance auditing and inspection of the Project by the Company. To supplement the ESMP, the 2013 IEE Update included proposed framework management plans (Stakeholder Engagement Plan Framework, Construction Labor Management Plan Framework, Emergency Response and Preparedness Plan, and Health and Safety Management Plan Framework). In preparing the Stakeholder Engagement Plan, dated August 2014, these framework management plans were further updated to (i) Construction Labor Management Plan, (ii) Emergency Preparedness and Response Plan, and (iii) Health and Safety Management Plan.



Organizational Capacity and Competency:



During the construction period, GAWPL will have an EHS Manager and a Community Relationship Officer to manage ESMS implementation in coordination with the E&S team of the EPC Contractor (Nordex and Descon). The social issues will be looked after by the Community Relationship Officer who will report to the EHS Manager. The EHS Manager will in turn report to the CEO of GAWPL. During the operational period, Engineering and EHS Manager will be appointed reporting to CEO of GAWPL. This manager will coordinate the ESMS implementation in coordination with the O&M Contractor (also Nordex and Descon). A Community Relation Officer will be working under the Human Resources Department. As per the agreed ESAP, the Company will appoint these officers prior to the start of the construction, and operation (ESAP Action No. 4).



Emergency Preparedness and Response:



The Emergency Preparedness and Response Plan was prepared for the GAWPL project in August 2014. Various emergency scenarios (injuries, turbine incidents such as fire, over-speed, or debris separation, wind turbine runaway, and bomb threat) were considered and corresponding response details were prepared. This will be updated based on the final arrangement with the O&M Contractor.



Monitoring and Review



For each of potential E&S impacts and required mitigation measures identified, the ESMP that was prepared as part of the 2013 IEE Update provides timing and frequency of monitoring, responsibility for implementation of monitoring, and reporting requirements. GAWPL will form a system through which the Company can audit the implementation of ESMP, check the robustness of the ESMP, and introduce changes wher
e required and take corrective actions.

Working Conditions and Management of Worker Relationship:



The Company has not established GAWPL’s Human Resources policy / procedures yet. Before the construction starts in the 1st Quarter of 2015, the Company will prepare its Human Resources policies / procedures setting out its approach to managing workers consistent with the requirements of IFC Performance Standards. The HR policy will include information dissemination to workers regarding their rights, regulating working conditions, staff welfare, health, non-discrimination, equal opportunity, non-tolerance of child & forced labor, workers’ organizations, retrenchment, grievance redress mechanisms and contractor monitoring and management of labor and their working conditions (ESAP Action No. 5).



During the construction phase of the project, GAWPL estimates that the Project will employ 600 workers and 100 support staff that include technical, security and administration, mostly by EPC Contractor. During the operational phase, the manpower requirement will reduce to about 30 workers, most of whom are likely to be highly skilled and recruited by the O&M Contractor. In addition, additional employment opportunities are estimated to include maintenance work for balance of plant facilities, 24 hour security and housekeeping / cleaning contracts. A construction labor accommodation camp will be constructed within the project site, and at least 1 km away from any settlement to avoid disturbance to the local people (Sindh EPA’s specific requirement in the IEE approval).



A Construction Labor Management Plan was prepared in August 2014 and this provides a framework to protect every worker against the dangers of injury, sickness or death through safe and healthy working conditions, thereby assuring the conservation of valuable manpower resources and prevention of loss of lives, consistent with IFC Performance Standard 2, IFC Guidelines on Worker Accommodation, and applicable laws on labor and working conditions in Pakistan.



Through the stakeholder engagement activities conducted, the Company is aware of the strong expectation by the local community for the Project’s job opportunities. The IEE approval issued by Sindh EPA in 2009 clearly stated “Employment will be provided to local people and assured for all unskilled jobs. Skilled jobs will be given to the locals after providing them proper field training, where a minimum training will be required”. As recommended by the 2013 IEE Update, the Company will develop an Employment Plan to define requirements and procedures on identifying and developing employment opportunities, managing employees, recording and reporting employment data, terminating work contracts, and other labor-related issues. This Plan will include a skill development program to help enhance employability of the local population, and a local hiring program to ensure that unskilled and semi-skilled labor be hired from the local communities. As per the agreed ESAP, t
he Company will develop this Employment Plan by January 31, 2015 (ESAP Action No. 6).



Protecting the Work Force:



The national minimum age for employment in Pakistan is 15 years. However, the client will prohibit employment of workers below the age of 18 for hazardous work or work that is harmful to their health and development both for their own operations and for the EPC Contractor and O&M Contractor.



Occupational Health and Safety:



A Health and Safety Management Plan was prepared in August 2014 and this covers occupational health and safety management. The Company will update the occupational health and safety components of the Health and Safety Management Plan before start of the construction and operation, based on the final arrangement with EPC and O&M contractors.

Resource Efficiency:



According to the Clean Development Mechanism (CDM) Project Design Document prepared for GAWPL, the project is estimated to achieve 93,783 ton CO2 equivalent per year reduction, assuming the project’s electricity generation of 151.9 GWh per year and the CO2 emission factor for the national grid in Pakistan of 0.6174 tCO2e per MWh.



During the operational phase of the Project, about 1 to 1.5 m3 of water per day will be required. This will be obtained from Nooriabad, a nearby industrial town in the area, and stored in a tank on-site. Packaged potable water will also be obtained from Nooriabad for meeting the requirements of 20 persons. Considering the water scarcity in the region, the Company will adopt water conservation measures to reduce the usage of water, and use recycled water as much as possible. No major water body is present within the project site boundary, and the area has rain water only during months of July and August. The Company is considering an option to divert the storm water runoff, where possible, from the constructed areas of the wind farm for irrigating the surrounding open area provided to the villagers. As per the Agreed ESAP, the Company will prepare the storm water diversion plan (ESAP Action No. 7).



Pollution Prevention:



The 2013 IEE Update conducted the noise impact assessment for different wind speed levels for affected receptors of which distance from the WTGs are in the range of 500 m to 2,720 m, including the sensitive receptors such as Muhib Chang School and Mosque. The predicted noise levels under the scenario of all the WTGs operating at 100% usage show that predicted noise levels will all comply with the World Bank Group / IFC ambient noise guideline limit of 45 dBA (night time). As recommended by the 2013 IEE Update, the Company will periodically monitor the noise levels near to the sources of generation to ensure compliance with design specifications, and in case of complaints of higher noise levels and uncomforting received from the inhabitants of nearby settlements, the Company will take additional measures such as putting noise barriers near to the receptor.



Out of the total 59 houses located within 2,000 m zone from each WTGs (which is considered as potential shadow flicker impact zone), shadow flicker is predicted to occur at 46 houses with the number of shadow flicker hours per year ranging between 4 hours and 41 minutes to 41 hours and 58 minutes. Using the internationally recognized shadow flicker guideline of 30 hours or less per year (German guideline), 8 houses are predicted to have shadow flicker impact exceeding this limit with estimated number of hours per year between 30 hours and 59 minutes to 41 hours and 58 minutes per year. The shadow flicker assessment proposes the following mitigation measures: (i) GAWPL will closely monitor the actual shadow flicker through engagement with residents during the operational phase, and the potential for using
screening like higher fencing and planting trees be explored; and (ii) if these measures proved to be ineffective, further analysis be carried out to identify the exact timings and conditions under which shadow flicker occurs, and a technical solution be sought, which is likely to involve pre-programming the turbines with dates and times when shadow flicker would cause a nuisance for affected receptors. GAWPL is committed to implement the proposals and will report the progress annually to IFC.

Community Health and Safety:



A Health and Safety Management Plan was prepared in August 2014 for the Project, and this includes community health and safety management arrangements. Specific measures to minimize the Project’s risks to community health and safety includes cordoning off the construction site from free public access to avoid exposure of local community to health and safety risks, posting information boards about public safety hazards in the work area in the local language and emergency contact information, recording all incidents and accidents involving community stakeholders and implement corrective actions, requiring contractors to keep record of outside labor and assure about their good health by pre-placement medical examination, providing good workforce accommodation and discouraging workforce to live outside the accommodation, raising awareness about STDs and HIV, and requiring workforce to maintain behavior standards while moving in the community. On the risks to community health and safety due to heavy traffic movement during the construction phase, the Plan also describes specific measures for the traffic and road safety management, and those include monitoring of traffic loads throughout the day to minimize chances of road accidents, and requiring vehicle drivers to comply with speed limits.



Security Personnel:



The Company estimates it will employ about 20 security guards during operations. The Company plans to employ the security guards mostly from local community to ensure good relationships between the Company and local population. The system for grievance mechanism for affected communities is included in the Stakeholder Engagement Plan, and the Company will ensure that any concerns by local community about the security arrangements and the acts of security personnel will be addressed through this system.

The 2013 IEE Update describes that (i) the project site and its surrounding area fall under degraded lands with few irrigated areas, (ii) none of the plant species in the area belong to protected, or endangered category, (iii) the plant and animal species identified are those commonly found in the dry habitat, and (iv) no wildlife reserves are located in close vicinity of the project site, no major water body is present within the site boundary, but there is a Keenjhar Lake Wildlife Sanctuary, a designated Ramsar wetland and Important Bird Area, about 15 km from the GAWPL wind farm site.



The 2013 IEE Update analyzes that out of the 59 species of birds reported from the project and surrounding area, the Saker Falcon (Falco cherrug) was listed as Endangered as per the IUCN category; Imperial eagle (Aquila heliacal) was listed as Vulnerable; and the Long tailed Bush Warbler (Prinia burnesii) and Kashmir Roller (Coracias garrulous) were listed as Near Threatened.



The 2013 IEE Update recommended that to assess the exact impact of the WTGs on the birds in the project area, additional detailed studies would be required. A bird monitoring plan was developed as part of the 2013 IEE Update by a company called Elan Partners. A bird monitoring consultant (“Ideal Services”) was retained to implement the bird monitoring activities and started monitoring activities in 2014. GAWPL and MPCL retained two full time bird monitoring persons from local community to do on-site daily bird monitoring. Data collected by the bird monitors is submitted to Ideal Services on a weekly basis for verification. An initial site visit was conducted by Ideal Services in May 2014 at the start of the study and one quarterly site visit by Ideal Services was done in October 2014. Data collected will serve as baseline in the bird monitoring activities for the operational phase. More detailed and prolonged studies on the impacts on birds will be undertaken in the migratory season of birds (October – March). Ideal Services experts will visit the site quarterly and a bird monitoring report is planned to be issued by the third quarter of 2015. As recommended by the 2013 IEE Update, the Company is committed to conducting bird mortality count in the immediate vicinity to establish any links between the wind turbines and birds mortality for two years starting from the commissioning of the wind farm. As per the agreed ESAP, the Company will review the results and recommendations of the bird monitoring study (May 2014 to April 2015) to be conducted by Ideal Services, and determine the need for additional mitigation measures beyond what were described in the 2013 IEE Update (e.g. operational turbine shut-off) (ESAP Action No. 8).



As of October 2014, there are two wind farm plants operating in the Jhimpir Wind Corridor, and additional multiple wind farm projects are being planned including those by GWAPL and MPCL. The 2013 IEE Update shows that in total 11 wind farm plants
may be developed in the same wind corridor. As per the agreed ESAP, the Company and the Sponsors will re-engage with the IUCN / WWF-Pakistan (which manages the protection program of the Keenjhar Lake) and other wind farm developers in the Jhimpir Wind Corridor to initiate discussion about benefit of sharing bird monitoring data and expertise so far accumulated and feasibility for joint evaluation of cumulative impacts of wind farms on the birds an bats (ESAP Action No. 9).



It should be noted that the UNDP/GEF Wind Energy Project conducted an initial Regional Environmental Assessment of the Gharo Wind Corridor (including the Jhimpir Wind Corridor) and developed a set of guidelines for environmental assessment for wind farm in this corridor (“Guidelines for Environmental Assessment of Wind Farms in the Gharo Wind Corridor – Pakistan, June 2009”). These Guidelines specifically proposed, as one of the mitigation measures to reduce impacts on birds / bats, that “in areas of high seasonal bird concentrations, where feasible, shut down turbines during periods when birds and bats are highly concentrated at those sites”. The Company is committed to follow this approach if such measures are determined as necessary.

A Stakeholder Engagement Plan, dated August 13, 2014, was prepared to strengthen the stakeholder engagement activities so far conducted by GAWPL. The past stakeholder engagement activities included those during the initial 2009 IEE preparation, and those during the 2013 IEE Update process. The plan identified the primary stakeholders (laborers and local communities) and the secondary stakeholders (non-governmental organization, neighboring communities). Disclosure of project information to the primary stakeholders will be done using the existing communication channels such as periodical meetings, announcements, information letters and notifications posted on information boards, and training. Disclosure of project information to the secondary stakeholders will take place via the project website (still to be established) and in response to direct queries, complaints or objections. Community involvement and consultation have been taken place through baseline surveys and meetings during the IEE and IEE Update process.

The updated second general stakeholder meeting took place on June 18, 2014 at a tent, setup outside the premises of Haji Qasim Burfat Goth on MPCL land, Jhimpir, District Thatta. The first general stakeholder meeting was conducted in 2009 when the IEE report was first prepared. The objectives of the second meeting was to provide summary of the 2013 IEE Update, describe the environmental findings, discuss predicted impacts and mitigations, receive comments from the stakeholders, and describe engagement process with the community and other stakeholders before and during construction and after start of operations, including grievance redressal mechanism and Corporate Social Responsibility program.

The meeting was held to present the results of the IEE Updates of both GAWPL and MPCL projects. The meeting was attended by about 130 stakeholders from local community. Due to cultural sensitivity, women were not part of the meeting. A separate consultation session was therefore held for women on the same day in which about 30 women participated.

The general expectations of communities expressed at the meeting included provision of unskilled employment to local residents of the project area, development of physical and social infrastructure, early identification of land use in the project area. Concerns expressed at the separate meeting with women included development of health care, social and physical infrastructure, provision of employment and earning resources for their men folk, and concerns regarding their privacy and presence of outsider men in the area.

According to the Stakeholder Engagement Plan, GAWPL’s Community Relations Officer will appoint a representative from each stakeholder village as Community Communication Coordinators, and these coordinators will be offered by GAWPL either a full time or a part time employment as well as necessary communicating facilities (e.g. cell phones, motorcycles or pick-and-drop service). Through those coordinators, GAWPL will effectively disseminate relevant project information (e.g. project activities in specific areas at specific time, announcement of new job opportunities, any change in proposed plan of the project, adverse impacts and mitigation measures, emergency response mechanism.

Iqbal Alimohammed
Chief Executive Officer
Gul Ahmed Wind Power Limited (GAWPL)
7th Floor, Al-Tijarah Centre, 32-1-A,
Block-6, P.E.C.H.S., Main
Shahra-e Faisal
Karachi, 75400, Pakistan
Phone: +92 21 34370044
Fax: +92 21 34370039
Email: mailto:iqbalalimohamed@gmail.com

The following documents are also being attached to this ESRS: (i) 50 MW Wind Power Plant by Gul Ahmed Wind Power Limited: Jhimpir, Pakistan, Final Initial Environmental Examination Update, December 2013; (ii) Shadow Flicker Study Report of GAWPL, Sindh Province, Pakistan, Draft Report, August 2014; (iii) Stakeholder Engagement Plan, Gul Ahmed Wind Power Limited, August 13, 2014; and (iv) Project Design Document Form for CDM Project Activities, Power Generation through Wind Energy at Gul Ahmed Wind Power Limited, December 21, 2012 and (v) Initial Environmental Examination (IEE), 50-MW Gul Ahmed Wind Power Limited, Jhimpir, District Thatta, April 20, 2009.

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
No. 1: GAWPL will get the Social Environment Health & Safety Policy signed by its management, and will display at its corporate office, the project operation site and at the CAWPL’s website.	01/31/2015
No. 2: GAWPL will monitor the NTDC’s progress of their Environmental Impact Assessments for associated transmission lines and a substation that are needed for successful implementation of the GAWPL project.	06/30/2016
No. 3: GAWPL will update the Corporate Social Responsibility (CSR) program to meet the requirement of the Sindh EPA IEE approval of December 24, 2012.	03/31/2015
No. 4: GAWPL will appoint (i) EHS Manager and Community Relationship Officer prior to start of the construction, and (ii) Engineering and EHS Manager, prior to start of the operation.	03/31/2015
No. 5: GAWPL will establish its HR policy and procedures in line with IFC Performance Standard 2.	03/31/2015
No. 6: GAWPL will develop an Employment Plan which defines requirements and procedures on identifying and developing employment opportunities, managing employees, recording and reporting employment data, terminating work contracts, and other labor-related issues, with an aim to enhance local employment. The Plan will include a skill development program to help enhance employability of the local population, and a local hiring program to ensure that unskilled and semi-skilled labor be hired from the local communities.	03/31/2015
No. 7: GAWPL will prepare the storm water diversion plan that will help to increase irrigation of the surrounding open area for the local villagers.	03/31/2015
No. 8: GAWPL will review the results and recommendations of the bird monitoring study (May 2014 to April 2015) to be conducted by Ideal Services, and determine the need for additional mitigation measures beyond what were described in the 2013 IEE Update (e.g. operational turbine shut-off).	06/30/2015
No. 9: GAWPL will re-engage with the IUCN / WWF-Pakistan and other wind farm developers in the Jhimpir Wind Corridor to initiate discussion about benefit of sharing bird monitoring data and expertise so far accumulated and feasibility for joint evaluation of cumulative impacts of wind farms on the birds and bats. Based on this discussion, GAWPL will prepare an action plan way forward and start implementation.	09/30/2016