1. | Assessment and Management of Environmental and Social Risks and Impacts |
| 1.1 | Develop and implement the Environmental and Social Management Plan (ESMP) for construction and operational phases including a mitigation programme and monitoring set out in the ESIA (and associated sub-plans). Sub-plans include:
- Community Health and Safety Plan
- Community Integration Plan
- Occupational Health and Safety Plan
- Occupational Health and Safety Plan
- Traffic Management Plan
- Emergency Preparedness and Response
- Biodiversity Management Plan
- Avi-Fauna Monitoring and Shut-down Plan
- Archaeological/ Cultural Heritage Chance Finds Procedure
- Dust management Plan
- Waste water management Plan
- Waste Management Plan
- Hazardous materials management Plan
- Noise pollution Plan
- Water Resources Plan.
- Security Management Plan.
- Site Security Plan.
The ESMP should also be reviewed and revised as appropriate based on timescales specified thereon in.
| IFC PS 1 Environmental Protection Law No. 52 2006. Agricultural Law No. 13 2015. Solid Waste Management Regulation No. 27 2005. Public Health Law No.47 2008. Management, Transportation and Handling of Harmful and Hazardous Substances Regulation No. 24 2005. Instruction for Management and Handling of Consumed Oils 2003. Instruction for Hazardous Waste Management 2003. Jordanian Standard 431/1985 – General Precautionary Requirements for Storage of Hazardous Materials. Regulation for Categorizing Wild Birds and Animals Banded from Hunting No.43 2008. Antiquities Law No.21 1988 & amendments No.23 2004. Instruction for Reduction & Prevention of Noise 2003. JS 1140-2006 Ambient Air Quality. Air Protection Regulation No. 28 2005. Water Authority Law No.18 1988 & amendments. Groundwater Control Regulation No.85 2002 & amendments. Traffic Law No.49 2008. Instructions for Allowable Speed Limits 2002. Labour Law No.8 1996 & amendments. Public Health Law No.47 2008. Regulatory Obligatory Employment of Jordanian Workforce from Surrounding Communities in Development Projects No.131 2016. | EPC Contractor (Vestas) / external consultants as required. | Prior to Financial Close Implemented throughout construction and operation. | Implementation of construction ESMP and sub-plans reviewed by the Lender’s E&S Advisors and approved by Lenders. Development & implementation of an operational ESMP and sub-plans reviewed by the Lender’s E&S Advisors and approved by Lenders. | Construction: Closed. Operations: Compliant: All construction ESMP/ sub-plans were approved prior to construction. Operational ESMP and sub-plans are in place. Updates to the operational plans have taken place as required and following year 1 operational monitoring audit. Compliance is ongoing throughout the remainder of operations. |
| 1.2 | Verify, monitor and ensure implementation of the contractor’s environmental and social obligations contained within the Health, Safety and Environment (HSE) Policy, the EPC and its employer’s requirements. Appoint and maintain a qualified Environmental manager to report directly to site manager, with independent reporting lines to corporate management | Best Practise | Sponsor / external. | Throughout construction and operation. | Appointment of a designated Environmental, Health & Safety (EHS) Officer throughout construction and operation. | Construction: Closed. Operations: Compliant to date. |
| 1.3 | Facilitate and permit the Lender’s E&S Advisors to undertake periodic external monitoring of key Environmental and Social issues as outlined in this ESAP and the ESIA documentation. | IFC PS 1 EP 9 | Sponsor / external consultants. | Throughout construction and operation. During construction, this would consist of reviews at 2, 8 and 14 months into construction to coincide with mobilisation on site, WTG erection and deliveries, site restoration and commissioning including review of bird survey plan. Operational audits will be completed every 12 months. | Lender’s E&S Advisors’ Environmental and Social monitoring reports produced following each site audit. | Construction: Closed. Operations: Compliant to date. E&S monitoring is contracted up to and including year 3 of operations. Year 2 operational monitoring is currently underway. |
| 1.4 | Implement SEP, including regular (at a minimum annual) feedback to local stakeholders on the implementation of agreed environmental and social mitigation measures related to impacts that could affect them. Keep records of any grievances raised and associated responses provided. | IFC PS 1 | Sponsor / external consultants. | SEP requires revision prior to construction. Further revisions throughout construction and operation. Grievances to be addressed within 7 working days of submission or clarification sought in the event further information is required. All grievances responded to within 20 working days. | Submission of SEP revisions for review and approval by the LTA (in consultation with the Lenders, where appropriate). Include stakeholder engagement and resolution of grievances in the periodic environmental and social reports. Include reviewed / updated stakeholder list in the periodic environmental and social reports. Disclosure of grievance mechanism process. | Construction: Closed. Operations: Compliant to date. Ongoing compliance is required throughout operations with a focus on documentation of all stakeholder / community engagement which takes place, grievance recording in matrix and resolution of grievances within the specified timescales. |
2. | Labour and Working Conditions |
| 2.1 | Implementation of the EPC Contractor, Vestas’ project-specific HR policy which includes general terms and conditions, holiday entitlement and grievance procedures which covers both temporary and non-employee workers. Inclusion of prohibition of child and forced labour. | IFC PS 2 Jordanian Legislation | EPC Contractor (Vestas), external consultants. | Prior to and during construction. | Implementation of the Vestas’ HR policy. | Construction: Closed. |
| 2.2 | Implementation of Vestas’ OHS plan to guide all activities on the project site(s) during all phases of activities. Requirements to include (but not be limited to):- Job- and task-specific hazard analysis and controls for the Sponsor and contractor activities.
- Personal protective equipment (PPE) provided, use of PPE required and enforced.
- Safety training for all personnel in their language.
- Train workers in the identification of occupational Electric and Magnetic Fields levels and hazards.
- Train employees on Grievance Mechanism.
- Traffic management plan.
- Proper training on the installation of the windfarm different components.
- Provide training to employees to enable workers and employees to respond to emergency cases and report them properly.
- Review and approval of contractors OHS plans, to meet same standards as ESMP.
- Oversight of contractor OHS implementation, including mandatory reporting.
The OHS plan should also be reviewed and revised as appropriate. | BAT IFC PS 2 | EPC Contractor (Vestas), external consultants. | Implementation: through construction and operation. | Include OHS issues, including accident statistics and training (by the Sponsor and contractor workforces) in the periodic environmental and social reports. | Construction: Closed. Operations: Compliant to date. |
| Annually | Updated OHS plan as needed. Include an update on this topic in the periodic environmental and social reports. | Compliant. Compliance ongoing through the remainder of operations. |
| 2.3 | Develop a formal grievance mechanism for employees and contractors and disseminate information about its uses to the workforce (in the language of the worker). | IFC PS 2 | EPC Contractor (Vestas), external consultants. | Implementation: throughout construction and operation. | Include the project’s performance on this topic in the periodic environmental and social reports. | Construction: Closed. Operations: Compliant to date. Compliance ongoing through the remainder of operations. |
| Prior to construction. | Training undertaken, and security guards vetted. Development of documentation with regards to required accommodation on site. Completed due diligence questionnaire regarding site security. | Construction: Closed. |
| 2.4 | Training for security guards in use of force and vetting for past offences Develop appropriate due diligence questionnaire for site security for review. | IFC PS 2 | EPC Contractor (Vestas), external consultants. | Prior to construction and at all times when workers’ accommodation is occupied. | Implementation of Vestas’ Security Concept Plan. Lender’s E&S Advisors Environmental and Social monitoring during construction and subsequent reporting. | Construction: Closed. Operations: Compliant to date. Security checkpoint is in place during operations. 15 JoEagle Security Guards are employed and work shifts. All security are vetted, ex police / military and from local communities. Compliance ongoing through the remainder of operations. |
3. | Resource Efficiency and Pollution Prevention Control |
| 3.1 | Maintain mitigation measures identified in the construction ESMP into contractor policies and method statements. Implement relevant detailed pollution prevention, waste / hazardous waste / substance / waste water management and disposal / dust management plans to prevent / reduce / control waste, air pollution and control dust emissions. | IFC PS 3 Best practices BAT Jordanian Legislation | EPC Contractor (Vestas), external consultants. | During construction & operation. | Approval obtained from Tafilah authorities for waste and waste water disposal at identified formal disposal locations. Include the project’s performance in the periodic environmental and social reports. | Construction: Closed. Operations: Compliant to date. Two licensed waste management contractors currently used for the Project. Compliance ongoing through remainder of operations. |
| 3.2 | Noise monitoring plan to be developed to ensure project meets applicable noise limits. This is to be based on compliance monitoring. Noise monitoring plan may be updated based on the outcomes of the grievance mechanism and monitoring following receipt of a valid complaint. Additional mitigations to be applied if required following noise monitoring where necessary and defined in ESMP. | IFC PS 3 Jordanian Legislation | Sponsor, external consultants | Implementation: throughout operation and in the event of a valid complaint regarding noise | Submission of noise monitoring plan. Application of any required mitigation. Include the project’s performance on this topic in the periodic environmental and social reports. | Compliant. Compliance ongoing through remainder of operations. |
| 3.3 | Undertake mapping of wells on site and water quality testing in the event of a complaint. | IFC PS 3 | EPC Contractor (Vestas), external consultants. | Mapping of wells prior to construction. Monitoring and testing during construction in the event of a complaint. Monitoring and testing during operation in the event of a complaint. | Lender’s E&S Advisors’ Environmental and Social monitoring reports produced following each site audit. | Construction: Closed. Operations: Compliant to date. A wells and water harvesting structure mapping report was produced in March 2019. The majority of the structures were empty and not used according to the Community Liaison Officer (CLO). This is still the case. Compliance ongoing. |
| 3.4 | Secure water requirements for the Project following review of anticipated water use on site. | IFC PS 3. | Sponsor, EPC Contractor (Vestas), external consultants. | Prior to construction. | Approval from Tafilah Water Directorate for water use. Lender’s E&S Advisors environmental and social monitoring during construction. | Construction: Closed. |
| 3.5 | Apply basic dust control and suppression measures during construction and supply appropriate PPE equipment. | IFC PS 3 OSHA requirements. Jordanian Codes. | EPC Contractor (Vestas) | During construction. | Implementation of the Vestas’ dust management plan. Regular inspection and scheduled maintenance programme for vehicles, machinery and equipment throughout construction for early identification of issues. Lender’s E&S Advisors’ Environmental and Social monitoring reports produced following each site audit. | Construction: Closed. |
| 3.6 | Calculate GHG emissions for the operational phase of the Project. | IFC PS 3 | Sponsor. | Prior to operation. | Submission of calculation satisfactory to Lender’s E&S advisors. | Compliant - Closed. |
4. | Resource Efficiency and Pollution Prevention Control |
| 4.1 | Develop a Community health and safety (H&S) plan. | IFC PS 4 | Sponsor, EPC Contractor (Vestas) | Development prior to financial close. Implement during construction. | Submission of Community H&S Plan satisfactory to Lender’s E&S Advisors within the Construction ESMP. | Construction: Closed. |
Development prior to operation. Implement during operation. | Submission of Community H&S Plan satisfactory to Lender’s E&S Advisors within the Operational ESMP. | Construction: Closed. Operations: Compliant to date. |
| 4.2 | Develop a community integration plan for working with the local community during construction. | IFC PS 4. Best practise. | Sponsor, EPC Contractor (Vestas) | Development prior to financial close. Implement during construction. | Submission of the community integration plan. | Construction: Closed. |
| 4.3 | Implement appropriate ESMP sub-plans which include procedures to protect public health and safety, to include (but not be limited to):- Traffic management plan for all drivers and equipment operators (speed limits, training, etc.).
- Public notice of any blasting operations near areas open to the public.
- Hazard signs/ notices in the languages of the area on power pylons/poles.
- Public safety information to be posted on information boards and to include emergency contact details.
- Compliance with noise levels.
- Comply with shadow flicker shut down requirements (operation only)
| IFC PS4 Best practice | Sponsor, external consultants. | Development: Prior to the commencement of construction works. Further announcements 1 week prior to any required blasting operations and 1 week prior to the commencement of delivery of WTG components. | Implementation of procedures outlined in the traffic management plan, dust management plan, community health and safety plan. | Construction: Closed. Operations: Compliant to date. |
| EPC Contractor (Vestas). | Implementation: Throughout construction and maintenance operations. | Include the project’s performance on traffic management, safety, security, other activities, including any incidents in the periodic environmental and social reports. | Construction: Closed. Operations: Compliant to date. |
| Implementation of shadow flicker shut down procedures and monitoring of noise levels during operation. | Include the project’s performance and details of any complaints / grievances with regards to noise and shadow flicker in the periodic environmental and social reports. | Part-Compliant. One grievance is outstanding which was filed to the Compliance Advisor Ombudsman (CAO) which is ongoing. WTGs 7-14 fitted with shadow flicker shutdown modules. Module for WTG 6 has been ordered. Ongoing compliance required during operations. |
6. | Biodiversity Conservation and Sustainable Management of Living Natural Resources |
| 6.1 | Implement the agreed and additional construction monitoring and mitigation protocols as per the ESIA and Biodiversity Management Plan (BMP). | IFC PS 6 Best practice | Sponsor, EPC Contractor (Vestas), external consultants (qualified ecologist). | Prior to construction. | Development of construction monitoring and mitigation within a BMP to be reviewed and approved by Lender’s E&S Advisors (in consultation with Lenders). | Construction: Closed. |
| 6.2 | Undertake detailed tortoise survey prior to construction. Relocation of any tortoises found within the areas potentially disturbed by construction to areas with similar habitats | IFC PS 6 Best practice | Sponsor, EPC Contractor (Vestas), external consultants (qualified ecologist). | Prior to construction. | Submission of tortoise survey report. | Construction: Closed. |
| 6.3 | Survey of threatened floral species prior to construction. This specifically relates to three nationally threatened plant species identified within the Project site during baseline studies. Marking / fencing of plants prior to construction or relocation. | IFC PS 6 Best practice | Sponsor, external consultants (qualified ecologist). | By 01 September 2018, prior to construction. Draft report provided 30 September 2018. | Submission of report on threatened flora survey. Lender’s E&S Advisors’ Environmental and Social monitoring reports produced following each site audit to review marking / fencing. | Construction: Closed. |
| 6.4 | Two near threatened breeding birds (Common cuckoo and Lesser kestrel) noted on site (and probably breeding) during pre-construction survey. If active attempts of these regionally threatened species are confirmed, construction activities that could affect breeding success shall be halted until either failed or young birds have fledged. Further annual breeding bird surveys to be carried out to inform operational phase activities. | IFC PS 6 Best practice | Sponsor, external consultants (experienced ornithological consultant(s)). | During construction and operation. | Submission of construction schedule and plan and demonstrate that construction is planned to avoid areas of concern during the breeding season. Inclusion of additional breeding bird surveys into construction and operational ESMP if they are deemed necessary. | Construction: Closed. Operations: Compliant to date. Surveys carried out during 2022 breeding bird season with submission of report for review. Ongoing compliance – year 3 operational surveys required during 2023. |
| 6.5 | Where fencing is required, ensure appropriate gap for natural movement of small faunal species. | IFC PS 6 Best practice | Sponsor, EPC Contractor (Vestas) | During construction & operation: In the event that fencing is required, incorporate a gap into the design prior to installation. | Lender’s E&S Advisors’ Environmental and Social monitoring reports produced following each site audit to review any fencing on site. | Construction: Closed. Operations: Compliant to date. Ongoing compliance in the event further fencing is necessary during operations. |
| 6.6 | Biodiversity code of conduct and awareness raising / training of personnel and good housekeeping. | IFC PS 6 Best practice | Sponsor, external consultants. | Prior to construction. Implemented during construction. | Submission of Environmental Awareness Manual as referred to in the Biodiversity Management Plan (BMP). Lender’s E&S Advisors’ Environmental and Social monitoring reports produced following each site audit to review training / toolbox talks for construction workers. | Construction: Closed. Information included in BMP and continuing compliance required during operations to ensure that the BMP is being implemented and relevant biodiversity issues included in site induction and toolbox talks. |
| 6.7 | WTG shut-down plan developed in relation to bird collision risk. This will be an observer-led shutdown on demand procedure to safeguard migratory soaring birds and priority resident / summer breeding raptor bird populations. | IFC PS 6 Best practice | Sponsor, external consultants (experienced ornithological consultant(s)). | Prior to operation and implemented during operation. Minimum period of first three years of operation with an evaluation for extension after this period. | Include monitoring within periodic environmental and social reporting. Lender’s E&S Advisors’ Environmental and Social monitoring reports produced following each annual operational site audit to include review of WTG shut down requirements. | Compliant. Ongoing compliance required during operations. BMP should be fully consistent with the operational bird protocols. |
| 6.8 | Bird (including breeding birds) and bat monitoring programme should be completed in accordance with the measures set out in an approved Operational ESMP for at least the first three years of operation. | IFC PS 6 Best practice | Sponsor, external consultants (experienced ornithological consultant(s)). | Develop protocol prior to operation. | Development of operations monitoring and mitigation within the Operational ESMP to be reviewed and approved by Lender’s E&S Advisors (in consultation with Lenders) prior to operations and implementation. | Construction: Closed. |
First three years of operation. To be reviewed by suitably qualified ecologist after first three years of operation and potentially extended, dependant on monitoring results. | Include monitoring and bird mortality data in the periodic environmental and social reports. Submission of updated monitoring plan. | Compliant. Surveys carried out during 2022 breeding bird season with submission of report for review. Ongoing compliance during operation – year 3 operational surveys required during 2023. |
| 6.9 | Monitor bird and bat mortality on site. In case of high mortality (as defined within ESMP), develop and implement an adaptive management strategy / protection plan. Survey to include all 15 WTGs based on calibration trials. Livestock movements monitored and recorded to help identify elevated risks to Griffon Vulture and other scavenging bird species that may be attracted to the site by livestock. Detailed measures should be incorporated into the Operational ESMP. | IFC PS 6 Best practice | Sponsor, external consultants (experienced ornithological consultant(s)). | Develop protocol prior to operation. | Development of operations monitoring and mitigation within the Operational ESMP to be reviewed and approved by Lender’s E&S Advisors (in consultation with Lenders) prior to operations and implementation. | Construction: Closed. Operations: Compliant to date.
Continued compliance required, ensuring that protocol procedures are followed correctly and Daehan Wind Power Company (DWPC) and the lenders are notified in the event of a priority species collision and mortality on the Project site. Mapping and recording of the location of the shepherd camps required with this information being passed on to the individuals completing the shut-down on demand monitoring. Continued consultation with the shepherds by the Project team to ascertain if, and when they are feeding their dogs in order to identify potential elevated risk situations. During these periods, and depending on recorded bird activity, individual WTGs, clusters of WTGs or the whole wind farm should be subject to a daily shut-down during these elevated risk situations in order to reduce the likelihood of collision. |
| First three years of operation. To be reviewed after first three years of operation and potentially extended, dependant on monitoring results. Thereafter: during routine maintenance / monitoring | Include monitoring and bird mortality data in the periodic environmental and social reports. Reporting to authorities and lenders in a timely manner and provision of bi-annual reports detailing results of in-flight monitoring (including elevated risk situations), shutdown on demand incidents (including near misses), carcass search surveys and trials to calibrate these surveys. |
| 6.10 | To best endeavours, assist with the set up and operation of an ‘Internal Committee’ comprising representatives of wind power projects participating in the Tafila Region CEA process, competent developer-contracted ornithological specialists and / or external specialists that will review all reporting relating to operational bird monitoring and mitigation. | IFC PS 6 Best practice | Sponsor, external consultants (experienced ornithological consultant(s)). | Prior to and during operation. | Undertaking of committee meetings. Include committee findings / discussions in the periodic environmental and social reports. | Part-Compliant: It is understood that the committee has been established and is led by the Ministry of Environment with key members including EDAMA and RSCN (Jordanian NGOs) but does not include any of the Project companies. As soon as the Project became operational, the MoEnv were to contact the Project company to ensure the implementation of the national guidelines of operational monitoring. No contact has been made to date and it is understood that DWPC are looking into this. Ongoing compliance required. |
| 6.11 | Monitor the distribution and abundance of the threatened plant species carried out for at least five years during operation. | IFC PS 6 Best practice | Sponsor, external consultants. | Develop protocol prior to operation. | Development of operations monitoring and mitigation within the Operational ESMP to be reviewed and approved by Lender’s E&S Advisors (in consultation with Lenders) prior to operations and implementation. | N/A – Waiver in place for this ESAP action. |
First five years of operation dependant on monitoring results. Thereafter: during routine maintenance / monitoring | Include monitoring and bird mortality data in the periodic environmental and social reports. | N/A – Waiver in place for this ESAP action. |
| 6.12 | Identification of any trees requiring removal for construction purposes. In the event that any trees are to be removed, an application is to be submitted to the Ministry of Agriculture (MOA) for approval. | IFC PS 6 Best practice | Sponsor, EPC Contractor (Vestas), external consultants. | On completion of final design, prior to construction. | Approval obtained from the MOA. Lender’s E&S Advisors environmental and social audit during construction to review any tree removal on site and associated permits. | Construction: Closed. |
| On completion of final design, prior to construction. | Approval obtained from the MOA. Lender’s E&S Advisors environmental and social audit during construction to review any tree removal on site and associated permits. | Construction: Closed. |
8. | Cultural Heritage |
| 8.1 | Implement 70m buffer from each site of archaeological importance within the detailed final design. | IFC PS 8 | Sponsor, EPC Contractor (Vestas), external consultants | Prior to construction. | Provision of final design to the Department of Antiquities to demonstrate archaeological sites avoided. | Construction: Closed. |
| 8.2 | Prepare and implement a procedure for managing existing cultural heritage / archaeological features including demarcating features and establishing a code of conduct / awareness training. These measures should be incorporated into the ESMP. | IFC PS 8 Jordanian Legislation | EPC Contractor (Vestas), external consultants. | Procedure prepared prior to construction. | Submission of final ESMP for construction. Lender’s E&S Advisors’ Environmental and Social monitoring reports produced following each construction audit (see Action No. 1.4 for schedule). | Construction: Closed. |
| 8.3 | Implementation of the chance find procedure during construction. These measures should be incorporated into the ESMP. | IFC PS 8 | EPC Contractor (Vestas), external consultants. | Implement during construction. | Submission of final ESMP for construction. Lender’s E&S Advisors’ Environmental and Social monitoring reports produced following each construction audit (see Action No. 1.4 for schedule). | Construction: Closed. |