PS5 Land Acquisition and Involuntary resettlement - does not apply, as long-term land leasing contracts were made under free and mutual agreement in between the sponsor and land owners and Central Puerto has no expropriation rights in case no amicable agreement are achieved. No resettlement is needed for this project either.   

Neither PS 7 (Indigenous Peoples) nor PS 8 (Cultural Heritage) are applicable to the project given the absence of either in and around the project area of influence according to the project’s Environmental and Social Impact Assessment (ESIA). The project was nonetheless required by local authorities to apply ‘chance find procedures”, and stop construction works and report any findings to the relevant authorities, in compliance with Law 25.743 on the Protection of Archeological and Paleontological Patrimony (Proteccion del Patrimonio Arqueologico y Paleontologico) of the Republic of Argentina.                                          

       This is a Category A project according to IFC’s Policy on Social and Environmental Sustainability. Preliminary results from avifauna baseline study found that La Genoveva windfarm is located in a nesting area of endangered species Loica Pampeana and thus impacts from the project could be significant, irreversible or  unprecedented if appropriate measures are not implemented.

      Environmental and Social Assessment and Management System

Central Puerto has attained ISO 14001 (environmental management), 9001 (quality), and OHSAS 18001 (occupational health and safety) management systems’ certifications for its thermal power and hydropower generation operations across Argentina. These management systems, and a system of independent audits, will be extended to La Genoveva at the operational stage.

Policy

Central Puerto’s approach to the environment, the safety and wellbeing of its workers, communities, shareholders, clients and contractors is stipulated in several corporate documents: a Code of Business Conduct, a Mission and Vision Statement, a Code of Corporate Governance, an integrated environmental, social, health, safety and quality (ESHSQ) policy, and Human Resources (HR) policies. The EHSQ policy provides an overarching statement on the principles that guide all activities managed by the company.

La Genoveva has stablished its own policy aligned to the sponsor’s integrated EHSQ policy, and including social elements, key principles and considerations around labor and working conditions, community health and safety, stakeholder engagement and grievance resolution. This Policy is included in the E&S management plan for La Genoveva I.

Identification of Risks and Impacts

Project risks and impacts were primarily identified in the ESIA and prioritized following a risk mitigation hierarchy. Additional baseline studies were required to better assess impacts to the local avifauna and including appropriate mitigation and/or compensation measures for affected species.

 The ESIA for La Genoveva wind park (La Genoveva I and II) was completed in Jan 2017 and received approval (Certificado de Aptitud Ambiental) from the Province of Buenos Aires environmental authority in August 2017. The ESIA covers the following aspects: characterization and location of the project; description of the natural, physical and social environments within the area of influence of the project; a review of the applicable regulatory framework; identification and characterization of impacts from the different phases of the project (construction and operations); and recommendations of control measures to mitigate the impacts from the project. 

Management Programs

The approved ESIA presents a series of management programs to avoid, prevent, mitigate and manage construction and operation related E&S risks and impacts of the project. These plans have been articulated on a formal Social and Environmental Management Plan for construction that has been submitted and approved by Province level environmental authorities and must be implemented by the EPC contractors.

As a result of proposed management programs from ESIA, Central Puerto has completed and submitted the E&S management plan for La Genoveva I project for approval from environmental authorities. The Plan includes the following sub programs designed to manage and mitigate potential impacts and risks: (i) management of construction and hazardous wastes; (ii) Soil (and soil loss) management; (iii) Air emissions; (iv) cultural heritage protection (chance find procedure); (v) environmental noise and vibration; (vi) fugitive emissions control; (vii) potable and wastewater management; (viii) Vector and pest control program (ix) Impacts to fauna and flora (x) traffic control; and (xi) monitoring program.

Central Puerto also has a set of OHS contractual obligation requirements for contractors compiled in a document called “Condiciones Basicas y Generales de Gestion de Higiene y Seguridad” that will be included in the contract with Construction companies of La Genoveva I.  This document defines several aspects of OHS management during construction, and implementation must be monitored and enforced by Central Puerto. This document includes obligations for construction contractors to know OHS risks before performing any job and to apply the safest job procedure available.  Going forward, Central Puerto will include in the contract with EPC construction companies the obligation to implement the approved Management Plan (applicable for construction phase), to provision the budget and resources, and to provide a detailed plan for implementation to meet all obligations and control measures designed in this plan. The Management Plan will require contractors to conduct preliminary risk assessment (Análisis Preliminar del Riesgo) for all construction jobs and implementing preventive measures in accordance with project E&S requirements as well as contractual penalties for non-conformities, including retention of due payments. Implementation of the plan will be monitored by an external audit company (ESAP action 1)

In the addition of the E&S management programs mentioned above, La Genoveva will also implement a : (i) bird and bat monitoring program for a period of 3 years after construction; (ii) Biodiversity Action Plan (BAP) including appropriate mitigation measures that must be implemented to achieve compliance with “net positive gain” requirement triggered by Critical Habitat determination, as described below in PS6 section.

Organizational Capacity and Competency

Central Puerto will have a construction management strategy whereby a central team will closely follow the construction schedule, manage contracts and monitor good industry practices and compliance with local regulations for environmental, health and safety issues.

The sponsor has assigned an environmental and OHS managers to work alongside Ventus (owner’s engineer), to oversee construction activities undertaken by each contractor. Contractors are required to have their own EHS teams, responsible for implementing the management programs and mitigation measures approved for the project. Going forward, Central Puerto must appoint a local community relations liaison (locally based) to manage communication with key stakeholders and community concerns.   (ESAP Condition 2)

Emergency Preparedness and Response

In the Management Plan for construction of La Genoveva wind park there is a specific sub section of environmental contingency plan covering different emergency scenarios such as oil/fuel spills, fires, explosions, floods, thunder storms, earthquakes, failures in wind turbines, damage to cultural heritage sites, damages to fauna and flora. In the OHS requirements for EPC contractors there is also a section describing the requirements for an emergency response plan which contractors must complete and have in place. 

Training

Central Puerto will develop a standard EHS induction training for all workers entering construction site, covering the all safety requirements, as well as most relevant aspects of La Genoveva environmental programs. Central Puerto will also develop a matrix of mandatory training requirements for workers doing hazardous jobs (working at heights, confined spaces, hot working, electrical works, working with chemical agents). Finally, Central Puerto will ensure all workers doing jobs that requires professional accreditation or special training must provide upfront a demonstration of valid professional accreditation (a.e. truck drivers, crane operators, electricians). (ESAP Condition 3)

Monitoring and Review

There is a monitoring and supervision program included into the construction E&S management plan covering permanent and periodic oversight of construction activities designed to monitor the implementation of all management programs and impacts from construction activities.

Central Puerto has been commissioned Ventus (Enginnering Company) to conduct permanent oversight of construction activities and contractor’s performance. Ventus will provide EHS weekly basis report to Central Puerto that must include as a minimum: progress on implementation of all management programs; worked hours and accident rates (frequency and severity); summary of EHS non-compliances and deviations; proposed corrective actions and completeness of opened past action; project’s and contractor’s performance indicators; contractor’s performance ratings; and applicable contractual penalties, if any.  (ESAP Condition 4)

In order to monitor contractors’ consistent implementation of EHS considerations, the project will establish a committee with members from each of the EHS teams, led by Ventus, and with the participation of the Project Manager to ensure appropriate measures and resources are in place to meet EHS objectives during construction. The team will meet on a weekly basis to coordinate management of any work activities they may have in common, discuss findings from previous monitoring report period, implementation of corrective actions, actual performance indicators vis a vis pre-defined contractual targets (accidents, progress on implementation of  management programs, violations of OHS procedures, unconformities with environmental management plans, etc…), as well as sharing experiences applying GIIP aligned to the project management programs, host country legal requirements and IFC PS requirements. (ESAP action 5).

Finally, specific EHS performance indicators will be included in the score cards of the Project Manager, Environmental Manager and OHS Manager during construction, as part as their annual performance evaluation process. (ESAP action 6)

    Working Conditions and Management of Worker Relationship

Human Resources Policies and Procedures

Central Puerto’s human resource (HR) policy commitments are articulated in La Genoveva’s E&S management plan. These HR policy commitments include such aspects as:  promotion of safe and healthy working conditions as well as the promotion of workers health;  freedom of association; compliance with labor laws at federal, provincial and municipal levels;  non-discrimination in the workplace or in employment decisions, as well as fair and equal treatment and equal opportunities for all workers; fair notification of dismissal and severance payments; and prevention of the use of forced labor. The E&S management program also outlines its commitment to hire contractors that are legitimate companies of recognized integrity, who employ workers in a legitimate manner, and who have an Environmental and Social Management System that is compatible with the policies and procedures defined in the E&S management plan.

Additionally, Central Puerto has its own Code of Conduct which it applies to all of its subsidiary operations and which, according to the Project’s E&S management plan, must be disclosed and applied to direct workers as well as employees of and contractors and sub-contractors.

Working Conditions and Terms of Employment

Labor rights in Argentina are enshrined in the Constitution and consolidated labor laws (Ley # 201744/73, Ley de contrato de Trabajo), and labor relations are highly regulated under country’s laws and labor practices. Fundamental workers’ rights are granted in the constitution.

At the national level, terms of employment are regulated by National Law 20744/76 (Regimen Contrato de Trabajo) which defines the principles, types and conditions for all terms of employment and types of working contracts. Maximum allowed working hours are 8 hours a day and 48 per week. Overtime cannot exceed 30 hours per month and 200 hours per year. At least one day of rest is mandatory and minimum annual leave of 14 days are granted to all workers. Maternity leave of 90 days is mandatory and women has job stability during this period. Minimum age for regular jobs is 18. Child labor is forbidden and underage citizens (at least 16 years old) can apply for apprentice programs, with relevant restrictions (such as no night shifts, hazardous or exhaustive works). More restrictive working conditions for specific industries can be set under collective bargaining agreements.

Central Puerto’s HR policy commitments outlined in the E&S management program, include a reference to the use of documented employment contracts with clear and understandable information about workers’ rights in accordance with the national employment and labor legislation and applicable bargain agreements. It also indicates that contracts will define the hours of work, wages, overtime, compensation and benefits, as well as any substantial change. 

In order to help verify contractors’ implementation of the project’s labor requirements, Central Puerto will deploy means of access control to construction site and will restrict the access to the contractors that has filed all documents to fulfill all labor and EHS requirements described in the OHS standard requirements for contractors as well as in accordance with the E&S management program for construction. Central Puerto will also deploy working time verification method at the construction site to ensure adherence with working hours and overtime legal requirements for all workers (contractors and subcontractors). (ESAP condition 7)

Workers’ Organization

Freedom of association in Argentina is granted by constitution, by the Law 20744/76 (Regimen Contrato de Trabajo) and Law 23.551 (Ley de Asociaciones Sindicales de Trabajadores), and workers are free to affiliate to the union of their choice. Union’s representatives are granted with higher level of protection including labor and contract stability. All construction workers are affiliated to the construction workers’ union – UOCRA (Unión Obrera de la Construcción de la República Argentina).  As previously mentioned, the company recognizes in its HR policy workers’ rights to join and form unions.

Non-discrimination and Equal Opportunity

As already mentioned above, the E&S management program has specific statements promoting equal and fair treatment for all workers and no employment decisions must be made based on personal characteristics unrelated to the requirements of the job.

In Argentina, equal treatment is a guiding principle granted in the constitution and reaffirmed in labor laws.  The Law 20744/76 (Regimen Contrato de Trabajo) prevents discrimination at workplace for any reasons including gender, religion or origin. In addition, workers are also protected by the anti-discrimination law (Ley 23.592), which grants their right of equal opportunity at workplace. In cases of discrimination at workplace direct employees and contracted workers can call the Ministry of Labor to investigate the case and open an administrative trial if the case is confirmed.

Grievance Mechanism

The E&S management program also has specific actions regarding an internal grievance mechanism for all workers, including contractors and sub-contractors.

Going forward, Central Puerto will develop and implement a project-specific employee grievance mechanism.  This mechanism will define the channels for workers lodge the complaints, including the possibility of anonymous complaints, as well as a system to document, address and resolve the issues and provide feedback. The project monitoring report will include specific indicators of Internal grievance mechanism implementation, a summary of the complains, resolution and feedback (for non-anonymous complains). (ESAP condition 8)

Protecting the Work Force

Child labor and forced labor are strictly prohibited by Argentine labor laws. This is not a risk for the power sector given the strong regulatory framework protecting worker’s rights in the country and the skilled nature of the jobs required. As mentioned before, underage workers (16) are allowed under apprentice programs, but not in construction works.

The E&S management program also has specific provisions preventing the use of forced and child labor during construction phase as already mentioned above.

Occupational Health and Safety

The E&S management program has specific requirements regarding the workplace safety including such aspects as: risk identification, prevention and control; training; recording of illnesses and occupational incidents; and emergency preparedness and response, among others.

In addition, Central Puerto has defined a set of OHS standard requirements for contractors included into construction contracts with EPCs. This document covers a wide range of labor and safety practices including: accident insurance policy requirements; demonstration of social security payments; documentation of assigned OHS professional; prof of PPE supply for all workers; emergency plan; training program; OHS risk prevention plan; copy of professional accreditation when required;  safety requirements for trucks and vehicles; Requirements for the entry of mobile cranes, forklifts, hydraulic lifters, loaders, excavators, mechanical shovels, auto lifts, etc as well as specific requirements for machine operators; general and basic conditions of hygiene and safety on construction jobs; Personal Protection Equipment PPE; machines and tools; safety requirements for lifting cargo; permission for hazardous work; working at heights; scaffolders and ladders; electrical safety; welding; life and fire safety; use of grinders; gas cylinders; sand blasting work; lavatories and locker rooms and emergency response plan.

Central Puerto also has specific corporate standards that must apply for operational phase including: hazardous energies control (energy isolating, lock out and tag out; isolating verification; grounding; safe distance areas; removal of lock-out tag-out and re energization procedures); confined spaces; working at heights; cargo lifting, ladders and scaffolders; electrical circuits disconnect procedure; and safety requirements for contractors.

The electrical circuits are designed following National and international electrical engineering codes and all wind turbo generator will be equipped with individual overcurrent protection, lightening protection, proper grounding and Ground Fault Circuit Interrupter (GFCI). 

Going forward, Central Puerto will complete an electrical commissioning procedure for the connection of the wind turbines to the substation and finally to the grid. Central Puerto will also complete a standard requirement for electrical PPEs with clear guidance on the use of different levels of protection proportional to the electrical hazard/electrical arc hazard, maintenance requirements and periodic testing. (ESAP condition 9)

Workers Engaged by Third Parties

As mentioned before all subcontractors must follow the labor and EHS requirements defined into E&S construction plan as well as OHS requirements for contractors. Central Puerto will implement rigid controls to grant access to the site ensuring all worker’s rights are protected and in accordance with Argentinian law. Central Puerto will also implement thorough monitoring of working conditions as defined in its policies and procedures.

  Resource Efficiency

This project uses only clean and renewable sources of energy (wind) to generate electrical power and does not make use of any finite source of natural resource and, as such this is very resource efficient by default. The wind turbines are designed and placed in a way to make the best use of the wind resource and generate power in its the most efficient way.

Water

Water will be used at relatively minor levels during construction works and also for domestic and sanitary purposes on site. If using well water, the project will obtain permission from the land owner and a municipal permit for its extraction and use.

GHG Emissions

The project will not contribute to greenhouse gases (GHG’s), other than during construction works due to the burning of fossil fuels from the use of vehicles and heavy machinery. The project will contribute to the avoidance of approximately 220,000 metric tons of CO2 equivalent (eq) per annum from the electricity grid based on estimated production of 417 GWh/annum and Argentina’s average grid emissions of 527 kg CO2-eq per kWh.

Pollution Prevention

As defined in the relevant ESMPs, the project will take all necessary measures to provide clean and safe drinking and sanitary water to all workers. Sanitary and domestic effluents will be separated and treated using chlorination prior to disposal in wells or septic facilities approved by the local authorities. Regular physical-chemical and bacterial controls will be carried out to ensure water quality is deemed safe for the intended use, in accordance to local requirements.

Also as defined in relevant ESMPs, the project will implement precautionary measures to ensure that rain or groundwater does not become polluted by oils or lubricants used at the construction site, ensuring these are properly stored, contained and separated in dedicated areas.  The project will implement a spill containment program with its employees to ensure that there is no ground contamination from spills of contaminating substances. Hazardous materials will be stored in containments with 120% of total net capacity.

Noise and air quality levels will be monitored in accordance to local laws and must demonstrate compliance with the EHS Guidelines during construction works.

Central Puerto has conducted preliminary analysis of operational noise emissions from combined projects La Genoveva I and II, and emissions model is showing predicted noise levels above 35 dB(A) at the closest receptor (single farm house). Going forward Central Puerto will conduct background noise monitoring at the closest receptors, and in accordance with IFC EHS guidelines background noise monitoring requirements for wind power projects. Central Puerto must then update noise emissions models including the results from background noise data and adopt appropriate mitigation measures if receptors are exposed to noise levels above 45 dbA (night) or 55dBA (day).  

Central Puerto has conducted shadow flicker analysis from La Genoveva I and II and shadow exposure to the closest neighbors won’t exceed 33hs per year in the worst-case scenario, affecting the nearest residential structure consisting of [a farmhouse?] about [x km] from the project.

Measures to control air pollution due to temporary sources in the construction phase include minimizing the generation of (i) suspended solids accumulated from excessive dust generation both at the construction site during clearing, digging and additionally from transport activities; and (ii) emissions from the use of heavy vehicles and machinery. Vehicles and machinery will receive periodic maintenance to avoid the excessive emission of pollutants.

Wastewater Treatment

As defined in the relevant ESMPs, wastewater will be generated at nominal levels during construction mainly from showers and toilet. Chemical portable toilets will be available for workers provided with a storage tanks. Wastes will be collected periodically and transported in special tank trucks. Sanitary wastewater will be disposed at authorized sanitary treatment facilities and the toilet provider company must provide a copy of disposal receipt.

Liquid effluents resulting from construction activities (concrete remnants and mixer truck wash) will be collected and delivered for external disposal. The effluents must be monitored before disposal, or treated to meet approved levels for alternative uses (garden irrigation, water re-use) .

The washing of tools and construction equipment, as far as possible, must be carried out outside the construction site, in authorized places.

Solid Waste Management

According to the solid and hazardous wastes program from the E&S Management plan there must be sufficient containers at the worksite for the transitory disposal of the waste. The ESMP includes such aspects as on-site waste segregation and classification and contracting of authorized entities for removal, transport and final treatment and disposal in accordance to legal requirements.

Hazardous Materials

The construction activities may generate limited amount of hazardous wastes such as contaminated material with oil, greases, solvents or ink/paint; printer’s tonners/cartridges; batteries; fluorescent lamps; used chemical containers; used oil, lubricants, fluids and ink wastes.  As outlined in the waste management plans, hazardous wastes will be managed by duly qualified companies according to chain of custody procedures to verify the final form of treatment and/or disposal. 

  Community Health and Safety

The project is located in a rural area accessible by public road to the city and port of Bahia Blanca but removed from any human settlements (4 km from Cabildo town, the nearest residential settlement). The main impact of the project to the public will come from disruptions to local transit and traffic during the transportation of turbines, heavy machinery, workers and other materials via state roads during project the temporary construction period. The project is responsible for implementing a traffic management plan that identifies safe transport routes to the project, identifies high risk areas requiring specific improvements or extra safety precautions, installs safety signage on public roads, enforces codes of conduct to all drivers, with special instructions provided to those transporting large and heavy loads. Turbines will be transported to the site during late night hours to avoid blocking off traffic on state roads during daytime and peak hours.

The project is responsible for maintaining direct contact and active coordination with public utilities in Bahia Blanca during any construction works that may result in the interruption of services. The project is far enough away from human settlements that it is not expected to have a visual impact, or other significant impacts like shadow flicker, blade throw and/or impacts associated with high noise levels. 

Infrastructure and Equipment Design and Safety

Central Puerto will follow strict construction standards provided by wind turbine manufacturer’s, including technical guidance for civil construction and required specifications for foundations (tower’s base), electrical circuits and connections, lightening protection and tower’s turbines communication with central of operational data monitoring. All electrical connections from the towers to the substation will be buried. Substation design must meet utility transmission company safety specifications. 

Emergency Preparedness and Response

The transport management plan will include specific emergency preparedness and response measures to be implemented with assistance from local authorities in the event of an emergency. In the event of an accident, the project will take all measures to ensure that impacts to the public are mitigated and managed accordingly. The client will submit the contractor’s traffic management plan to IFC for review; the plan will identify how the safety and security of all those potentially affected during the transportation of project equipment and machinery in public areas will be ensured (ESAP Condition 10).

Security Personnel

The project will contract the services of a private security company during both construction and operations that will take care of access control and asset protection. Security personnel will be unarmed. There are no communities surrounding the project site and security risks in the area are assessed to be low. The client will require the security contractor to screen its staff so as to avoid anyone implicated in past human rights abuses and will ensure that security personnel are instructed on how to interact respectfully with workers and members of the community.

   The wind project is sited on an area covering roughly 3008 ha at an inland location with mostly flat topography, entirely below 100 meters elevation above sea level.  It is located in the southern portion of the Province of Buenos Aires, approximately 30 km northeast of the city of Bahía Blanca, along, and on the north side of the provincial route 51 highway.  The project is located entirely within the Pampas grassland biome, toward its southern limit.  The “Pampas” refers to a grassland biome within central Argentina and Uruguay, characterized by relatively flat topography and treeless terrain. Similar to other subtropical-temperate grassland biomes, plant communities of the Pampas are dominated by a variety of perennial bunchgrasses and forbs, and both plant and animal communities are characterized by low diversity, but contain several highly specialized, endemic species.  This biome covers much of the Province of Buenos Aires and has been heavily impacted by domestic livestock grazing as well as crop agriculture.  The entire wind project site is located on an active cattle ranch, and is heavily dominated by remnant pampas grassland habitat.  The condition of the grassland habitat varies substantially, with some areas showing signs of heavy cattle grazing pressure, such as very low, sod-like grass cover or bare dirt, and other areas showing signs of less intense grazing pressure, with taller and denser coverage of perennial grasses and forbs.  Relatively small portions of the area have been plowed and planted to a grass cover crop.  Very small portions of the project area are occupied by buildings/yards/gardens, and there is a small lake in the northeastern portion of the project area.  The area is essentially treeless, containing only several small stands of planted exotic trees, and no native woodland or shrubland areas.  A bird and bat baseline study (spanning a continuous year of data gathering from June 2018 through May 2019) is being conducted by qualified and experienced locally-based consultants using IFC-vetted methodologies designed to render a comprehensive characterization of potential risk birds and bats, given the species potentially occurring at the site. Methods include point count surveys, vantage point surveys and bat acoustic surveys (ultrasound).

The project area does not overlap any protected areas or Key Biodiversity Areas (KBA).  The closest such area is the Important Bird Area (IBA, or “AICA”) numbered BA-17 and named “Villa Iris, Chasicó, Napostá” by Aves Argentinas, the national IBA authority, located roughly 32 km to the west of the project site, at its closest point.

Although the natural Pampas grassland habitat contained within the project site is heavily impacted by cattle grazing activity, the site does contain significant biodiversity values. The site is classified as Critical Habitat (CH), due to its importance for a restricted-range species, the Pampas Meadowlark (“Loica Pampeana,” Leistes or Sturnella defillippii), which triggers CH criterion #2 under IFC PS6.  This species is classified as Vulnerable by IUCN and as Endangered (En peligro de extinción) nationally, primarily as a result of drastic population declines and geographic range reduction over the past century, believed to have resulted from extensive loss, fragmentation, and degradation of the Pampas grassland habitat on which it is highly specialized.  Once distributed across a large portion of Uruguay, and the Argentine provinces of Buenos Aires, Santa Fe, Córdoba, Entre Rios, and La Pampa, this species is now believed to be restricted to small, remnant populations in Uruguay, and the southern portion of the province of Buenos Aires.  Potential impacts to the Pampas Meadowlark as a result of project construction and operation include both direct (e.g. bird collisions with project infrastructure) and indirect effects (e.g. displacement, or the abandonment of the area by the species subsequent to project construction).  The susceptibility of this species to these effects is currently unknown.  The presence of CH at the project site triggers several IFC policy requirements under PS 6 that have been incorporated into the project’s ESAP, including demonstration of “net gain” of biodiversity values through mitigation, and the preparation of a Biodiversity Action Plan (BAP), including associated biodiversity monitoring, mitigation, and adaptive management components.

The small lake in the northeastern portion of the project site is likely to host concentrations of waterfowl and other water-affiliated bird species throughout the year, including the Chilean Flamingo (Phoenicopterus chilensis, IUCN Near Threatened, nationally Vulnerable), the three species of geese in the genus, Chloephaga, commonly referred to as “Cauquenes” (listed individually below), and a wide variety of other species that are not classified as protected either internationally or nationally.  The potential for the project to adversely affect such species has been largely mitigated through turbine micrositing, as no turbines will be installed within 500 m of the lake, reflecting a change from the original design, made by the developer at the request of IFC in response to bird-related concerns raised during early discussions.

Powerline impacts on flying wildlife are expected to be minimal or negligible, as the project has been designed with a buried low/medium voltage power-collection system to bring power from the turbines to the project’s substation, effectively eliminating the potential for the project to cause bird electrocutions, and as the project’s high-voltage interconnection to the grid will take advantage of existing transmission lines that run adjacent to the project site along the southern boundary.

In addition to the Pampas Meadowlark, the upland habitats of the site support a variety of bird, bat, and other wildlife species typical of the region that may be impacted by the project.  Additional sensitive species that have the potential to occur in the upland habitats at the site include the Greater Rhea (Rhea americana, IUCN Near Threatened, nationally Vulnerable), the Ruddy-headed Goose (Chloephaga rubidiceps, IUCN Least Concern, nationally Endangered and protected by law), the Ashy-headed Goose (Chloephaga poliocephala, IUCN Least Concern, nationally Threatened and protected by law), the Upland Goose (Chloephaga picta, IUCN Least Concern, nationally not threatened but protected by law), the Long-winged Harrier (Circus buffoni, IUCN Least Concern, nationally Threatened), the Swainson’s Hawk (Buteo swainsonii, IUCN Least Concern, nationally not threatened, but protected by national law), the Upland Sandpiper (Bartramia longicauda, IUCN Least Concern, nationally Vulnerable), the Burrowing Parakeet (Cyanoliseus patagonus, IUCN Least Concern, nationally Threatened), the Bearded Tachuri (Polystictus pectoralis IUCN Near Threatened, nationally Vulnerable), and the Rusty-backed Monjita (Xolmis rubetra, IUCN Least Concern, nationally Vulnerable).  Potential impacts to these, and other bird and bat species include collisions of highly aerial species with turbine rotors, towers, or power lines, and permanent or temporary displacement effects.  The specific likelihood and intensity of such effects is difficult to predict with certainty, due to a lack of information regarding the specific susceptibility of Argentine birds and bats to wind turbine collision impacts.  Operations-phase monitoring and adaptive management requirements have also been included within the ESAP, intended to address potential impacts to sensitive species, as well as overall collision impacts to birds and bats, in the face of this uncertainty.

  The project has an External Communications Program including a set of actions to articulate the project with the local social environment, aiming to minimize eventual conflicts that may arise resulting from construction activities. The Environmental and Social Management Plan must be communicated to the different municipal, provincial or national administrations, that can be affected by construction works.

The communication program includes:

- A sign to be placed in front of construction site indicating: name of the project, Central Puerto’s Name, Construction Company; with addresses and telephone for contact.

- A formal and documented communication procedure, which facilitates communication with society and offering channels for stakeholder’s lounge complains, opinions, suggestions related to the project development.

- Conduct consultations with directly affected parties (rural neighbors, local communities, among others

- Stablish a channel of communication with authorities, rural neighbors, tenants or representative of civil society

- communicate in advance with potential affected parties and relevant authorities when any activity can significantly affect any stakeholder and create conflict 

- monthly reporting to the local, provincial and national authorities of the progress of the work and what is scheduled for the following month

As described above in PS1 (Monitoring) section, Central Puerto must monitor the external complaints until its resolution and feedback.

Going forward, Central Puerto must develop and implement the communication (grievance) procedure as described in the E&S management plan and in accordance with IFC PS1 requirements, as well as conduct meetings with local affected communities to disclose details of the project, expected impacts and appropriate mitigation or compensatory measures. (ESAP Condition 11)