Based on IFC’s review of the project PS7: Indigenous People is not applicable as there are no indigenous peoples in the project area; and PS8: Cultural Heritage is not applicable as the project is not located in the area of known historical or cultural significance and does not impact any known cultural heritage. However, the project will develop a chance finds procedure in case of the identification of cultural/archeological resources in the area.                                              

 This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability as the E&S impacts associated with the project are limited, generally project-specific and can be addressed through the implementation of good international industry practices.  Further, it is possible to design and implement engineering and management measures to mitigate adverse impacts during construction and operation. The environmental and social risks are rated as moderate (as per IBRD classification) and for those that have been identified, the client’s E&S management system and the agreed E&S Action Plan (ESAP) provides appropriate mitigation.                                              

  Environmental and Social Policy and Management System

At a corporate level, the company has developed a QHSE Policy which outlines their commitment to quality, the prevention of injury, ill-health, limiting pollution of the environment and to complying with applicable statutory and regulatory requirements at all times. At a project level, the company, as a part of their ESHS management systems, will develop a project level ESHS policy building upon their corporate level policy, defining their ESHS objectives and principles aligned with applicable laws and regulations and consistent with the objectives of the IFC Performance Standards (IFC PSs). This policy will indicate who within the company will be responsible for its implementation. The company will communicate the policy to all project employees and will require their contractors to develop their own ESHS policy aligned to this policy.

At a corporate level, the company has developed a QHSE Management System (MS), detailed within a QHSE MS Manual, which is aligned with the general requirements of ISO14001, ISO 9001 and ISO 45001. The company is yet to establish mechanisms to align project level and corporate level management systems.

As per ESAP 2, the company will develop and implement an Environmental and Social Management System (ESMS) in accordance with the general requirements of PS1 and in line with the objectives of ISO14001 (certification is not required) specific for this project.  The company’s ESMS will detail processes to be implemented to provide adequate management & supervision of their contractors including the engagement of a Project Management Consultant (PMC).

The ESMS will outline process developed by the company to identify environmental and social risks and impacts and detail the specific measures to be implemented to manage these.  Company will require its EPC and O&M contractors to develop an ESMS needed to identify, manage and control risks related to their activities and that of their sub-contractors.

Identification of Risks & Impacts

During the inception phase of the project i.e. Scaling Solar advisory Project, IFC commissioned a ‘Site Suitability Report’ and an ‘Environmental and Social Scoping Report’ with the aim to provide project bidders with a basic understanding of environmental and social conditions in the project area and ensure the general suitability of the site.

Following project award, the company developed a preliminary Environmental & Social Impact Assessment (ESIA) report in accordance with good international practice. The purpose of the preliminary ESIA was to conduct an initial assessment of impacts based on existing information, supplemented with additional surveys. The preliminary ESIA also identifies the type and extent of further studies required. As per ESAP 1, a full ESIA will be further developed, prior to construction and as a condition of disbursement, following the same structure but will also include an assessment of residual impacts. Further site surveys will be carried out when circumstances allow as part of the full ESIA. The full ESIA, mitigation protocols and Environmental & Social Management & Monitoring Plan’ (ESMMP) will be prepared following the completion of additional studies.

In addition to the above, the project is required to develop an EIA in accordance with national legislation and seek regulatory approval prior to commencement of construction activities.

The company has engaged a local consultancy to assist in the development of the national level EIA documents. To date a Stage I – Concept Statement of Environmental Impact has been completed in accordance with local requirements which has been submitted to the regulators.

Management Programs

As mentioned above, the project’s ESIA will include the development of an ESMMP, which will provide a summary of the E&S management framework, monitoring requirements and mitigation measures applicable to the construction and operation phases of the project.  As per ESAP 3 and ESAP 4, the company will develop a Construction Environmental and Social Management Plan (CESMP) and an Operation Environmental and Social Management Plan (OESMP).   The CESMP and the OESMP will be based upon the ESMMP and will be reviewed and approved by the Project Lenders prior to use. 

The CESMP will consist of a suite of sub-plans, which will include but not be limited to: waste management; pollution prevention (including emissions, erosion, spill response etc.); water management (including supply, treatment, disposal etc.); hazardous materials; biodiversity management (including fauna / flora, topsoil, ground disturbance, invasive species etc.); emergency preparedness & response; community health, safety & security; road safety & traffic  management;  accommodation management; local recruitment & labor management; influx management;  cultural heritage (including chance finds); environmental monitoring plan; stakeholder engagement (including grievance management) and contractor management plan.

The OESMP will consist of a suite of sub-plans, which will include but not be limited to: waste management; pollution prevention (including emissions, erosion, spill response etc.); water management; hazardous materials; emergency preparedness & response; community health, safety & security; biodiversity management; environmental monitoring plan and stakeholder engagement (including grievance management). 

The company shall require their contractors to develop, implement and maintain their own ESMPs and associated procedures aligned with project requirements and their scope of work.  These documents will be reviewed and approved by the LTA and / or Project Lenders prior to use.

Construction and operations phase E&S management and monitoring responsibilities will be shared between the company and its contractors. Both the EPC and O&M contractors will be contractually bound to adhere to the requirements to which they are assigned as the responsible party in the ESMPs. 

As per ESAP 5, the company will develop, and shall require their EPC & O&M contractors to develop, an OHS Management System aligned (but not necessarily accredited) with OHSAS18001 / ISO 45001 and elements of an ESMS to identify, assess, manage and control risks.

As part of the OHS Management system, the company will develop an over-arching Project OHS Management Plan (ESAP 6) outlining the project’s health & safety management framework and setting OHS minimum project requirements / standards, taking into the consideration potential COVID-19 related infection risk to the work force.

The company will require its EPC & O&M contractors to develop a series of plans, procedures and systems to adequately manage occupational health & safety risks associated with their scopes of work.  The contractors shall establish a comprehensive risk identification and management process & permit to work system. 

The EPC and O&M Contract is a key tool for ensuring compliance with the ESHS requirements of the company. As per ESAP 7, the company will develop and include ESHS and labor provisions (including complying with IFC PS) and compliance conditions in its EPC and O&M contracts which will provide contractors and third part service providers (including security agencies) with clear guidelines on performance requirements.

 Organizational Capacity & Competency

The company has at a corporate level a QHSE and CSR Manager which will have oversight of EHS issues on the Project. The company has demonstrated capabilities to manage a range of environmental, social and occupational health and safety issues at other renewable energy projects in which the IFC has provided funding.

The company’s project manager shall have overall responsibility for environmental, health, safety, social & security management for the project. The company will develop a project level board which will include ESHS representation and ESHS reporting requirements. The project board will provide a means for ESHS aspects to be raised and escalated as appropriate to senior management. A mechanism to link the project level board and the corporate level board should also be established.

The company will appoint qualified professionals to be responsible for the environment, health and safety and social aspects of the project. The company will engage a PMC to provide additional support and project supervision including ESHS oversight.

As per ESAP 8, the company will appoint, at a site level, a suitably qualified stakeholder liaison manager, and through the PMC, suitably qualified project E&S and OHS manager as well as human resource management support.  At a corporate level, the client will appoint qualified E&S and OHS representative to be the lenders focal point throughout the duration of the construction & operational phases of the project.

The appointed individuals will have adequate qualifications & experience including the knowledge of international requirements & best practice. These individuals must have sufficient authority and resources to fulfil their responsibilities as required by the Project ESMS and the SEP, Lender requirements, the ESAP and local regulation. 

As per ESAP 9, the company will require their PMC, EPC and O&M Contractors (including their sub-contractors) to appoint a suitably qualified environmental, labor and OHS team to manage their scope of work.  These individuals must be aware of, and fully understand, the obligations and responsibilities placed upon them by the Project ESMS. 

Emergency Preparedness & Response

The Company and their contractors will develop an Emergency Preparedness and Response Plan (EPRP) in accordance with IFC PS1 & PS4.

These plans will cover preparedness and responses to a range of potential emergency scenarios, including but not limited to medical emergencies (including pandemic type outbreaks), fire, earthquakes, extreme weather conditions, transport incidents & major hydrocarbon spills. Security related incidents, act of sabotage/vandalism, terrorism etc. will be addressed with a separate Security Management Plan (ESAP 21).

The response plans will include a communication protocol to alert local authorities and communities as appropriate and the management team in addition to specific responses and evacuation procedures.

Regular drills and emergency exercises will be conducted by the EPC & O&M Contractor covering the different emergency scenarios.

Monitoring & Review

The company will be responsible for reviewing and formally auditing their contractors with regards to their ESHS performance and compliance against project standards, national requirements and Lender guidelines.

As part of its management system, the company will establish procedures and allocate resources to monitor and measure the effectiveness of their and their contractor’s management plans / programs and compliance with relevant Uzbek legal requirements.

E&S / OHS monitoring requirements of the EPC & O&M contractors for their own activities and that of their subcontractors will be defined within their management plans and their implementation will be closely followed by the company.

The EPC and O&M contractors will provide as a minimum, monthly E&S / OHS reports as part of the general reporting on the project.  This report will include coverage of the contractor’s E&S / OHS performance in accordance with reporting requirements outlined within the project ESIA & ESMPs.  Clear key performance indicators (KPIs) will be developed as part of the reporting. 

The company will appoint an independent auditor to undertake review of the effectiveness of CESMP and OESMP quarterly during construction phase, and annually in the first three years of power plant operation as noted in the ESAP item 10.                                               

 The project is expected to employ approximately 140 workers at the construction start, 900 workers during peak construction and up to 117 workers at the end of construction; during operation, there is expected to be 22 workers in site working in shifts. The EPC site management team is expected to be around 30 individuals across the construction period.

The number and gender of local & national workers that are predicted to be employed is yet to be fully established by the company although it is likely that approximately 400 technicians and low-skilled personnel will be required.  Potentially these workers could be sourced either locally or nationally dependent on skill sets available.

Human Resources Policies and Procedures

At a corporate level the company has an existing Code of Conduct (Mubadala Code of Conduct) which sets principles related to core company values and ethics. These principles will be implemented throughout project execution. 

The company will develop a Human Resources (HR) Policy and plans / procedures that are project specific and in line with IFC’s PS2, International Labor Organization (ILO) and with national labor laws. The HR Policy will contain an enforceable code of conduct applicable to all workers. As per ESAP Action Item 11, the HR policy must include commitments to (i) Non-discrimination, equal rights and equal pay; (ii) Prevention of child labor and forced labor; (iii) Freedom of association and right to collective bargaining; (iv) Terms of employment including hours of work, overtime arrangements and overtime Compensation, rights to refuse overtime requests; (v) Commitment to apply zero tolerance for any proven case of gender based sexual or physical violence and workplace harassment.

This policy will be provided to all employees in their language(s). Induction training on the HR policy will be provided to all newly hired workers.

The company will develop an additional Code of Conduct for site security personnel which will be in line with the requirements of PS2, PS4 and the Voluntary Principles of Security & Human Rights.  Further detail concerning security is provided within the section covering PS4.

As described within PS1, the company will develop and implement a contractor management plan which will outline mechanisms to monitor and enforce contractors’, sub-contractors’ and service providers (including private security agencies) compliance with labor policy & human resource requirements.

Non-Discrimination & Equal Opportunity

The company is committed to avoid all forms of discrimination against its employees, based on the age, gender, sexual orientation, health, race, nationality, political opinions or religious beliefs of its counterparties. The requirements of non-discrimination and equal opportunities will be extended to all contractors and subcontractors as part of contractual obligations.  

 Recruitment

As per ESAP 12, the company will supplement existing, publicly available, local workforce statistical data, by undertaking further stakeholder engagement to determine likely local & regional workforce availability, gender & skill levels to guide workforce planning.

As a consequence of local restrictions on face to face meetings, due to the current COVID-19 pandemic, it will not be possible to undertake a detailed, house by house social survey to determine likely local and regional workforce availability and skill levels.  The company will engage with local communities leaders (including, but not limited to the Deputy Khokim of Navoi region, Deputy Head of Investment Department of Navoi Region Khokimiyat, a senior member of the local Women's Committee, and the Chairman of the mahalla committee Malik {Uzumzor is part of the Mahalla Malik}) to  establish an adequate workforce profile. The company will discuss the skills required and will provide draft job specifications during the engagement. All necessary measures to appropriately manage community expectations will be taken. 

The engagement detailed above will assist the client to prepare a Local Recruitment & Employment Plan (LEP) which outlines their recruitment strategy and processes, including promotion of equal opportunities. The LEP will describe how women and Project Affected People (PAPs) will be preferentially selected, alongside other residents from the two most affected communities, for recruitment and training in advance of the start of construction activities. This LEP should include an analysis of local workforce skills against required worker profiles and numbers, engagement with regional vocational training centers that could be used (potentially with the support and technical assistance of the project) to provide vocational training, and employment targets for women. The company will commit to maximizing the inclusion of women in the workforce as much as reasonably practicable and will investigate different options, such as working with local NGOs etc. to assist in achieving this aim.  Roles and responsibilities associated with local recruitment between the company and their appointed contractor(s) should be clearly defined.

The project’s recruitment strategy will include a tiered approach in which recruitment campaigns will focus on recruiting suitably skilled employees / sub contactors from within project affected communities as a priority. Should suitable individuals not be available within this area, the recruitment campaign will expand to the local region and subsequently other regions of Uzbekistan should suitable employees / sub contactors not be available.    The employment of international workers will be seen as the last option.

The company will ensure that their contractors develop LEPs aligned with the requirements outlined within their LEP. 

Working Conditions and Terms of Employment

As per ESAP 13, the company will ensure that all employee contracts are consistent with local labor codes, ILO and IFC PS2 requirements.

All employees shall be provided a copy of their contracts (in a language they understand) and these shall stipulate the terms of employment, such as working conditions (including health & safety requirements) wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity and paternity leave, vacation and holiday etc.

All construction phase worker contracts shall clearly describe the short-term nature of the project and provide an indication of likely employment duration. 

The company will ensure that their contractors provide all workers, including sub-contractor workers, with written documentation concerning the terms and conditions of their employment as per the above. This requirement will extend to any personal engaged via labor hire companies.

The company will ensure all workers have contracts and background checks including references from most recent employers.

Workers Grievance Mechanism

As per ESAP 14, the company will develop a confidential grievance reporting, referral and support system for workers. This worker’s grievance mechanism (WGM) shall be consistent with local labor codes and IFC PS2 requirements.

The WGM process shall involve an appropriate level of management (including designated staff and accountability, and the establishment of an appeals panel) to address concerns promptly and an understandable and transparent process that provides timely feedback to those concerned, without any retribution. The WGM is to include specific considerations related to the harassment/gender-based violence grievances.

The company will provide specific training to grievance officers and general awareness to employees on harassment and bullying, engagement with women employees on their concerns regarding transportation and safety.

The company will ensure their WGM is available to their contractors, sub-contractors and service provider’s etc. personal as required. The PMC will be given responsibility for the operation and management of the WGM during the construction phase of the project.  It is anticipated that the PMC will identify a named individual who will take the lead, but this individual will be supported by a panel who will consider any appeals.  Final arbitration will sit with the Company’s Project Management.  During operations, the O&M contractor will establish and operate a WGM aligned with company’s WGM (including necessary training and awareness programs).

The existence and availability of the WGM shall be clearly communicated to all employees via. their employment contracts, HR plans and through the site induction process.

Workers Accommodation

The company is yet to decide the accommodation arrangements for project workers, with two options currently being considered: (i) Development of a workers camp potentially located adjacent to the project area; or (ii) Accommodated in nearby hotels and / or guesthouses.  

The ESIA currently under development will include an assessment of likely risks & impacts associated with worker accommodation and will propose necessary mitigation measures.

As per ESAP 15, the company and the EPC contractor will prepare an Accommodation Management Plan in line with “Worker’s accommodation: Process and Standards” Guidance note by IFC and EBRD.  The management plan will incorporate social risks & impacts posed to nearby communities by project workers, including required mitigation measures.

Consideration of the need for workers’ accommodation must take account of the COVID-19 pandemic and the potential impact of the construction workforce on the local communities. The company & contractors management plans must assess the health risks to the workforce and put appropriate measures in place to protect the workforce and the local communities.

Safety audits shall be conducted to identify settings affected by the project that might increase the risk of GBVH. For example, consideration whether adequate measures have been put in place to manage interaction points with communities such as truck stops.

Every effort shall be taken to provide safe, secure and separate living spaces for male and female construction workers, including adequate lighting and segregated wash facilities

Workers Organizations

It is unlikely that workers’ unions will be involved in the project as the main concentration of workers will be on site during a short-lived construction period only; as noted above, the operations staff will be small. The company will not in any way prevent workers from seeking to join unions or other workers’ organizations; this will be specified in the labor policy and procedures.

Child and Forced Labor

No child or forced labor will be used by the project at any time. Proof of identification and age will be required at the time of employment. The company will ensure appropriate contractual provisions are included with their contractors / suppliers to ensure this requirement is cascaded throughout the project.

Workers Occupational Health & 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, traffic accidents, exposure to electric shocks and burns, and safety issues related to PV module assembly.

As mentioned under PS1, the company will develop and shall require their EPC & O&M contractors to develop, an OHS MS aligned with OHSAS18001 / ISO 45001. The OHS MS will include project specific OHS plans / procedures for the construction and operations phases.  These procedures will cover, but not be limited to, the following issues: hazard identification and assessment; the construction site safety (barricades, safety nets, control of the access, clear demarcation of areas and provision of safety information to visitors, etc.); specific procedures for hazardous works; worker’s safety and training plan; personnel qualification, limitations and equipment needs (e.g. personal protective equipment); site supervision and audit procedures; incident reporting system and intervention measures (first aid etc.).  The procedure will be designed to be specific to the PV solar sector (in terms of industry-specific hazards) and the project site. The OHS procedure will also link into the project-specific Emergency Preparedness and Response Procedures (EPRP) which will include fire risk assessment and control systems, fire alarm systems and drills, emergency preparedness and planning, as part of OHS Procedures for both the construction and operation phases.   

The company in coordination with its contractors, will develop and implement a training program for the project. As per ESAP 16, the EPC & O&M contractors shall develop and implement an ‘Training Needs Analysis’ and ‘Training & Competency Plan’ to ensure that all workers are appropriately trained, skilled, licensed / permitted & competent to undertake all tasks required of them within their role.

Supply Chain

As per ESAP 17, the company will develop a ‘E&S Supplier & Vendor Management Plan’ which outline processes to be implemented to identify, manage, and monitor environmental, social, health & safety, risks and track performance of project key suppliers and vendors.

The process will include initial screening & due diligence exercises of key potential suppliers & vendors with a focus on OHS performance, licensing / permitting, human resource risks (child labor and forced labor) and an assessment of gender and safety risks in bidding process for contractors.

 Resource Efficiency – Greenhouse Gases

Greenhouse gas emissions from the project during the construction are expected to be predominantly associated with the use of fuels such as in generators, transport, on-site equipment, and machinery. Although the quantities of emissions have not been calculated, these are expected to be low and significantly less than 25,000 tones CO2 equivalent (tCO2eq/year). 

The project is expected to generate approximately 270 gigawatt hours (GWh) of electricity per year, resulting in a predicated annual GHG reduction of 142,000 tCO2eq/year. 

Resource Efficiency – Water Consumption & Availability

The company is yet to fully quantify water consumption requirements for the project.

Water required for construction has been estimated as 3,600m3 excluding accommodation requirements and 10,658m3 including accommodation requirements. The main water requirement during construction is likely to be water for dust suppression, concrete production and domestic use. It is yet to be determined whether concrete batching activities will be conducted on site or in Navoi, although initial calculations have assumed 0.2 m3 of water for every 1 m3 of concrete will be required. Construction phase water consumption requirements will be accurately quantified by the company when a decision is made concerning concrete batching arrangements & worker accommodation requirements. 

Water requirements during operation and maintenance will be largely focused on panel cleaning. The company has stated that due to high levels of ambient dust the project design has considered wet cleaning of the PV modules as their base case.  The company has estimated that this requirement would be approximately 4,620 m3 per annum. The company will consider the contextual risk of water scarcity in the region as a guiding principle for selecting a water efficient cleaning technology option.  The company will refine the cleaning regime during operations to avoid unnecessary cleaning and use of water.

The company is currently assessing different water supply options available to the project including groundwater abstraction, tapping into an existing water pipeline in close proximity to the project and trucking in water from Samarkand.  It was noted during stakeholder engagement sessions held with local communities that water scarcity / availability is a primary concern of the local population.  The company stated during the project virtual appraisal exercise that it is mostly likely that water will be sourced from Samarkand and trucked to site.  If this is to occur, it is estimated that the water demand would be equivalent to one truck per every two days.

As per ESAP 18,  the company will conduct an Alternatives Analysis for water use taking into account environmental, social and technical considerations and subsequently develop a Water Management Plan which will quantify water requirements for the construction (including non-potable water to be used for mixing concrete and dust control) and operational phases of the project and assess potential impact on availability of water resources to local communities (including farmers & herders). 

If ground water is planned to be used, the company shall first undertake a hydrological study to determine the availability and suitability of groundwater for construction water and for panel washing during operation. Groundwater shall not be used for potable water unless subject to appropriate treatment.

The company will obtain all required permits / licenses / permissions related to water abstraction, consumption and treatment etc.

Pollution Prevention – Waste

The overall volumes of both solid and hazardous waste generated by the project during both construction and operation are expected to be low.  The company is yet to develop a comprehensive estimation of their anticipated waste streams & volumes for the project or undertake an evaluation of waste treatment & disposal options.

It is anticipated that the project will produce both non-hazardous wastes, such as paper, wood, plastic, scrap metals and glass and a limited quantity of potentially hazardous materials such as transformer oils, paints, batteries, etc. and other electronic waste.

As per ESAP 18, the company and its contractors will develop a Waste Management Plan for the project aligned with local legal requirements, IFC PS3 and WBG EHS general guidelines. The waste management plan will commit to the reduction of wastes to the extent possible whilst maximizing the re-use and recycling of materials and will outline process for appropriate waste storage, segregation, transportation and disposal / treatment.

The company will develop a waste inventory and will undertake an assessment of disposal & treatment facilities / options.  Project waste will only be disposed of and treated at appropriately licensed facilities.  The company will adhere to Principles of “duty-of-care” in waste management.

An assessment of the suitability of each licensed disposal facility will be undertaken prior to use to ensure project waste is disposed / treated in such a manner that is safe for human health and the environment.

Pollution Prevention – Hazardous Materials

Hazardous materials likely to be required during construction & operation phase of the project include hydrocarbons, oils, lubricants and paints. The company and its contractors will establish and implement a hazardous material management plan and spill prevention and repose plan that are commensurate with the potential risk present. These management plans will address the protection of workforce and the prevention and control of the releases and accidents.

A limited number of waste PV modules are expected to require disposal during the construction phase, and they will be returned to the PV manufacturer for recycling.

Pollution Prevention

During construction, a minor and insignificant amount of pollution to air, noise, water and soil is anticipated that can be easily mitigated through standard pollution prevention and control measures which will be outlined in the respective environmental management plans. During the operational phase, no environmental pollution impacts are anticipated with the exception of wastewater, primarily from panel cleaning, and regular household waste generation. The company will require its EPC contractor / O&M operator to implement pollution prevention measures in accordance with national law, IFC’s Performance Standards, the ESIA prepared for the project, and the ESAP for the project agreed between the company and the IFC.                                               

 Before the start of construction, the company will assess risks and impacts to host communities of the project, such as the influx of workers. Based on the findings, the company and its contractors will develop a series of Community Health and Safety plans and procedures to protect public health, safety and security on issues that include: road safety and traffic management; potential emergencies and required responses; security measures to prevent unauthorized access during construction; measures to prevent sexual harassment, gender-based violence, and the sexual exploitation of children; and measures to prevent the spread of disease including COVID-19 and HIV/AIDS.

As per ESAP 20, the company will inform local stakeholders about the construction program and any potential associated hazards including expected increases in traffic around the site.  The company must actively consult with local stakeholders and authorities regarding the numbers of workers that will be on site during the construction period, the potential for employment, worker accommodation, and worker welfare and health. The company must also listen and respond to any concerns raised by local stakeholders or authorities relating to COVID-19 and the potential impact on the health of the local community and the capacity of local medical services. 

As described under PS 2, the company will maintain a ’Code of Conduct for employees’, that will be applicable to all employees, contractors and subcontractors. It will include references to non-discrimination, sexual harassment and gender-based violence, and rules for interaction with the local population.

Road Safety & Traffic Management

The project is yet to fully quantify required traffic movements for the project.  This information will be contained with the ESIA being developed.

The company has indicated that it is likely that solar panels required by the project will be transported by rail to the nearest rail head and trucked approximately 30 km to site.

As described within PS1, the company / contractor will develop and implement a project specific Road Safety & Traffic Management Plan (RSTMP) which will outline traffic management and accident prevention measures, including needed infrastructure, signage, training, to mitigate any impact on local communities. The RSTMP will define road transport routes to be used by the project, including routes to be used during equipment deliveries.  The transport routes will be based on risk assessments undertaken to evaluate road conditions and to minimize impacts to local communities.

Community Exposure to Disease

As described within PS1, the company / contractor will develop a ‘Community Health & Safety Management Plan’ (CHSMP) which will include necessary mitigation measures to minimize the potential for community exposure to water-borne, water-based, water-related, and vector-borne diseases, and communicable diseases that could result from project activities. The CHSMP will avoid or minimize transmission of communicable diseases that may be associated with the influx of temporary project labor.

The company and its contractors will implement stringent measures to manage risks related to COVID-19 and will ensure that adequate plans & procedures are developed to minimize, as much reasonably possible, its transmission. The project’s workers accommodation planning will be developed considering these risks.

Community Emergency Preparedness & Response 

As described within PS1, the company and its contractors will develop an emergency preparedness & response plan (EPRP) for the construction & operational phase of the project.

The EPRP will outline the projects emergency preparedness and response activities, resources, and responsibilities, and will disclose appropriate information to affected communities, relevant government agencies, or other relevant parties as appropriate.  The EPRP will define engagement processes and ensure that local communities are informed of any emergency situation which may impact them.

Security Personnel

The entire perimeter of the project site will be fenced and entry to the project site will be regulated. In case the project will benefit from public security support in ensuring safety of the workforce and construction sites the client will assess and document risks arising from the project’s use of government security personnel. The client will seek to ensure that security personnel will act in a manner consistent with the PS4 and encourage the relevant public authorities to disclose the security arrangements for the client’s facilities to the public, subject to overriding security concerns.

As per ESAP 21, if the project will additionally employ private security contractor, the company will develop an additional Code of Conduct for site security personnel which will be in line with the requirements of PS2, PS4 and the Voluntary Principles of Security & Human Rights and which will requests that public security adhere to the same standards when working with the company and supporting its security personnel. The company will ensure that their security contractors personal are appropriately screened, trained and competent for their scope of work.  Security personal will be made aware that the use of force is explicitly forbidden, and the security guards must not carry arms of any kind (including batons). 

Both the company and the Government security agency agree to notify each other immediately and in writing if they suspect the other has committed a breach of human rights or the laws of the Uzbekistan.

 The PV Plant will occupy approximately 268 hectares (2.6 km2) of land and will be enclosed by a 2.5-meter-high fence.  The land is currently used for rough grazing of livestock and is generally flat with few features of interest. Previous attempts to cultivate arable crops were noted but a combination of poor soil quality and lack of water made this unviable. The region is semi-arid, and the site is predominantly covered by scrub grassland. Although the site is grazed by domestic animals, it is largely Natural Habitat, although localized areas within the northern and eastern boundary of the site have been modified by historic cultivation. Therefore, Natural Habitat requirements of PS6 apply to the Project.

The Project site is located close to the eastern edge of the Central Asian Southern Desert Ecoregion, with the Alai-Western Tian Shan steppe Ecoregion beginning to the east of Navoi. Both ecoregions are characterized by desert vegetation, which varies according to soil type. The Project is not located within an internationally recognized areas or Protected Area. The nearest Key Biodiversity Area (KBA) is the Tudakul and Kumazar Reservoirs Important Bird Area (IBA) located 20 km to the southwest of the project site, which includes the Tudakul lake which is saline, and the Kuyu-Mazar freshwater reservoir.

Botanical surveys were completed in March 2020, which confirmed that the site largely supports wormwood steppe. This relatively sparse vegetation community is dominated by wormwood species (Artemisia spp.), frequent Isirik (Peganum harmala), frequent grasses (eg. Poa spp.) and occasional thistles (Asteraceae). Although the site is grazed by domestic animals, it is largely Natural Habitat, although localized areas within the northern and eastern boundary of the site have been modified by historic cultivation. Therefore, Natural Habitat requirements of PS6 apply to the Project. During March 2020, a single IUCN Endangered bird species, Steppe Eagle (Aquila nipalensis) was observed migrating northwards over the site. The Emirate Centre for the Conservation of the Houbara (ECCH) at the Uzbekistan (ECCH) was consulted regarding Asian Houbara (Chlamydotis macqueenii), who confirmed that there is potential for this species to occur, although it was not observed during surveys completed during March and June 2020. There are no wetlands within the Project site that might attract congregations of water birds. The only other threatened species confirmed on-site is the IUCN Vulnerable Central Asian Tortoise (Testudo horsfieldii). As per ESAP 23, the company will complete additional flora and fauna surveys confirm the extent and condition of Natural Habitat and the presence of invasive alien species within the Project site (including construction camps, access roads and other areas impacted by the Project).

The Preliminary ESIA provides a short list of ‘likely’ biodiversity-related mitigation measures (e.g. pre-construction survey, relocation of fauna, prohibition of hunting), as well as operational phase monitoring of bird collisions with solar panels and overhead lines. As specified in ESAP 24, the company will develop a construction-phase Biodiversity Management Plan (BMP) that will be designed to achieve no net loss of Natural Habitat and associated threatened species (including the Central Asian Tortoise), with appropriate mitigation measures to preserve the integrity of topsoil and existing natural vegetation on-site and restoration natural vegetation in areas disturbed during construction.

As per ESAP 25 the company will develop an operational-phase BMP that includes long-term management of Natural Habitat on-site and control of invasive alien species. The BMP will also include a biodiversity monitoring plan for the operational phase, including monitoring of bird and tortoise fatalities and to demonstrate no net loss of Natural Habitats.

As per ESAP 26, if the company installs any new, or makes modifications to, existing overhead transmission lines, they will install and maintain bird flight deflectors for the life of the project.