While all Performance Standards are applicable to this investment, IFC’s 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

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

Impact on communities of indigenous people and on cultural heritage is not expected on account of the project. Accordingly, PS7: Indigenous Peoples and PS 8: Cultural Heritage are not considered applicable to the Huanghou and Huayuan projects. However, it is possible that in the company’s future projects, PS7 and/or PS8 may also be applicable or one or more of the above six PSs may not be applicable. The company will be expected to as part of its ESMS undertake an ESIA for each of its future projects and determine the applicable PSs in the ESIA.

If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards.                                                    

This is a Category A project because: (a) 275 households are affected due to land acquisition at Huanghou site and about 330 households are expected to be affected due to land acquisition at Huayuan site;  (b) the two projects have a a diverse set of risks and impacts including those linked to land acquisition, soil and water conservation during construction, risks to terrestrial, aquatic and avifaunal biodiversity,  labor and working conditions during construction and operation; noise; community health and safety; pollution prevention during construction and operation, and community consultation and engagement; and (c) in future, following a possible future conversion of the current investment into equity, the company may undertake projects that result in significant, diverse, or unprecedented risks and/or impacts. 

Concord will be required to implement an ESMS, which has been defined to include the company’s HR Policies and Procedures, with IFC PSs appropriately incorporated  to undertake its future projects and manage its environmental and social performance in accordance with applicable local laws and regulations and international standards, including IFC’s Performance Standards on Social and Environmental Sustainability.

Environmental and Social Assessment and Management System 

Concord’s stated mission is to protect and improve the environment through provision of clean and renewable energy. The Company has also articulated a public commitment to maintaining high standards in management of environment, occupational health and safety (OHS), employee working conditions and community relations in its projects and operations. Further,  Concord has, as part of IFC’s earlier investment, implemented an ESMS for its wind power business that incorporates IFC Performance Standards 2006. The company will, in accordance with an action plan agreed with IFC (refer ESAP#1), complete a third party review of the existing ESMS with respect to the provisions of IFC PS 2012, and appropriately upgrade the ESMS to meet IFC’s updated Performance Standards of January 2012, the World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines for Wind Energy dated 2015, and other applicable WBG EHS Guidelines including the additional measures for upgrading the ESMS that have been described below.

Policy  

The company has a publicly articulated policy that focuses on identifying and responding to stakeholder needs and proactive management of environmental and social (E&S) risks associated with its business. Further, as part of the earlier IFC investment, the company has adopted and implemented an environmental, health, safety and social (EHSS) policy which, in addition to compliance with national laws commits to adhere to IFC Performance Standards to achieve outcomes aligned with the objectives of each of the eight Performance Standards. Towards this, as part of the ESMS, the company has: (a) articulated the objectives, aligned with the Performance Standards, that it proposes to achieve; and (b) identified the applicable national laws of relevance to each of the eight PSs.

Identification of Risks and Impacts  

Concord, as part of its ESMS, has procedures and tools in place to undertake an E&S screening, early in the decision process for a proposed project, to assess the nature and scale of impacts that may be expected from the project. Based on the outcome of the screening and as part of the feasibility assessment: (a) an appropriate third party EIA is undertaken; (b) a soil and water conservation plan prepared; and (c) compensation for land acquisition and involuntary resettlement is estimated. The outcome of these assessments informs the project selection and development decision. Further, prior to commencement of construction at site, the EIA is completed, stakeholder consultation undertaken and regulatory approvals obtained. The EIAs are typically completed before any land acquisition takes place, or before application of restrictions on access to natural resources, and precedes the award of EPC/construction contracts. The EIA results in the development of an Environmental and Social Management and Monitoring Plan (ESMP) that meets the IFC PSs setting forth: (a) measures to mitigate adverse impacts; (b) monitoring requirements for ensuring that the mitigation measures are implemented effectively and in a timely manner; (c) organizational and financial resources for carrying out the measures; and (d) an implementation schedule for these activities. 

The company will as part of the ESMS upgrade mentioned at ESAP # 1 further upgrade the screening procedure with delineation of appropriate acceptance/rejection criteria to ensure adherence to IFC PSs in the projects it bids for as a: (i) project owner/developer/ co-developer; (ii) construction/EPC company; and (iii) as an O&M operator. Where Concord is bidding for a project as an owner/developer/co-developer, the company will proceed to bid only if after application of the screening procedure Concord has obtained assurance that the project can be developed and implemented in accordance with the provisions of IFC PSs. 

Where the company is bidding for a project as a construction/EPC company or an O&M operator, Concord will apply the screening procedure in the context of its role and contractual obligations. Application of the screening procedure will lead to the following outcomes: (a) the acceptance of contracts in which the company’s environmental and social standards (including those of IFC’s PSs 1 through 8) can be met; and (b) the re-evaluation, renegotiation, or decision on rejection of contracts that cannot be implemented according to IFC PSs. In applying the screening procedure, the company will review: (a) the E&S impacts of the project and significance of gaps with Concord’s policies and the IFC PSs requirements; (b) E&S mitigation, management and monitoring measures (ESMP) it is contractually required to implement against the requirements of IFC PSs and WBG EHS Guidelines (as applicable in the context of its role); (c) identify gaps and implement additional measures, within its contractual obligations, to meet the IFC PSs and WBG EHS Guideline requirements. In case the risks and impacts of the project are significant, and gaps in mitigation measures with respect to Concord’s policies (including IFC PSs requirements) are also significant, the company will re-evaluate, renegotiate, or take a decision on not bidding/rejection of the contract. In particular, in EPC/Construction or O&M contract bid situations: (i) if the screening process, determines presence of high risk criteria like Critical habitat (CH), Critical Cultural Heritage (CCH), and/or Free, Prior and Informed Consent (FPIC) requirements, impacts on  indigenous persons and/or involuntary displacement, then the company will not bid for the project if the project is in CH or impacts CH or critical cultural heritage or FPIC triggers present, and there is significant gaps in mitigation with respect to IFC PS requirements; (ii) for other high risk criteria  (e.g. involuntary displacement and impact on indigenous peoples IPs), the company will bid for project only if the land acquisition/displacement was fully completed 3 or more years ago and there are no ongoing disputes, litigation or other conflicts; (iii) for other high risk criteria where impacts have occurred within the previous 3 years and there are gaps with respect to IFC PS requirements, the company may consider/evaluate the decision of proceeding with bidding if there are no ongoing litigation, disputes or conflicts; and (iv) in case of other high risk criteria where impacts have occurred within the previous 3 years and there are significant gaps with IFC PSs provisions also if there are ongoing disputes, litigation or conflict, the company may renegotiate with their client and proceed to bid only if either the company’s client agrees to close the gaps with IFC PS provisions, or the company’s client allows Concord to close those gaps and compensates Concord for the cost of closing the gaps.

For projects where Concord is a developer/owner/co-developer, the company will, as part of the ESMS upgrade (ESAP # 1), include procedures that will require: (a) undertaking of an ESIA in accordance with the IFC PS 2012 or review of any existing ESIA for completeness and consistency with IFC’s PSs and applicable WBG EHS Guidelines; (b) determination of the need for any supplemental studies to meet IFC Performance Standard requirements; and (c) prior to commencement of any construction activity at the project site, completion of such supplemental studies, or as appropriate update of existing ESIAs in accordance with IFC Performance Standard provisions. The ESIA or the ESIA update shall result in the development of an Environmental and Social Management Plan (ESMP) that meets the IFC PSs setting forth: (a) measures to mitigate adverse impacts in accordance with the IFC Performance Standard provisions; (b) monitoring requirements for ensuring the mitigation measures are implemented effectively and in a timely manner; (c) organizational and financial resources for carrying out the measures; (d) an implementation schedule for these activities; and (e) an appropriate incentive structure to ensure plans are implemented. These procedures will also be applicable in instances where a greenfield or recently expanded acquired asset (including its associated facilities) has been in operation for less than two years or where land has been acquired within the previous two years or where there is land acquisition remaining/underway or proposed, and in all cases where new development or expansion is proposed post acquisition of an asset. Concord  will , as part of the ESMS upgrade, develop and implement procedures such that land acquisition, in all projects undertaken by the company as an owner/developer/co-developer and/or its subsidiary companies, is in accordance with IFC’s Performance Standard 5 provisions.

The company will, as part of the ESMS upgrade, put in place formal procedures (ESAP#1): to review projects it considers for acquisition against a set of defined criteria; undertake prior ESDD of potential acquisition targets for timely presentation of ESDD findings and recommendations to appropriate decision authorities in the company; defining the decision authority, decision processes and escalation mechanism linked to environment and social risks; and to screen out assets that do not meet the acceptance criteria.  The company will, as part of the ESDD, carry out a review of EHSS risks to the asset including from outstanding litigation, or notices from regulatory authorities, or stakeholder concerns, and gaps with IFC PSs, all of which will together inform the acquisition decision process and outcome. In case of assets where risks and gaps with  IFC’s PSs   are identified in the ESDD, the company will only consider those assets for acquisition in which it determines that the issues underlying the identified risks and gaps can be mitigated in accordance with the IFC PSs. In all other cases, the ESMS will include procedures to ensure that the company: develops and implements a corrective action plan based on the ESDD findings; undertakes an assessment of EHSS aspects, impacts and risks; develops and implements operation and maintenance procedures consistent with IFC PSs, good international industry practice (GIIP) including applicable provisions of WBG EHS Guidelines to address the identified significant risks and impacts.

Concord will, as part of the ESMS upgrade mentioned at ESAP # 1: (i) include procedures to assess cumulative impacts and impacts from associated facilities; (ii) adopt a  policy, not to undertake any project or operational activities that are in, or have the potential to impact, a Tier 1 critical habitat; (iii) as a policy not undertake a project in Tier 2 critical habitat without first developing a mitigation plan in line with PS6 provisions particularly related to creation of offsets and measures that demonstrate net gain; (iv) adopt a policy to obtain Free, Prior and Informed Consent (FPIC) from IP communities prior to undertaking any projects, if impacts of the nature that trigger FPIC are expected on IP communities; (v) as policy in all cases, where communities of indigenous people are likely to be impacted, implement an engagement and grievance redress mechanism based on the principles of informed consultation and participation (ICP) and mitigation measures in accordance with the provisions of PS7; and (vi)  develop and implement a chance find procedure for projects including for finds of archaeological, paleontological, historical, cultural, artistic, and religious values, as well as unique natural environmental features that embody cultural values, such as sacred groves. 

The Company has as part of the existing ESMS identified environmental, health, safety and social aspects, risks and impacts for wind power project planning, construction and operation, and has developed procedures to address the identified significant risks and impacts. Some of the key risks and significant aspects/impacts identified include those relating to: soil erosion and runoff management; handling, storage and use of hazardous materials; emissions to air and water; noise; shadow flicker; handling, storage and disposal of hazardous wastes; fire risk in turbine, sub-station, worker living quarters ; facilities and amenities to be made available to workers; working at height; working in confined spaces; electrical safety; traffic safety; child and forced labor; compensation for land acquisition/livelihood impact; impacts on indigenous people; biodiversity impacts; and impacts on cultural heritage among several others. Concord will, as part of the ESMS upgrade process (mentioned at ESAP # 1), prepare a formal Hazard Identification and Risk Assessment Process (HIRA) and Aspect, Impact and Significance (AIS) determination processes to ensure a structured identification of risks and impacts in all projects and operations going forward. 

Environmental Impact Assessments (EIA) prepared by a third party have been completed for both Huanghou and Huayuan project. EIAs for both the projects have been approved by the provincial authorities. The EIAs address key environmental impacts associated with each of the project’s construction and operation including those pertaining to: noise; dust, air quality and ambient conditions; water and wastewater; solid waste; ecology; avifauna and bird migration; shadow flicker; vehicular emission; hazardous materials and waste; soil erosion; monitoring, reporting and supervision; and budgetary requirement. Further, a soil and water conservation assessment and plan has been prepared for each of the two projects for run off management to minimize soil erosion and pollution of surface water bodies including through: provision of vegetative measures (sowing grass, hedges and vegetation/trees), stone retaining walls, geotextile cover, provision of settling basins, earth filled bag retaining walls, retention, garland and alongside drains, and back filling as much of the excavated material as is possible. Each of the two project companies will implement additional mitigation/management measures consistent with good international industry practices including those discussed below in construction and operation of their respective projects in accordance with IFC Performance Standards. The construction contractors are contractually required to ensure adherence to the environment management plan and provide a compliance report for each site upon completion of construction at each WTG location. 

Management Programs  

Concord’s ESMS include procedures for:   compliance with regulatory requirements; development and implementation of management programs, including standard operating procedures for project screening,  undertaking EIA commensurate with project risks and impacts, managing EHSS risks and impacts from operations and maintenance; incident and accident handling, recording, reporting, investigation and analysis; emergency preparedness and response; EHSS organization, responsibility and resource allocation; training and awareness; communication and consultation; monitoring, recording, reporting and documentation of environmental and social performance; internal and corporate audit of the ESMS and project ESMP implementation; management review; and EHSS performance reporting to the Concord management. 

Organizational Capacity and Competency  

Concord’s Board of Director’s is overall responsible for setting the E&S strategy and objectives. Audit committee of the Board, as part of its overall work program, also exercises oversight of adherence to the E&S strategy and objectives. Office of Social Responsibility and Environmental Protection (OSREP), which is housed within the planning and operation department, is responsible for: (a) development, update and maintenance of the ESMS; (b) oversight of implementation of the corporate ESMS, and consistent application of the company’s E&S policies across each of its projects, plants, and monitoring follow up on improvement actions; (c) oversight of E&S staff deployed at each project and/or plant site; (d) performing an advisory role for each project and plant management on interpretation of E&S standards, sharing good practices between projects and plants; (e) development of corporate training and capacity building programs; (f) corporation wide oversight of internal and corporate audits, corrective actions and management review processes; (g) oversight of compliance with legal and other corporate commitments; and (h) reporting E&S performance and exceptions to the company’s senior management, board, investors, and other stakeholders. The company also has a corporate Safety Management Committee (SMC), which oversees implementation of the occupational health and safety (OHS) management system with its role and responsibility similar to that of OSREP but focused on OHS. There are in all 3 dedicated staff that together comprise the corporate OSREP and SMC team.  Further, Concord puts in place, at each project site and in its operating plants, suitably trained professionals for management of safety and environmental aspects. In all there are 60 dedicated environmental , social/community relations and safety staff in the Concord Group across all of its projects and operations including all of its subsidiaries. Further, during operation stage, appropriately trained professionals form part of the Occupational Health and Safety and Fire Safety committees led by the site director at each site. The Company will, as part of the ESMS upgrade process (refer ESAP#1), obtain a third party assessment of the need, if any, for strengthening: (a) the corporate, project and each subsidiary level E&S organization; (b) procedures for effective oversight of contractor EHSS performance; and (c) third party audit of project sites during construction and subsidiaries’ operation with appropriate periodicity respectively.

Monitoring and Review  

Concord requires its subsidiaries to put in place an appropriate monitoring plan for construction and operation phases based on the key risks and impacts identified in the EIA. The parameters monitored include: ambient air quality, ambient noise levels, vibration, hazardous and other waste generation and disposal, health and safety data, accidents/incidents, training and drills, stakeholder engagement, media reports, community concerns, deviations from the national and investor requirements, and corrective actions taken. Each project site and operating plant location submits at least a monthly report to OSREP and SMC.  OSREP and SMC, on a sample basis verify and validate the submitted monthly reports and compile an annual safeguard monitoring report for each project. Further, corporate team audits each under construction site at least once a month and local regulatory authorities also undertake monthly site audits. 

The EIAs for both projects have detailed a monitoring plan that covers: noise;, dust and ambient air quality during construction; water and wastewater; hazardous waste; solid waste; delineation of the responsibility, location and frequency; and budget to be provided. The soil and water conservation plan for both the sites includes a detailed monitoring plan detailing the parameters to be monitored, locations and frequency of field surveys, equipment to be used and budgetary requirement covering pre-construction, construction and rehabilitation phases. The management and monitoring plans covers areas impacted by wind turbines, access roads, transmission line, booster station, excavated rock storage yards and accommodation areas. The company will, as described in detail under the PS6 section and as mentioned at ESAP 2 & 3, further strengthen the monitoring and management plan related to biodiversity risks and impacts through: (a) enhanced surveys and monitoring of threatened species, and where required development of adaptive management measures in consultation with species experts; and (b) monitoring of bird and bat collision, and implementation of appropriate adaptive management measures. 

Each subsidiary company undertakes quarterly internal audits. A corporate audit of each subsidiary company is undertaken at least once a year by OSREP and SMC. The internal audit reports are made available to the OSREP and SMC. The findings of these audits and overall performance monitoring feed into the annual management review process both at individual subsidiary company level and corporate level to assess efficacy of the ESMS and to identify measures to further strengthen the ESMS. Further, the Company will (as mentioned at ESAP # 6: (i) undergo an annual third party audit of the ESMS implementation including a review of the ESIAs, ESDDs and ESMP gap analysis undertaken during the year; and (ii) implement corrective actions based on the findings of this annual third party audit. Furthermore, Concord  will as part of the ESMS, implement procedures to: (a) undertake bi-annual third party audits during project implementation/construction phase of high risk projects to obtain assurance that the mitigation, management and monitoring measures detailed in the ESIA are being implemented, and implement corrective actions based on the audit findings; and (b) undertake annual third party audit of each high risk project during first two years of operation to obtain assurance that the operation phase mitigation, management and monitoring measures detailed in the ESIA are being implemented.                                                   

Human Resources Policies and Procedures 

Concord has 1202 full-time employees, 107 of whom work at the group’s headquarter, 254 in project development and management, 233 in engineering consultancy, design, equipment procurement and construction (EPC) and 608 in operation and maintenance. In addition, there are contract workers hired through different contractors engaged at the company’s various project sites and who are mainly involved in project construction activities. At a typical project construction site there could be about 10 Concord staff and about 500 contract workers. During operation phase, typically, depending on the size of the project, there are between 15 – 30 staff at a location. In the Huanghou project, there are 10 company staff and about 1000 contract workers engaged through 13 contractors. Most of the contract workers are from other provinces. 11 O&M staff will be deployed for the Huanghou project. Similar staffing is expected for Huayuan project.  

Concord has in place policies and procedures to comply with the applicable labor laws and regulations. Further, as part of the previous IFC investment, the company’s wind power business has adopted policies and implemented procedures aligned with IFC PS2 provisions delineated in their human resource (HR) manual including on: working age; prevention of forced labor; avoidance of abusive behavior; reward and disciplinary procedures; employee records; employee transfer and exit; attendance; employment contracts; expatriate employees; training; wages; working hours; overtime and overtime compensation; leaves; and recruitment. The policies and procedures are communicated to employees through training including at least an [eight hour] orientation focused on the HR policies and procedures during new employee induction, and are also available on the company intranet. The Concord’s HR Policies and Procedures are applicable to its subsidiaries and include in its scope only direct employees. To implement and oversee these policies and procedures, Concord has an 6 member corporate HR team and in all about 50 number of HR staff deployed across all the subsidiaries/plant sites.

Working Conditions and Terms of Employment 

Basic terms and conditions are communicated in the employment letter to direct employees including details  pertaining to: benefits, leaves, deductions, hours of work, overtime arrangements and overtime compensation, and such other.  Concord typically provides adequate accommodation to its O&M employees (2-3 persons to a room) with all basic amenities, and facilities including food and recreation. The same standards are being adhered to in Huanghou project for O&M staff, who have been provided bachelor accommodation in the substation cum control room building for the project.  

Workers’ Organization 

Concord is committed to complying with relevant laws related to employees/workers union/organization. While there is at present no workers organization in place, there is no evidence of the company preventing any worker from setting up or joining a labor union  

Non-discrimination and Equal Opportunity 

While Concord does not have a formally articulated policy on Non-discrimination and Equal Opportunity  in practice it adheres to these principles in  recruitment and hiring, salary, compensation, working conditions and terms of employment, access to training, promotion, termination of employment or retirement and discipline . The company has a concerted focus on enhancing diversity of its personnel including based on gender, region and age. The company will, as part of the ESMS upgrade process, articulate an Equal Opportunity and Non Discrimination Policy, communicate it to all staff, and put in place appropriate formal procedures to ensure adherence to it in particular in relation to migrant workers employed by contractors at the project sites.  

Retrenchment 

There are no plans for retrenchment. The company has procedures in line with the national laws on layoffs and will, as part of the ESMS upgrade, undertake a review of the existing procedures for conformance to PS2 provisions, and develop and maintain a retrenchment policy and procedure that meets PS2 provision. 

Grievance Mechanism  

Concord, as part of the earlier IFC investment developed and implemented a formal employee grievance redress procedure. Further, the company also has in place a formal complaints procedure to deal with employee code of conduct in particular fraud and corruption. Further, Concord has a process for confidentially seeking employee feedback. Concord will, as part of the ESMS upgrade process undertake a review of the existing grievance redress process to assess its effectiveness, and in particular upgrade it to: (a) provide for anonymous complaints and confidentiality protection, where the aggrieved person so desires; (b)  ensure that service provider/contractors’ employees have access to an appropriate grievance mechanism; (c) delineate time bound steps to be taken upon receipt of a complaint; and (d) detail procedures for  documentation, analysis and reporting of grievances received and resolved to senior management . 

Protecting the Work Force  

Concord has in place formal and well defined HR Policies and Procedures for prevention of child and forced labor. 

Occupational Health and Safety  

Concord has put in place corporate and subsidiary level OHS management system (OHSMS). The OHSMS of Concord’s EPC operations and O&M company are certified to OHSAS 18001 standards. The management system includes: OHS Policy; OHS objectives; roles and responsibility allocation; safety training procedures for employees; provision of safety and hazard signage; procedures for provision and use of personal protective equipment; electrical safety procedures; emergency response procedures; accident investigation, reporting and corrective action procedures; safe work procedures for various activities that exposes workers and employees to hazardous conditions (working at height, confined spaces, temperature, poor weather); safe design, provision of adequate amenities and maintenance of hygienic conditions in the  of workplace and accommodation; traffic/road safety; fire prevention and control procedures; medical surveillance program; access to medical facilities; periodic internal and corporate audit; and management review.  

Concord’s monitoring data indicates that there have been no fatal accidents in 2016 and lost time accidents in calendar year 2016 were no lost time incidents involving staff. The company will, as part of the ESMS upgrade mentioned at ESAP # 1, implement procedures to track lost time incidents involving contractor’s workers.The company will as part of the ESMS upgrade process mentioned at ESAP # 1, commence monitoring lead and lag safety indicators, and benchmark the performance against OSHA incidence rates recorded levels for this industry. There have been no lost time accidents at the Huanghou project site. In the Huanghou project 3 number of government certified safety staff have been deployed and in the Huayuan project 3 safety staff will be deployed. The Huanghou project company has tied up with a local hospital in the event of an emergency/urgent medical care.  

Workers Engaged by Third Parties 

At the Huanghou project, migrant workers employed by contractors currently stay in local rented houses. A typical location includes about 30 to 40 workers  at each individual rented house which results in variability in the quality of housing and offer of basic amenities.. 

Concord will, as part of the ESMS upgrade process, expand this contractor management and oversight procedure by including: (i) a comprehensive compliance checklist against the applicable legal requirements and PS2 provisions; (ii) periodic internal audit procedure using the checklist; (iii) OHS performance criteria as part of contractor qualification, selection, ongoing monitoring and contract renewal decisions; (iv) procedures to ensure conformance of worker accommodation provided by contractors with IFC PSs; (v) requirements to enable contract workers can access an appropriate grievance mechanism; and (vi) procedures to ensure that engagement of migrant workers is on substantially equivalent terms as non-migrant workers performing the same work. 

Supply Chain  

Concord has in place procedures to undertake annual supplier assessment and requires its suppliers to at least have certified quality, OHS and environment management systems in place to qualify as Concord’s suppliers. The company will, as part of the ESMS upgrade process (ESAP #1), include in the annual supplier assessment program, appropriate procedures to assess supplier’ policies and procedures to prevent child labor and forced labor, and OHS performance.  

Resource Efficiency 

Concord manages environmental impacts of its projects and operations as per its environment management system and sets emission reduction/avoidance targets for NO X  , SO 2  , greenhouse gas (GhG) emissions, water and energy consumption. Further, in case of future greenfield projects, project specific resource conservation, pollution prevention, and mitigation measures that meet the Performance Standards and the WBG EHS Guidelines will be identified during the project specific environmental assessment, and incorporated into the Environment and Social Management Plan (ESMP). The company also implements resource efficiency in their office operations.  1 m 3  /day of domestic water is required during construction and will be sourced from neighboring villages and tankered to the project site.  Water consumption of 2.4  m 3  /day during operation stage will be for domestic purposes for operation staff only, hence material impact on water sources is not expected on account of the projects both during construction and operation stages.  The water to be used for potable purposes will be ultraviolet light treated for disinfection and pumped to overhead tank in the substation cum control room building. 

Energy and Material Efficiency Projects  

In 2016, Concord had a total installed capacity of 2,547MW, and generated 3,722,350MKWh of renewable energy which results in GhG avoidance. The company has implemented other energy and emission reduction initiatives including sensor lamps in the office building, reduction in number of office cars, purchase of electric automobiles, and encourages staff to car pool and take public transport. 

Greenhouse Gases  

The electricity generated by the company’s wind power plants and solar power plants resulted in avoidance of 3,150,000 tons of carbon dioxide equivalent (tCO 2e  ) emission and the company’s renewable energy operations have cumulatively resulted in avoidance of 16,680,000 tCO 2e   to date. Each of the two projects will result in GhG emission avoidance of about 176,000 and 148,000 tCO 2e   per annum respectively. 

Pollution Prevention  

Air Emissions and Ambient Air Quality  

Wind projects do not represent sources of atmospheric emissions.  However, temporary impacts to air quality may occur during the construction phase. Therefore, the company will implement measures to minimize dust during construction period including: covered transport of material; spraying of water in vehicle movement areas; management of fill/excavated earth, construction rubble including staggered excavations at neighboring locations and wetting stockpiles; restricting excavations and material handling during high wind conditions; dust suppression measures; vehicular movement planning; paving/hardstanding vehicular movement areas in the substation; minimizing time for which excavated earth is left loose at site;  management of pollution from vehicular and equipment emissions,  and other measures for minimization of fugitive dust emissions. 

Noise  

Baseline noise levels in communities nearest to both the Huanghou and Huayuan  projects fall within national ambient noise standards for villages/rural communities. Additionally, the turbines at both locations are sited on mountain ridge generally away from habitation and randomly distributed with about 500 m distance between turbines. However, temporary increase in ambient noise level is anticipated on account of use of earth moving and other construction equipment and increased traffic for material movement during the construction phase.  Incremental noise level increases during construction will be temporary, restricted to day time working hours and limited to the vicinity of the noise generating source, except in case of movement of material through/near habitations or other sensitive receptors.  In addition to ensuring that the equipment is well maintained and has appropriate mufflers, the company will ensure that the construction work will be carried out only during day time and no noise generating equipment will be operated at night, transport routes will avoid sensitive receptors, and appropriate transportation time planning is undertaken. In addition to ensuring use of appropriate personal protective equipment while operating/working in the vicinity of such equipment, the construction company will be required to reduce exposure of its operators/workers to   noise generating equipment. Noise from individual turbine during operation phase decreases to below national ambient noise standards at a distance of 280 m from the turbine. There are no habitations or other sensitive receptors within 300 m of any of the turbines. Further, due to the sparse spacing of turbines cumulative noise impacts not expected.

Wastewater Treatment  

Generation of wastewater is mainly limited to sanitary waste during construction and to a much lesser extent operations of wind projects. Each of the projects is  expected to generate about 2 m 3  /day of contaminated construction wastewater and 0.8 m 3  /day of sewage during construction and about 2 m 3  /day during operation. The projects ensure that construction waste water (from equipment cleaning, transit mixer washing and other equipment washing/maintenance work) will be disposed through an oil water separator and settling tank. The treated wastewater will be used in dust suppression. The sewage will be treated through septic tank and soak pit both during construction and operation stages. 

While construction will generally be avoided during rains, the company has developed a detailed soil and water conservation plan. Under the plan locations and quantified areas have been identified and estimated for implementation of measures to prevent erosion including areas for provision of vegetative cover, areas to be covered by geotextiles, area for provision of drains and sediment traps and areas for provision of retaining wall/runoff barriers.

Solid Waste Management  

Surplus excavated earth will be used for road and area leveling, back filling and for localized leveling work around the wind turbines. The Project Company will ensure that other wastes (packing material, metal, debris, cement bags, drums/carbuoys etc.) are collected, stored and disposed off to re-users or in government authorized debris treatment and disposal areas. During operation stage about 7 tons per annum of garbage and domestic waste will be generated in the substation/cum residential quarters. This will be disposed to local government authorized disposal areas. Concord, promotes a paperless office culture in its operations. Waste paper and other office garbage are recycled through a qualified agency. Further, the company enters into a take back arrangement with suppliers for waste toner cartridges, ink cartridges, fluorescent tubes to facilitate their recycling/reuse.

Hazardous Materials 

Hazardous materials (transformer oils, dielectric containing material, paints, batteries etc) and hazardous wastes (used oils, waste/residual paint, oil/paint soaked rags/material, filters, empty oil/paint/chemical drum/barrels etc) are expected to be generated during construction and operation. The individual project companies will ensure that hazardous material and hazardous wastes handled/generated at site (both during construction and operation) are: stored under segregation and containment; handled/used with appropriate care and personal protective equipment; and disposed off through entities authorized to handle and dispose hazardous wastes. Further, the company will ensure that: transformers do not use PCB containing oils; and ozone depleting substances banned/phased out under Montreal Protocol are not used.  

Community Health and Safety 

Concord will, as per its updated ESMS (ESAP #1),  identify and mitigate community health, safety and security impacts in accordance with IFC’s Performance Standard 4 provisions.  Further, the company will implement measure to minimize the risk of exacerbation of community exposure to disease due to influx of labor or due to changes in land/hydrologic or other terrestrial regimes. Additionally, where an influx of labor is expected, Concord will provide or require its contractors to ensure that: in the labor accommodation appropriate facilities and amenities are provided including housing, toilets, washing and cleaning water, potable drinking water and cooking fuel; treated sanitary waste water meets IFC requirements prior to discharge; and potential host community impacts on account of influx of labor are assessed and managed.

Further, based on the project specific social and environmental assessment, Concord will implement appropriate measures including: material movement planning; speed controls; barricading of excavated areas; safety signage; provision and use of appropriate personal protective equipment; illumination; mitigation of shadow flicker ; to reduce fugitive emissions; restriction of night time activities to low noise generating work; monitoring and mitigation of ambient air quality as also noise impacts; provision of aviation light (night sighting) and paint/markings (for day sighting); adherence to safety offset criteria; wind turbine cluster design with uniform size, design, shape, colors, painted in a non reflective neutral color to minimize adverse visual impact; and other measures to mitigate public health and safety risks and impacts.. In transmission line route planning, Concord will take into account risks and impacts including electrocution, as applicable. Further, for communities’ resident in the vicinity of the transmission line, Concord will implement a general awareness program detailing dos and don’ts to minimize electrocution risk. The company will prepare and implement an onsite and offsite Disaster and Emergency Management Plan at each of its project sites.

The WTGs in Huanghou and Huayuan projects are located on mountain ridge and there are no habitations within 300 m of any of the turbines at both the project locations and the turbines are themselves located about 500 m from each other. Shadow flicker impact assessment has been undertaken, which indicates that no habitation and other sensitive receptors will experience shadow flicker impact.  Material noise impacts on communities is not predicted due to these two projects.  The wind turbines will be provided with aviation light (night sighting) and paint/markings (for day sighting); and wind turbine cluster will be designed with uniform size, design, shape, colors, painted in a non reflective neutral color to minimize adverse visual impact. Both the project companies will implement measures to minimize adverse impacts on communities by  restricted working hours, appropriate disposal of sanitary wastewater and hazardous waste, transport planning and providing migrant workers with adequate living facilities. 

Infrastructure and Equipment Design and Safety  

The projects and associated facilities have been designed to national engineering standards. Both the projects are located in seismic zone VI with moderate seismic hazard, which has been taken into account in the design of turbines and their foundations to prevent tower failure. The sites of both the projects are low risk for floods and cyclones.The turbines have been designed to remain safe in storm situations as well.  

Ecosystem Services  

The project companies will source water from the nearby villages for construction and operation. Material impact is not expected on account of this water consumption. Further, a detailed soil and water conservation plan has been prepared for both projects to minimize soil erosion and related impact on the water bodies that are of importance to communities and also species of concern mentioned at PS6 below. Baseline surface water quality assessment has been undertaken and water quality monitoring will be undertaken during construction period to upto one year post the construction completion to assess any impact on the surface water bodies of importance, and the company will implement appropriate mitigation measures, if required

Emergency Preparedness and Response  

Concord’s current ESMS requires each project company to develop and implement a tailored emergency preparedness and response plan, and outlines the main contents of the emergency response plan.  Both the project companies will prepare and implement an Emergency Response Plan to deal with emergencies such as electrocution, fire, community safety incidents, natural disasters, and others based on the risk assessment. Emergency numbers will be displayed at site and in the nearby communities.  Joint emergency response drills with district emergency management authority will be undertaken every year.

Security Personnel  

Concord deploys in-house security staff at sub stations/control rooms and they are not armed. Concord’s existing ESMS requires each project company to put in place a security and safeguard management plan but detailed guidance on how the plan needs to be developed and what principles it should adhere to have not been provided. The company will, as part of the ESMS upgrade, put in place guidance for project companies on developing and implementing security and safeguard plan the meets IFC PS4 provisions and includes amongst other aspects: delineation  of clear objectives and permissible actions security personnel; procedures requiring that security incidents are recorded, investigated and corrective action implemented; procedures requiring that  bona fide complaints against security personnel are investigated/disciplinary actions implemented; and having in place a grievance mechanism for aggrieved members of community or employees in the event of a violation of the code for security personnel .    

Protection and Conservation of Biodiversity 

Huanghou and Huayuan wind power projects are located in the Qin Ling Mountains of Henan Province in China, which is classified as deciduous forests ecoregion. Both projects are within landscapes of largely Modified Habitats (e.g. secondary forests, agriculture, orchards) with some patches of natural low density evergreen and deciduous forest. The  turbine layout at both project sites is irregular, on mountain ridges and turbines are sparsely distributed (i.e. turbine to turbine distance is approximately 500-700 m on average). Each turbine requires a conversion of about 2000 m 2   of land (0.2ha), of which about 1000 m 2   (0.1ha) is permanent conversion while the balance will be revegetated/rehabilitated post completion of turbine construction. Total footprint at each of the two site prior to rehabilitation is estimated at 10 ha, distributed over about 40 separate  locations of which 5 ha will be rehabilitated.

IFC conducted an internal screening for Critical Habitat, using IBAT and consultation with external species experts. Four species of concern were identified as potentially occurring within a 50km radius of both projects but did not meet thresholds for Critical Habitat.  No protected areas or key biodiversity areas are found within 50km of either project site as per the screening.  

One project area is immediately adjacent tothe predicted range of the IUCN Critically Endangered (CR) Chinese Giant Salamander ( Andrias davidianus  ). Given the uncertainty over range data, the species is being treated as a species of concern until confirmed otherwise.   Expert consultations with a member each of Chengdu Institute of Biology,  IUCN SSC Amphibian Specialist Group, and Zoological Society of London and IFC in-house experts   for Chinese Giant Salamander indicate that this species is likely not present within the area of influence of either of these two projects. Regardless of findings, the projects have in accordance with national regulatory requirements undertaken a soil and water conservation assessment, and will be implementing several measures to avoid and mitigate any impacts to water quality or quantity during  construction, as well as erosion impacts. The project will also, as mentioned at ESAP # 8,  implement measures to prohibit possession, sale or purchase of Giant Salamanders and other legally prohibited, CITES listed, or threatened species by staff and contractors.

The project overlaps the known range of CR  Baer's Pochard ( Aythya baeri  ), EN Scaly-sided Merganser ( Mergus squamatus  ) and  EN  Saker Falcon ( Falco cherrug  ).  Baer’s Pochard and  Scaly-sided Merganser  are not considered WTG collision prone and the project habitat type (mountain ridgeline) is away from their preferred habitat.  Saker Falcon are potentially at risk from project structures (turbines/powerlines) if breeding within or adjacent to the project sites. The project locations are not known to be prefereed breeding ground for Saker Falcons and typically, mountainous areas are not their preferred habitat.

Additional species have been identified which are at risk of collision with the WTGs or associated transmission lines -  specifically, Eastern Imperial Eagle  Aquila heliaca  , Pallas’s Fish Eagle  Haliaeetus leucoryphus  , Great Bustard  Otis tarda   and Dalmatian Pelican  Pelecanus crispus  .  IBAT screening indicates that both sites are within the East Asia/Australia migration flyway. No information on migratory bird activity at either site is available, however neither of the project sites are within documented areas of high migration activity .   No information is currently available on the occurrence or activity of bat populations at either project site.. 

Concord’s current ESMS includes policies and procedures to minimize biodiversity impacts and in particular assess risks to birds and bats on account of projects implemented by the company and its subsidiaries.  Taking account of the available species occurrence information, and identified information gaps for the Huayuan and Huanghou projects, Concord will contract an independent environmental consultant with experience of designing monitoring and mitigation measures for assessing and minimizing the  effects of wind power projects on birds and bats. 

The consultant will design and implement a post-construction bird and bat fatality survey program which will run for a minimum of two years from the start of the operational phase at each of the two projects.  The monitoring program will include procedures for; immediate reporting and implementation of adaptive management measures if collision fatalities of priority species occur; Quarterly interim reporting of bird fatality search survey results and a full report of corrected bird fatality estimates at end of  12 months; (c)  to undertake bird/bat area usage, breeding and hit/mortality monitoring on an ongoing basis; and (d) retain/engage an ornithologist/bird/bat expert to review the monitoring results and suggest adaptive management and mitigation measures based on the monitoring findings.

Concord will contract the environmental consultant to; (a) develop and implement a post-construction monitoring program to assess flight activity and collision risk of any priority  bird species using the site: (b) conduct a breeding season survey for Saker Falcon in each project’s area of influence; (c) conduct a non-breeding season survey of suitable rivers and other water bodies to check for the presence of Baer’s pochard and Scaly-sided Merganser, Chinese Giant Salamander and (d) conduct the post construction monitoring of fatality searches, including carcass removal and searcher efficiency trials. .The consultant will provide reports that detail the results for each of these surveys, suggest adaptive management measures to mitigate any negative effects on globally or regionally threatened species identified during surveys, and where necessary  contribute to the development of species specific action plans to mitigate identified impacts. 

Concord will, as part of the ESMS upgrade: (i) adopt a  policy, not to undertake project or operational activities that are in, or have the potential to impact, a Tier 1 critical habitat; and (ii) as a policy not undertake a project in Tier 2 critical habitat without first developing a mitigation plan in line with PS6 provisions particularly related to creation of offsets and measures that demonstrate net gain. Further, the company will, as part of the ESIA for future wind power projects undertake: (a)  pre-construction bird/bat baseline surveys of an appropriate duration designed and implemented by an experienced ornithological and bat specialists. These surveys should collect data adequate for characterizing bird/bat activity at the project site, and suitable for conducting formal collision risk modelling for any high conservation status, collision risk vulnerable bird species using the project site.

Ecosystem Services 

A detailed soil and water conservation plan has been prepared for both projects to minimize soil erosion and related impact on the water bodies that are of importance to communities and also species of concern mentioned above. Baseline surface water quality assessment has been undertaken and water quality monitoring will be undertaken during construction period to upto one year post the construction completion to assess any impact on the surface water bodies of importance, and the company will implement appropriate mitigation measures, if required. In addition, each project company will implement measures including:

-    Researching  local hydrogeology  to identify areas of groundwater discharge and recharge and their potential relationships with surface water bodies and groundwater quality.

-    Maintaining suspended sediment concentrations at watercourses at preconstruction levels. 

-    preventing  the release of pollutants such as fuels, lubricants, concrete waste and washings, and wastewater from site toilets and washing facilities. 

-    Identifying  and avoiding  unstable slopes and local factors that can cause slope instability (groundwater conditions, precipitation, seismic activity, slope angles, and geologic structure).

-    Avoiding  creating hydrological conduits between two aquifers.

-    Constructing  drainage ditches only where necessary. Using  appropriate structures at culvert outlets to prevent erosion.

-    Avoiding  altering  existing drainage systems, especially in sensitive areas such as erodible soils or steep slopes.

-    Using  special construction techniques in areas of steep slopes, erodible soils, and stream crossings. Crossing  water bodies at right angles to the channel and/or at points of minimum impact, without alteration of the stream bed to the ordinary high water level.  Avoiding or minimizing alteration to natural drainage patterns.

-    Developing  a storm water management plan to ensure compliance with regulations and preventing  off-site migration of contaminated storm water or increased soil erosion.

-    Identifying  water body crossings prior to construction to minimize the span over or trenching within them and to avoid the more environmentally sensitive portions of the water bodies.

-    For stream crossings, locating  transmission line support structures as close as possible to the upland edge of the stream buffer to preserve taller vegetation, thus minimizing trimming requirements and potential thermal warming of existing shaded water bodies.

In case the  ongoing monitoring indicates that Chinese Giant Salamander (CGS) is present, the following actions shall be taken:

-    Identify and contact stakeholders that research and manage local CGS populations to get recommendations for avoiding or mitigating impacts.

-    Map the CGS distribution and abundance within potentially impacted drainage systems.

-    Provide an assessment of life history variables, population structure and recruitment rate.

-    Provide an assessment of existing local threats to CGS (land ownership and use, harvest, and illegal trade).

-    Assess the effectiveness of the local existing management regime to preserve and protect CGS. In coordination with local stakeholders, develop and implement a CGS protection program. 

The company will not introduce any invasive alien species, and will as part of the above monitoring program include procedures to identify potential sources linked to its activities through which the alien species could inadvertently be introduced and implement measures to prevent their introduction. 

Stakeholder mapping and Stakeholder Engagement Plan 

Concord has, in keeping with articulated centrality of stakeholders to its business, has mapped the key stakeholder groups and has developed an engagement framework for each group. The key stakeholders identified by Concord include: government and regulators, shareholders, employees, suppliers, contractors, clients, and the community. The company has also identified the expectations of each of these stakeholder groups and the appropriate engagement channels for addressing each of the expectations of each group (e.g. meetings, calls, publication of reports, submission of documents, donations) . Further, the company has mapped each group’s influence on Concord and Concord’s influence on each stakeholder group. The company, based on the feedback received through his stakeholder engagement process, develops its E&S priorities and plans. The company will as part of the ESMS review process (ESAP # 1), undertake a review of the stakeholder engagement approach and develop this into project specific detailed stakeholder engagement plans (SEPs) in accordance with IFC PS1 provisions, which will include details on engagement strategy, information disclosure, monitoring, reporting and guidance on maintaining records of stakeholder consultations. SEPs will be developed to ensure ongoing community engagement during current operations, and updated for construction as also and operation phases of any expansion projects. Further, as part of the SEP, the company will develop a plan for ongoing disclosure of information to key stakeholder groups. Concord will, for both Huanghou and Huayuan projects develop a detailed stakeholder engagement plan.  

Consultation  

The company undertakes consultations for its projects in accordance with the regulatory requirements and develops its CSR program through ongoing consultation with local leaders and villagers. The processes for ongoing consultation will be further formalized and strengthened as part of the updated SEP.

The two project companies have undertaken project level consultations for each Huanghou and Huayuan project in accordance with the regulatory requirements. The consultations for Huanghou project were undertaken during June to October 2015, and for Huayuan project between May to October 2016. The consultation process involved: putting up information and notices through Concord website and in the communities resident in the vicinity of project sites; workshop/seminars; and a public perception survey. Relevant government authorities and regulatory agencies, technical experts and communities’ resident in the vicinity of the project sites were consulted. The process involved: first publicizing project related information and contact details seeking inputs from the general public to the EIA process; a second public notice was publicized summarizing key risks and impacts, and the respective mitigation measures seeking public inputs to the findings of the EIA; questionnaire survey was conducted covering 218 and 203 respondents for Huanghou and Huayuan projects respectively. The perception survey covered members of County Environment Protection Bureau and communities in the project area; workshop  for each project in which the findings of the EIA and mitigation measures were discussed with 24 participants including environment protection agency representative, village representatives, township authorities, ; and the full EIA report was disclosed to the public through Nanzhao county government website for the Huayuan project prior to issue of environmental approval. The key input received in the consultation process was that the stakeholders are generally supportive of the project but there is an expectation that the company will strictly adhere to the mitigation measures delineated in the EIA and to the extent possible generate employment and other benefits the for local population. The company has committed to meet these expectations to the extent technically possible

External Communications and Grievance Mechanisms  

Concord has as part of the ESMS developed a community grievance redress procedure. OSREP is overall responsible for development and implementation of this community grievance redress procedure. The company will, as part of the ESMS upgrade process, update this procedure to include: (a) timebound internal resolution and/or escalation steps; (b) communicate to affected communities the channels/means for  lodging concerns/grievances; (c) redress the grievances in a time bound manner; (d) upon redress communicate the decision to the aggrieved person/community; (e)  provide a mechanism to appeal against a redress decision in a higher joint committee if the aggrieved persons/community is not satisfied by the redress proposed in the first instance; (f) document grievances received and redressed; and (g) analyze grievance related data to identify patterns and undertake systemic improvements as needed.

Information Disclosure and Ongoing Reporting to Affected Communities 

Concord discloses its environment, social and governance report as part of its annual financial report. Further, EIAs and project information is disclosed in accordance with regulatory requirements as outlined above. Concord will disclose this ESRS, ESAP and subsequently when it is updated , an outline of its updated ESMS through its website. The two project companies will disclose the ESRS and ESAP to the neighboring communities in an appropriate form and language at a third party location nearby. The two project companies will also periodically disclose information on status of implementation of the ESAP.  

Considering the nature of the investment, Concord will disclose this ESRS and ESAP through its website at: www.cnegroup.com and these will also be disclosed in the local language and English at third party locations in villages near both the project sites. at the following address:

Any queries and/or comments about the project may be directed to:

Concord Contact Person: Ms. Yang Shuke
Company Name: Concord New Energy Group Limited
Mob: +86 13581619407
Email ID: yangsk@cnegroup.com
Website: www.chinawindpower.com.hk/en/