PS 7 is not applicable as no indigenous peoples are present within or in proximity to the Project area or its OTL route.  PS 8 is not applicable as the ESIA has not identified the presence of historical or cultural sites within the project site or along the proposed overhead transmission line (OTL) route. However, additional measures are discussed in PS1 since Mets Masrik and area are stated to have a rich heritage of monuments of history and culture, including Stone Age houses, medieval village territories, cemeteries, obelisks and khachars (cross stones).

This is a Category B project according to IFC’s Sustainability Policy. The ESIA concluded that the project has manageable impacts due to the avoidance of physical displacement, no cultural heritage, and no Indigenous Peoples in the area.  Potential impacts due to economic displacement and on biodiversity values are also considered to be limited.                                                   

  Policy:

As defined in the ESAP item #1.1 the company will establish an overarching environmental and social policy. The policy will specify that the project will comply with applicable laws and regulations, including those laws implementing host country obligations under international law. The policy will indicate who, within the client’s organization, will ensure conformance with the policy and be responsible for its execution.

Environmental and Social Assessment: 

Initial Environmental and Social Assessment of the project was conducted prior to the tender, under grant-funding from Strategic Climate Fund’s Scaling-up Renewable Energy Program (“SREP”) administered by the International Bank for Reconstruction and Development (IBRD). Involvement of IBRD ensured that environmental and social considerations have been included early in the process, starting from the site selection, to avoid such adverse impacts as physical resettlement or location in critical habitat.

After receiving a contract from the GoA, FRV engaged Energy Advisory as the consultant to undertake a full ESIA study of the project for the purposes of meeting national environmental regulations.

Environmental and social risks and impacts identified in the ESIAs prepared in 2017 and 2019 are summarized in the Non-Technical Summary, which is disclosed together with this ESRS, and mainly relate to construction activities, land use, landscape, water resources and biodiversity.

As outlined in ESAP item #1.4, the company will supplement the conducted assessment with a series of women-only engagement activities within the three affected communities of Mets Masrik, Poqr Masrik and Arpunk. The results of a gender analysis will be complied into a Gender Action Strategy, including mitigation of the risk of a gender-based violence in the workplace and within affected communities. The Strategy will cross-reference various management plans that will be used to implement the measures identified. Additional supplemental assessment of potential E&S impacts to address resource conservation and biodiversity risks are described further below in the respective sections of this ESRS.

An assessment of possible cumulative impacts was not considered necessary as the nearest infrastructure development planned in the project area is a much smaller PV solar plant proposed to be developed at 6 km distance. This additional PV solar project is not yet under development, would be located further away from ecologically sensitive Sevan Lake, is smaller in scale (34 hectares) than the proposed project, and only requires 0,3 km of new OTL.  

Management Programs:

The ESIA includes an Environmental and Social Management Plan (ESMP) which describes mitigation measures to eliminate or reduce potential impacts, including dust suppression and noise reduction during construction, controlling sediment and erosion on construction site, fencing the PV plant along the entire perimeter and others, and monitoring actions to ensure that the identified mitigation measures are implemented. As described in ESAP item #1.3, the company will elaborate the existing ESMP into a stand-alone overarching framework ESMP, which will include (i) all mitigation, monitoring and management measures set out in the ESIA together with any additional IFC/EBRD requirements, which will be implemented over the lifetime of the Project; (ii) schedule, the resources and performance indicators; and (iii) definition of responsibilities: organisational structures, roles, communications and reporting process required for the implementation of the ESMP.  The ESMP output documents will include a Contractor Construction ESMP prepared by the EPC Contractor to achieve the E&S performance objectives set out in the framework ESMP; FRV Environmental and Social Management System required to implement and monitor the Management Actions described in this ESMP; and detailed implementation sub-plans to be developed and executed to address the mitigation and compensation measures identified through the ESIA and the Supplementary studies such as: Code of Conduct for employees and contractors (addressing gender-based violence in the workplace and communities); Workers accommodation plan; Community Health and Safety Plan; Community Integration Plan; Occupational Health and Safety Plan; Traffic Management Plan; Emergency Preparedness and Response; Erosion and Sediment Control Management Plan; Archaeological/Cultural Heritage Chance Finds Procedure; Dust reduction Plan; Waste water management Plan; Waste Management Plan; Hazardous materials management Plan; Noise pollution minimization Plan; Water Resources Plan; Site Security Plan and Security Management Plan.

According to the draft EPC contract reviewed by IFC, the EPC contractor and O&M service providers will be contractually required by FRV to follow applicable E&S requirements, including IFC Performance Standards, and fully implement E&S commitments specified in the ESIA and ESMP. For this purpose, the contractors will be obliged to (i) develop a number of E&S ‘implementation’ sub-plans detailing the controls that will be applied to ensure compliance with E&S requirements; and (ii) submit these documents for FRV review and approval within an agreed timeline relative to the project schedule. The contracts also include a clear statement that the contractor is responsible for the E&S performance of subcontractors and suppliers. Contractors will be required to include in subcontracts the requirements to comply with IFC PSs and all E&S requirements that are appropriate for the works being subcontracted.  

Organizational Capacity and Competency:

As described in the ESAP item #1.2, the company will appoint Environmental, Health and Safety (EHS) Manager, who will be responsible for overall project’s E&S performance. The Developer will include the requirement in the EPC and O&M contracts that E&S personnel be appointed throughout project implementation.

Monitoring and Review:

As described in ESAP item #1.3, EHS monitoring requirements will be included in the ESMP for the construction and the operation phases of the project. The E&S staff contracted by the EPC contractor/O&M provider will be responsible for the implementation of the ESMP, including contractors’ developed management plans and programs, monitoring actions and reporting.

As described in ESAP item #1.2, FRV’s EHS Manager will oversee implementation of project’s monitoring actions required by ESMP and control contractor and subcontractor E&S performance. This will involve both visits to work locations, reviews of records kept and reports submitted by the contractor, and follow up as needed to ensure timely resolution of issues and non-compliance with E&S requirements.

Clear responsibilities and reporting lines will be determined to avoid duplication of effort, or conversely, gaps in monitoring.

At any stage of construction or other work, if the contractor has not taken appropriate action to correct any identified non-compliances, the company will order the contractor to stop work until E&S performance is brought under control. FRV E&S Manager will be part of the process for signing off on all payments to contractors.                                                 

    Human Resource Policies and Procedures

The Project will provide up to 240 jobs during the construction phase for a duration of eighteen (18) months which will include unskilled labour (e.g. security personnel), semi-skilled labour (electricians, welders, fitters, etc.) and skilled labour (engineers and management professionals).  As described in the ESAP item # 2.2, the company will develop a Local Employment Plan to give a preference in hiring to the local community members.

During operation, the Project will provide approximately 12 jobs for a duration of 20 years, which will include skilled labour (such as electrical and mechanical technicians) and unskilled labour (such as module cleaners and security personnel).

As described in ESAP item #2.1 the SPV will develop its own overarching Human Resources (HR) Policy in line with IFC PS2 requirements and local labor regulations and ensure that the HR policy and procedures adopted by the EPC contractor/O&M provider are aligned with it. These HR policies and procedures will stipulate terms of employment such as: wages and benefits; hours of work; overtime arrangements and compensation; leave benefits; and vacation and holidays. Terms of employment will meet national and PS 2 labor requirements and will be included in employee contracts. The HR Policy and procedures will include a stated policy on aspects such as: non-discrimination and equal opportunity in recruitment; an anti-sexual harassment policy; working conditions (including occupational health, safety and security), equal facilities for men and women workers, employee termination, retrenchment, workers right to organize, collective bargaining rights, prohibition of child and forced/bonded labor, disciplinary action, and a worker grievance mechanism, including an anonymous reporting line for sexual harassment and gender-based violence. The HR Policy and procedures will also provide for staff and workers training (induction and recurrent) related to HR, technical, wildlife protection, and occupational health and safety aspects. The training management systems and procedures will also cover contractual workers and workers hired by third parties.

As per ESAP item #2.3 the company will develop a formal grievance mechanism for employees and contractors and disseminate information about its uses to the workforce in the language of the worker.

Working Conditions

Although preference will be given to local employment, the project envisages a requirement of skilled workforce from outside to the immediate project area. A site labor camp will be constructed within the project boundaries and maintained until the completion of construction phase. As part of ESAP Item#1.3, specifically the preparation of a “Workers Accommodation Plan”, the company will ensure that adequate labour camp facilities and amenities are provided onsite to construction workers in line with IFC’s and EBRD’s Good Practice Note on “Workers’ accommodation”, including: adequate living/sleeping facilities and space per person; fire detectors/extinguishers; potable water that meets national standards; climate control; toilets, washing and cleaning facilities; canteen; locker/storage facilities; and facilities for management and disposal of garbage, sewage and other waste. The company will periodically review and monitor the condition of the labour camp.

Occupational Health and Safety

Key occupational health and safety (OHS) risks for a PV project include slips and falls, potential hazards from on-site moving machinery, heavy load lifting, exposure to electric shocks and burns, and safety issues related to PV module assembly. As part of ESAP Item#1.3, specifically the preparation of an “Occupational Health and Safety Plan”, FRV will ensure that the EPC contractor and O&M service provider develop a site-specific OHS procedures for the construction and operations phases as discussed under PS 1. The procedures will be designed to be specific to the PV solar sector (in terms of industry specific hazards) and the project site (climate).

The company will also ensure that the EPC contractor/O&M service provider assess and track their OHS performance during both construction and operations. OHS performance evaluations will be carried out and the EPC Contractor / O&M Provider’s EHS Officer will record and track any OHS incidents through an incident tracker and will report on OHS statistics during both the construction and operations phases.                                                                                             

 Pollution Prevention

During construction, a minor and insignificant amount of pollution to air, noise, water and soil is anticipated which will be readily mitigated through standard pollution prevention and control measures.  During the operational phase, no environmental pollution impact other than wastewater and waste generation is anticipated.  FRV will require the EPC contractor / O&M operator to implement pollution prevention measures in accordance with their management procedures to mitigate the risk of any pollution as discussed under ESAP the item#1.3, specifically the preparation of an ”Erosion and Sediment Control Management Plan”; “Dust reduction Plan”; “Waste water management Plan”; “Waste Management Plan”; and “Hazardous materials management Plan”.                                               

Resource Efficiency

As outlined in the ESAP item #3.1, FRV will quantify water requirements for construction (including non-potable water to be used for dust control) and operation phases of the project and assess potential impact on availability of water resources to local communities.

Solid Waste Management

It is anticipated that project might handle limited quantities of potentially hazardous materials such as transformer oils, paints, batteries and generate limited quantities of potentially hazardous wastes such as used oils, waste/residual paint, oil/paint-soaked rags/material and containers, filters, and used batteries.  The hazardous waste will be managed as per regulatory permit conditions (hazardous waste authorization) and disposed through authorized hazardous waste management agencies.  Non-hazardous solid wastes such as paper, wood, plastic, scrap metals and glass will be generated during construction phase.  Solid and hazardous waste generated by the project during construction phase will be managed as per detailed management plans and programs to be formulated based on the ESIA/ESMP and discussed under PS 1 earlier.   FRV will ensure that waste management procedures are integrated as part of the Project ESMS discussed under ESAP. Waste management will be a KPI to be monitored during construction and operational phases.

GHG Emissions avoidance

As per the estimates of FRV, this 55 MW capacity PV solar project is estimated to offset the equivalent of 54,000 tons of CO2eq/year from the electric grid of Armenia.                                                  

    Before start of construction, the client will assess risks and impacts to host communities of the project, such as the influx of contractors/migrants.  Based on the findings, as described in the ESAP item #1.3 the client will develop a Community Health and Safety Management Plan that is designed to manage such risks and impacts effectively. The plan should include gender-specific mitigation measures to ensure negative impacts on women due to the project are addressed.

As defined in ESAP item #1.3, specifically the preparation of a “Code of Conduct for employees and contractors”, the client will develop and implement a code of conduct that will be applicable to all employees and to workers engaged by contractors and subcontractors. It will include references to non-discrimination, sexual harassment and gender-based violence, and rules for interaction with the local population. The client will implement measures such as induction and training programs on HR policies and procedures, the code of conduct, local laws, and awareness raising for the workforce about refraining from unacceptable conduct toward community members, specifically women and children; including requirements that contractors cooperate in investigating complaints about GBV.

As defined in the ESAP item #1.5, the company will revise their community grievance mechanism to ensure it can receive and address complaints of GBV between employees/contractors and members of the community. This will include a mechanism that ensures confidentiality for survivors of GBV and, where possible, effective referrals to support services or the provision of support services.   The grievance mechanism must identify specific response methods for GBV involving children.

The entire perimeter of the project site will be fenced and entry to the project site will be regulated. The main access road to the project plot is the 2-lane state road M14 between Mets and Pokr Masrik villages. Inside the solar park, FRV will construct 4m wide access road. The company will implement appropriate mitigation measures including setting speed limits, posting of traffic marshals and material movement planning to reduce community exposure to traffic safety risks. Further, at the project site, the company will exercise appropriate access control; safety signage; illumination and other measures to mitigate the risk of accidents for general public during construction. As part of Project ESMS and ESMP discussed under ESAP, FRV will require the EPC contractor/ O&M operator to implement traffic management and accident prevention measures to mitigate any impact on local community.

The project will engage unarmed security personnel. As part of ESAP item #1.3, specifically “Security Managament Plan”, the company will ensure that security management procedures integrating the following aspects are formulated and implemented by the EPC Contractor/O&M service provider: security risk assessment; working procedures; past records of security personnel employed are screened; security personnel have clear objectives and permissible actions are laid out; security personnel are trained to avoid abusive conduct even under stress or provocation; security incidents are recorded, investigated and corrective action implemented; complaints against security personnel are investigated and appropriate disciplinary actions are implemented; and there is a community grievance mechanism in place for aggrieved members of local community or employees, in the event of a violation of the code for security personnel.                                               

  The project area is a highly modified habitat traditionally used for agriculture and grazing.  However, it is located in the protection (buffer) zone of Sevan National Park, an IUCN category II protected area. The area is covered by the legal framework of the Law of the Republic of Armenia on Lake Sevan. The project is within the “Direct Impact Zone”, for which Article 10 of the Law restricts certain types of ecologically harmful economic activity. Development activities such as solar projects are not on the list of prohibited activities within this zone.

The project is also located within two internationally recognized areas for biodiversity that overlap with Lake Sevan National Park, its buffer zone and with each other. The first of these is the Lake Sevan Important Bird Area (IBA), designated mainly because it is one of the most important breeding sites for the migratory and congregatory bird (NT), the Armenian Gull, Larus armenicus. In April-June each year, about 5000 nesting pairs of these gulls migrate to Lake Sevan to nest and breed. The Gilli Preserve, part of the Lake Sevan National Park, is closest to the project site at 6.3 km to the west.

The second area is a wetland designated under the Convention on Wetlands of International Importance (the Ramsar Convention). This site is the Lake Sevan Ramsar site designated for Ramsar Criterion 2 for the presence of the Critically Endangered Sociable Lapwing, Vanellus gregarius, and Criterion 6 because the area supports 16% of the global population of the Armenian Gull, Larus amenicus, during its breeding season.

While the project is located within an Internationally Recognized Area for Biodiversity (IBA and Ramsar sites), the biodiversity values that define the IBA and Ramsar sites are not found on the project site. The ESIA provides evidence that the 97.5 ha project area is located within a large agricultural zone, primarily on pasture land that is heavily grazed. The field survey of the area requested for Masrik 1 Plant concluded that there are no plant or animal species which may become extinct or are endangered, and that the plant species are common and typical of pastures.

Baseline information is lacking for Spring season when migratory birds arrive and use the area around Lake Sevan. As described in ESAP Item #6.2, the existing biodiversity baseline studies will be complemented with additional field surveys of flora and fauna (including insects) in April-June 2019. This will cover the entire area of 130 ha for PV plant and the OTL route. The company is committed to conduct the studies according to the best international practices and Guidelines (such as Good Practices for the Collection of Biodiversity Baseline Data (approved by both IFC and EBRD). Field biologists team includes a flora expert, a bird expert and an insect expert who can identify the local insect diversity. The study is already underway.

If the Spring field surveys document any important biodiversity values (such as Red List threatened species) using the project site, the project will need to develop mitigation actions to avoid/mitigate any adverse impact on these values to achieve no net loss of biodiversity where feasible.

Based on the information currently available through the project ESIA, IFC concludes that the project site is not located in Critical Habitat per IFC’s PS6. While the biodiversity values of the project site indicate that it is highly modified, IFC will conservatively apply Natural Habitat requirements because the project is located within an Important Bird Area (IBA) and Ramsar site.

Project construction impacts include clearing of flora on the project site, access roads, and removal of topsoil in construction areas. Operation impacts include shading of 37.7% of the occupied area and partial shading of the remaining 62.3%. New plant assemblages may form under the solar panels, most likely originating from nearby sciophyte (shade tolerant) vegetation. Given the highly-modified nature and lack of biodiversity at the project site, no impacts on biodiversity are expected from the project. However, if any important biodiversity values are documented on the project site during the Spring surveys, an impact assessment will need to be undertaken for these values.

The 9.2 km 110 kV OTL will likely have the greatest potential impact on biodiversity through possible collision or electrocution. Water birds, in particular, are known to collide with transmission lines and raptors tend to roost on pylons. The project area is flat and treeless and thus the OTL pylons will likely be used by birds as perching sites, creating suitable habitat for migratory and resident birds, particularly raptors. If rodent populations flourish in that area, many raptors could be present in or around the project site.

Electrocution risk to birds could be completely mitigated by choosing the right pylon design. Although risk of electrocution is low for high-voltage lines since conductors are spaced well apart, the requirement for the bird-safe design of pylons was included in the EPC contract and verified by IFC. Collision risk will be minimized by installing bird flight diverters (spirals) on the ground wire as described in ESAP item #6.1.

In line with PS 6 objectives to protect and conserve biodiversity, as described in ESAP item #6.3, the company will develop and implement a bird mortality monitoring program to assess impacts of the Transmission Line. If any bird species are found injured along the Transmission line during post construction monitoring, they will be transferred to a rehabilitation center for veterinarian care and potential re-release into the wild.

As defined in the ESAP item #6.4, the project will conduct consultations with stakeholders of the Ramsar site, and implement additional programs, as appropriate, to promote and enhance the conservation aims and effective management of the area.                                                 

  Stakeholder Engagement Plan has been developed for the project. 

The ESIA documents stakeholder engagement and consultation which has been carried out to date.

As of today, 7 public meetings with affected communities (Mets Masrik, Poqr Masrik and Arpunk) were conducted as part of the ESIA and LRP preparation on: January 30, 2018; October 15, 2018; December 13, 2018, January 30, 2019 (2), 28 February 2019, April 26, 2019 and May 8th, 2019. Going forward, the company is planning a number of public meetings in May with focus on the LRP, final ESIA and the Gender analysis.

As well, wide-ranging stakeholder consultations have been carried out including representatives of State Bodies and Non-Governmental Organizations along with representatives of the Historical and Cultural Monument Protection Agency of the Ministry of Culture and with representatives of the Ministry of Nature Protection (including Ramsar convention’s focal point in Armenia). 

Stakeholder feedback have been used to focus the assessment and, where appropriate, to influence Project design and execution.

The Grievance Redress Mechanism has been established within the project so that community residents and project affected people have the opportunity to submit proposals or to appeal decisions, practice or activity that may arise during project implementation or compensation of land.

Grievances can be addressed at the local community level, where the grievance is recorded and forwarded to the Developer’s grievance coordinator responsible for registration of grievances and decision on grievance redress.  Grievances that are addressed to the construction and O&M contractors will also be forwarded to the Developer grievance coordinator, even if the contractor decides to settle the grievance on the spot. Also, all project related complaints can be directly addressed to the Developer grievance coordinator via phone or e-mail.

During the site visit by IFC and Wood, a grievance box was noted to be present in the Mets Masrik community. As of today, reportedly no grievances have been received about the project via the grievance box and other channels. However, during meetings held with community representatives and land owners by the Lenders’ Technical Advisor in March 2019, it was clear that local people are not aware of the grievance mechanism is place for the project. As outlined in ESAP Item #1.5, the company will raise awareness of the grievance mechanism through leaflets to be prepared by FRV and distributed to APs with copies held in public meeting places. Contact details of the Developer’s grievance focal point will be posted on the public signs located at the project site.

As defined in the ESAP item #1.5 the company will in addition conduct women-focused engagements which is to be completed as part of the gender analysis; will revise the community grievance mechanism, if needed, to ensure it can receive and address complaints of gender-based violence between employees/contractors and embers of the community; and will undertake focused consultations with local communities with regards to potential cultural heritage features which could be affected by the project.                                                 

The ESIA details that the non-technical summary and ESIA will be disclosed online and within the affected Local Self Governance Body’s Offices.                                               

Full project preparation documents, including the ESIA, NTS, and Stakeholder Engagement Plan (SEP) including the grievance mechanism for affected stakeholders and communities will be available at the following locations:

-Municipality of Mets Masrik

Location:  City Hall, Mets Masrik, Armenia

Email: metsmasrik.gegharquniq@mta.gov.am

Tel: (374) 26 961 283

-R2E2 Fund

Location:  Renewable Resources and Energy Efficiency (R2E2) Fund

Sayat- Nova 29/1 str., Yerevan, Armenia

Tel: (374) 10 588 011

Contact Details for the Public

FRV Services Middle East DMCC

Jumeirah Business Center – 14th floor, Unit 1403-1404, Cluster G, Jumeirah Business Center 1, Jumeirah Lakes Towers P.O Box 392632, Dubai, United Arab Emirates,

Telephone: (971) 4 375 4138

E-mail: cyril.perrotey@frv.com