If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards. No physical or economic displacement of people will be required. As described above, land has been leased to the company by the Government of Sindh and no land acquisition and involuntary resettlement-related impacts are foreseen. No Indigenous Peoples or areas of high archeological value have been identified within the project footprint, or nearby. As a result, Performance Standards (PS) 5, 7 and 8 are not considered applicable to this project. 

    This project is categorized B due to its limited size and the fact that it is a relatively low impact renewable energy project in a sparsely-populated, semi-arid area with no especially sensitive environmental or social receptors within or immediately adjacent to the project site. The project site is comprised mainly of barren rocky or sandy substrates and sparse vegetation interspersed with occasional nullahs (wadis). Key E&S risks and impacts are expected to include: (i) enforcement of labor and working conditions during construction, in particular health and safety and worker accommodation-related considerations; (ii) transmission of E&S management measures to the EPC and O&M contractors and monitoring of their E&S performance during construction, operation and maintenance; (iii) potential cumulative impacts on birds, bats and groundwater resources associated with the simultaneous development of multiple wind farms in the area; (iv) project-specific impacts on birds and bats during the operations phase; (v) general construction nuisance (dust, noise, increased traffic) for nearby communities; and, (vi) risks posed to communities and workers by the presence of security personnel in the area. 

   An Initial Environmental Examination (IEE) was completed for the wind farm (Renewable Resources, 2016) and subsequently approved by Sindh Environmental Protection Agency. According to Pakistan’s national EIA regulations, all wind projects are subject to an IEE rather than a full-scale E&S Impact Assessment. The 2016 IEE assessed the wind farm impacts in various relevant areas including land use change, landscape and visual impacts, soil environment, water environment, air quality, noise, loss of natural vegetation, loss and disturbance of habitat, settlement and community access, land-based livelihoods, social and demographic structure impacts by influx of workers, local economy and employment, cultural environment, community health and safety including shadow flicker, blade glint, and blade throw. To address some additional E&S issues covered by IFC requirements, ACT II Wind commissioned supplemental E&S studies and reports, foremost of which is the project E&S Management and Monitoring Plan (ESMMP). This document contains i) the company’s Environmental, Health & Safety and Social, Human Resources and Gender Policies; ii) applicable national and Lender E&S requirements; iii) a summary of the project and key E&S characteristics of the area in which its located; iv) project impacts and associated mitigation measures; v) a description of E&S-related roles and responsibilities involving the company, its consultants and contractors; vi) a description of Human Resources requirements and worker capacity building programs, including a worker Code of Conduct and Grievance Mechanism; and vi) monitoring and reporting requirements. The ESMMP for this project is being disclosed with this ESRS. The company will ensure that the EPC and O&M contractors receive this document and that its contents are explicitly referenced and thereby rendered enforcable via the EPC and O&M contracts (ESAP action #1).   

Cumulative impacts: There are currently 22 operational wind power plants in the Jhimpir wind corridor, most clustered to the west of Lake Khinjar, with a combined capacity of over 1,280 MW. Another 16 projects representing another 670 MW of capacity will be added under the current wind program, of which six (including this one) will be supported by IFC. Portfolio projects supported by IFC include the 56 MW Zorlu Enerji project, the 50MW Gul Ahmed I project, the 50MW Metro I project, the 150MW (3 x 50 MW) of TriconBoston project and a 50 MW CSAIL project. A cumulative assessment of the impacts of wind power development in the JWR was commissioned by OPIC and published in late 2015, namely the ‘Jhimpir Wind Farm Region Cumulative Impact Assessment’ (ERM, October 2015). This assessment focused on the potential for cumulative impacts on Valued Ecosystem Components (VECs) associated with wind farm noise, biodiversity impacts, land acquisition, construction and other aspects related to simultaneous development of multiple projects. Key concerns identified included the need for adopting good industry practices for biodiversity monitoring and management, control of water extraction during construction and the benefits of a coordinated approach to employment and CSR inputs to benefit local communities during operations. Although the cumulative assessment provided a useful review of the potential collective impacts on identified VECs in the JWR, a collective mechanism to manage cumulative issues was never fully developed.  Given the fact that the wind program in this area is expanding and that multiple international financiers – including IFC – will be involved, IFC will be coordinating with other Development Finance Institutions to update the study (expected in the first half of 2020), particularly with respect to the development of a common management and monitoring framework focused on identified cumulative concerns. The types of management and monitoring measures proposed in the CIA are not expected to be onerous or expensive for developers as these measures will focus on coordination of data management (e.g. sharing of biodiversity monitoring outcomes), coordination of CSR efforts between companies and participation in a regional wind association, rather than new project-specific monitoring actions. Per ESAP action #2, IFC will hold its clients – including ACT II Wind – responsible for meeting key recommendations arising from the update, including taking part in a collective management mechanism in collaboration with other developers in the JWR.

The E&S performance of the project will be managed by ACT II Wind’s EHS Officer, a Human Resources (HR) Officer, a Community Liaison Officer (ESAP action #3) and the EPC contractors E&S team, comprising at least one environmental specialist, a social/community relations expert and Occupational Health and Safety team members. During the construction phase, the EHS Manager will manage and report on all EHS issues and coordinate with the EHS team of EPC Contractor for management and monitoring of impacts and implementation of the ESMP and related plans and procedures. Social issues will be handled by the HR Manager and the Community Relations Officer, who will report to the Site Manager. During the operational phase, the EHS Manager will be part of the Company’s Engineering Department and will work in close coordination with O&M Contractor and site employees for management of impacts and implementation of the ESMP. The company will also hire an independent E&S consultant to undertake any monitoring activities required by the national or provincial authorities, as necessary. There will also be a Lenders E&S monitoring consultant that will visit the site on a regular basis during the construction and early operations phases in order to monitor implementation of the ESMMP and E&S Action Plan and to make recommendations to the Lenders on any corrective measures needed.

Construction workers will receive training on EHS matters, in particular the Worker Code of Conduct, OHS (safety) awareness, including job-specific risks and corresponding use of appropriate personal protective equipment. This training will be delivered by ACT II Wind’s E&S consultant (RE2) and supplemented as necessary by the project construction manager.

The ESMMP includes an Emergency Response and Preparedness Plan setting out procedures and measures to be taken to deal with emergency situations including emergency escape, shutdown during emergency evacuation, accounting for all personnel after an evacuation, rescue and medical duties for employees, and other emergency reporting (e.g. fires, medical emergencies). ACT II Wind will familiarize all employees and contractors with the plan, which will be reviewed and amended as appropriate to ensure that all parties concerned are furnished with up-to-date information particularly related to snake bite risks.

   During construction, most of the workforce is expected to be sourced from the local region (primarily Jhimpir District, Thatta and nearby villages). At the peak of construction phase, it is expected that around 400-500 workers will be on site; however the average number of workers throughout the c. 15-month construction period is expected to be around 100-150. The workforce requirement during full scale operations is anticipated to be approximately 15-20 people (excluding security personnel) within the proposed facility. The company recognizes the benefits of employing workers from surrounding villages in terms of public acceptance, social inclusion, cost and security and will endeavor to restrict the use of outsiders and foreigners to skilled positions that are not readily available in the project area.

ACT II Wind has developed a Human Resources (HR) Policy which is incorporated into the ESMMP, as noted under PS 1 above, together with associated HR procedures. This covers aspects such as project-specific terms and conditions of employment, working hours and rest time, weekly rest, minimum wages, termination of contract, and a mechanism for resolution of collective and individual labor disputes (i.e. a worker grievance mechanism). The ESMMP also highlights all key PS 2 requirements that the EPC and its sub-contractors will be responsible for, to ensure onward transmission to the EPC and third-party workers. The company will monitor these requirements during construction and operations on a regular basis, and implement corrective measures when needed, per ESAP action # 4. 

As noted above, the company has developed a worker grievance mechanism in the ESMMP and will ensure that all workers, including company employees, contractors and sub-contractors, are made aware of it and trained in its use, such that worker grievances are systematically recorded, tracked and addressed. The EPC and O&M contractors will be required to implement a grievance mechanism and appoint contact persons for receiving, documenting and responding to worker complaints and this will be reported on to the company on a regular basis (per ESAP action #4). The grievance mechanism shall be made available in English and appropriate local languages and disseminated verbally at health and safety meetings and on notice boards. The company will periodically monitor the effectiveness of the EPC grievance mechanism through interviews with workers. The EPC and O&M contractors will be required to either adopt the company’s worker grievance mechanism or develop their own version in line with national and IFC requirements. The worker grievance mechanism shall provide a prompt, understandable and transparent process that provides timely feedback to those concerned, without fear of retribution, and allow for anonymous grievances.

The project ESMMP contains specific requirements related to non-discrimination and equal opportunity which are aligned with PS 2 and Pakistani requirements and which the EPC and O&M contractors will be required to abide by. The ESMMP also makes clear that the project and its contractors will not make use of child or forced labor and will comply with local labor laws and PS2 related to protection of the workforce. As part of ACT II Wind’s commitment to diversity and inclusion, the company has agreed to explore options to help ensure women have equal opportunity to employment; this may include the identification of individuals and/or relevant civil society organizations to provide insight on how women might play a role in the workforce (be it unskilled, semi-skilled or skilled labor) and/or benefit from targeted community investment efforts (ESAP action # 5). 

The company will ensure that, the EPC and O&M contractors develop site-specific Occupational Health & Safety (OHS) Plans for the construction and operations phases, the requirements for which are spelled out in the attached ESMMP document. The company will also ensure that the EPC and O&M Contractors provide their workers with appropriate personal protective equipment (PPE) and train them on the use of this equipment and in adherence to applicable OHS requirements, e.g. how to deal safely with activities such as lifting, electrical testing, work at height/at night and hazards, safety procedures, and emergency preparedness and response arrangements. Safety rules and guidelines will be established and regularly communicated to employees through internal circulars and training programs. All new employees will receive a basic safety and security presentation and regular training will be conducted for first aid and CPR (cardiopulmonary resuscitation), firefighting, and emergency response. EPC shall conduct regular safety inspections and track all incidents and loss time injuries during the construction phase and will keep snake bit kits in vehicles and at key site locations.

Workers Accommodation:

Due to the isolated location of the project site and absence of social amenities locally, a worker’s accommodation camp will be built to house a portion of the construction workforce and will be located near the site: the exact location and size of this camp will be established by the EPC contractor. Workers accommodation arrangements will be managed in accordance with relevant IFC-EBRD guidance (ESAP action #6), key elements of which have already been incorporated into project ESMMP requirements for contractors and discussed with the EPC. These arrangements will be subject to monitoring by the company as well as to external monitoring by the Lenders E&S Consultants during the construction and early operations phases of the project.

   The project is estimated to generate 166,440 MWh per year, with greenhouse gas emission reductions of c. 94,000 tCO2 equivalent per year using a grid emission factor of 0.5687 tCO2e/MWh.

Water use during construction will be dominated by the need to pour concrete foundations, as well as to provide for daily domestic requirements of workers during the 15-month construction period. The ESMMP provides a detailed breakdown of projected water usage. Considering the general scarcity of water in the region, the company has developed a water management plan (refer to attached ESMMP), including using recycled water as much as possible and avoiding the use of scarce groundwater during the construction period. Instead, water will be sourced from one of two government canals which transport water from the nearby lakes to Karachi and other large towns. Water usage will be significant during construction due to the need to construct turbine foundations from concrete and due to the presence of a large workforce on site; this is also a cumulative issue as multiple projects will be developed simultaneously. Water usage will be negligible during operations as the project will not require water beyond for potable purposes involving a small workforce. The company will ensure that the EPC tracks water usage and confirm that no groundwater extraction will take place for project purposes during construction (ESAP action #7).

A 15-month construction phase for the project is envisaged comprising the construction of WTG foundations, sub-station, installation of towers and turbine facilities and all accompanying facilities. Access road construction/expansion and construction works associated with the wind turbines foundations and transformer station requires proper drainage and erosion management. All soil and land disturbed and excavated during construction will be re-contoured, replanted, and returned to its original use where possible. A concrete batching plant will be located on each wind farm site as each of the turbine foundations requires about 800 to 1000 m3 of steel reinforced concrete. The prefabricated concrete batch plants will be provided, operated and decommissioned by the EPC contractor.

Dust emissions from excavations, access roads development, vehicular movements, etc. are potential nuisance risks to the nearby community and will be addressed with adequate mitigation measures, as spelled out in the Noise and Vibration Management Plan contained in the ESMMP. Noise from construction is not expected to be an issue for this project due to the absence of any sensitive receptors within a 3 km radius of the project boundary.

The construction phase will generate a limited amount of waste (packaging, metals, plastic etc.) which will be mostly recyclable and will be sorted and separated in appropriate leak proof containers and disposed of in designated placed by licensed waste management operators. A Waste Management Plan has been developed and is incorporated in the ESMMP.

Contractors will be required to implement specific procedures to reduce waste at source, segregate waste by type, and enhance recycling. During the operational phase, one 250KVA diesel generator will be installed for emergency power supply, to be operated only as back-up. Fuel will be unloaded in designated areas and stored in above ground storage tank. A small quantity of oil/oily water may be generated during the maintenance of pumping stations. Hazardous goods (diesel and oil) will be stored in a covered and controlled storage area with the secondary containment and impermeable floors. Necessary approval from explosive department may need to be acquired for storage of hazardous fuel. The ESMMP contains a Raw Materials and Hazardous Materials Management Plan.

As noted above, there are no sensitive receptors within 3 km of this project site and therefore wind and shadow flicker-related impacts are not relevant to communities and turbine siting.  

  The project ESMMP sets out measures in a Community Impact Management Plan to ensure community health and safety, such as cordoning off the construction site from public access, implementing mitigation measures for transporting wind turbine parts and other materials to site safely, placing information boards about public safety hazards and emergency contact information in the project area in the local language, ensuring that construction workers are housed in worker accommodation facilities built at least 1 km from any community and maintaining worker behavior standards through mandatory training on the project Worker Code of Conduct (which is incorporated into the ESMMP).

No households are resident within the safety buffer zone around each turbine. Although the project area is sparsely populated, dust levels are high and there is a potential danger to local community members from increased construction traffic in the area. To address this, the project has developed a Traffic Safety Plan which is incorporated into the ESMMP, the implementation of which (by the EPC and O&M contractors and their workers) will be monitored by the company. Contractors will be required to ensure that nearest receptors and communities are advised in advance of any significant activities where transport issues have the potential to impact them, with special attention being given to any local religious fairs, market days or village processions.

The project will make use of around 100 armed security personnel and unarmed guards during the construction phase, some of whom will come from the police, the army rangers and from a private security firm to be hired by the EPC contractor. The unarmed guards will be hired from local villages and used as watchmen to prevent petty theft from laydown areas and turbine laydown areas. During operations the project will required between 20 - 30 armed security, who will be contracted by the O&M contractor. The company is in the process of updating its security risk assessment and integrating it with its security management plan (these documents are confidential and will not be publicly disclosed).

The company will make reasonable inquiries to ensure that those providing security are not implicated in past abuses; will train them adequately in the use of force (and firearms), and appropriate conduct toward workers and affected communities; and require them to act within applicable law (ESAP action #8). The company will not sanction any use of force except when used for preventive and defensive purposes in proportion to the nature and extent of the threat, and will provide a grievance mechanism for affected communities to express concerns about the security arrangements and acts of security personnel (the community grievance mechanism is discussed further under Stakeholder Engagement, below).  

     Sindh province of southern Pakistan sits within the Central Asian Flyway (CAF) for migratory birds.  Within this flyway, migrants use the “Indus River Green Route” entering Pakistan across the Sulieman and Karakorum mountains in the north between September and November, making use of wetland areas as they move south.  Large numbers of birds stay (?) over-winter in the Indus Delta in the south of Sindh province before returning northward in February through March. 

Within the vicinity of the Jhimpir Wind Farm Region (JWR), there are two Important Bird and Biodiversity Areas (IBAs) as recognized by BirdLife International, also recognized as Key Biodiversity Areas (KBAs) by the International Union for the Conservation of Nature, that are situated at varying distances from the project site.  These are Keenjhar Lake (Kalri) (11-km from the project site) and Haleji Lake (13-km from the project site), which are both Ramsar Sites and Wildlife Sanctuaries (IUCN Protected Area Management Category IV).  Hadero Lake (9-km from the project site) is also a Wildlife Sanctuary (IUCN Protected Area Management Category IV), but not recognized as a Ramsar site or an IBA/KBA. 

The JWR sits to the west / northwest of Keenjhar Lake in a low-lying, flat, hard rocky landscape dissected by intermittent streams (nullahs) and dry riverbeds.  Ground cover is sparse and limited to small bushes most frequently occurring around the riverbeds.  The area has been highly modified due to expanding rural settlements and cultivation.  A prominent contextual risk in the area is the hunting of the iconic Houbara Bustard (Chlamydotis macqueeni; IUCN Red List – Vulnerable [VU]).  The JWR is a noted hunting ground for the bustard by foreigners and residents alike, which has contributed to this bird’s drastic decline in recent decades from this region.   

Given the numerous existing WPPs located within the JWR, bird survey data have been collected in the area at large for several years.  In coordination with other developers, the company has conducted a preliminary review of existing bird data from 16 existing WPPs as well as from external sources.  Ninety-nine species were recorded at one or more of these project sites. Of these, 59 were regarded as resident and 40 as wintering. The review found records of five IUCN globally threatened raptor species - Egyptian Vulture (Neophron percnopterus) - IUCN Red List Endangered (EN), Steppe Eagle (Aquila nipalensis) - IUCN Red List EN, Greater Spotted Eagle (Clanga clanga) - IUCN Red List VU, Eastern Imperial Eagle (Aquila heliaca) – IUCN Red List VU, and Tawny Eagle (Aquila rapax) - IUCN Red List VU, as well as records of Asian Houbara Bustard (Chlamydotis macqueenii) ) - IUCN Red List VU.  Species were recorded however at very low occurrences. 

Existing literature suggests that the main passageway for birds lies to the east of the Keenjhar Lake, as that is where the Indus River flows. The eastern side of the lake is largely composed of riverine forest; whereas the western side (in which the JWR is located) is mainly composed of rocky strata and tropical thorn forest.  External publications (non-project related) also corroborate these findings, stating that birds of prey are scarce in the JWR.  Publications by the Sindh Environmental Protection Agency (EPA) and other published literature show dramatic declines of waterbird populations since the start of the millennium at both Kheenjar and Haleji Lakes. 

Although the project area itself qualifies as Modified Habitat per Performance Standard 6, given the degraded nature of the area, the threatened birds previously mentioned will be subject to Natural Habitat requirements.  The Indian Spiny-tailed Lizard Saara hardwickii (not assessed on the IUCN Red List) is considered a priority species locally and is declining in the JWR due to collection and trade for medicinal purposes. Although existing data are ample, as identified in ESAP action #9 the company, in collaboration with other developers, will conduct a six-month supplementary baseline survey starting in September with focus on threatened bird species as well as bats following GIIP.  For birds, the baseline will employ “vantage point” survey methods, and for bats, it will entail ultrasound detectors.  As identified in ESAP action #10, the company will also complete its preliminary review of bird survey data from the 16 existing WPPs with focus on summarizing JWR-wide data on threatened birds, which will also support efforts to develop the CIA management framework as mentioned in the PS1 section.

The company’s IEE did not find project-related impacts on biodiversity to be significant.  With the exception of potential impacts on the Spiny-tailed Lizard, the Jhimpir Wind Farm Region Cumulative Impact Assessment conducted by OPIC in 2015 concurs with this view as available information does not indicate the presence of significant numbers of threatened or migratory birds, or that the area is an important aerial habitat for birds or bats. IFC’s due diligence is in alignment with these views.

In alignment with the mitigation hierarchy, the company will bury all collector lines on site except in certain areas due to geological conditions.  The project will micro-site turbines away from habitats of relevance to birds and the Spiny-tailed lizard, such as nullahs and areas with vegetation, burrows or other types of refuge areas.  If there are further relevant findings from the bird and bat baseline survey described in ESAP action #10, the company will consider further adjustments to micro-siting.  With respect to minimization, the company will avoid lighting that may increase collision risk (i.e., steady stream, white lighting), install bird flight diverters in any areas of exposed collector lines, minimize the project footprint, avoiding off-road driving, and, undertake good waste management practices.  These and other measures are incorporated in a dedicated section on biodiversity management in the construction phase ESMMP.

The key measure moving forward will be the development of a robust fatality monitoring program that follows GIIP and is accurately able to generate fatality rate estimates.  For this reason, as indicated in ESAP action #11, the company (with another five developers which IFC is supporting in the area) will contract an internationally-recognized and specialized wind-wildlife consultancy to design and develop a fatality monitoring program in collaboration with a local consultancy and to develop its Operational Phase Biodiversity Management Plan (BMP).  The international consultancy will provide oversight of implementation of the program for a period of at least one year, including periodic in-country site visits, pending an end-year review.  The wind-wildlife consultancy will also provide training to the local consultancy on fatality monitoring in-field methods as well as on fatality rate estimation (mentioned below).

The Operations Phase Biodiversity Management Plan will be developed at least six months before the operations phase and will contain detailed protocols relating to (i) fatality monitoring; (ii) bias correction experiments; (iii) calculating fatality rate estimates; and (vi) an adaptive management strategy (ESAP action 12). The adaptive management strategy will be based on thresholds established as part of the supplemental CIA work. The fatality monitoring program will consist of an adequate number of bias correction trials for both scavenger removal and searcher efficiency and will cover wind turbines as well as any exposed collector lines.  The program will take place for at least a three-year period with an end-year review.  Continuation of the program will depend on the adaptive management strategy (i.e. depending on the results).  GenEst software will be used to generate fatality estimates.  To ensure readiness for the program, the company will procure a freezer for the storage of bird/bat caresses to be located on the project site.  The company will also research possibilities to obtain surrogate bird and bat carcasses for the carcass removal bias corrections to ensure the validity of the results. 

   The 2016 IEE did not identify any villages within the project boundary and this has been confirmed by 2019 surveys. As described above, there are no settlements within 3 km of the project site.

Thatta District is a relatively barren, sparsely populated area with few, if any social services available, meaning that local communities are socio-economically vulnerable. Most members of these communities speak Sindhi and the majority (80 percent) live in ‘katcha’ (poor quality, made from mud/clay and wood with thatched rooves) houses with no running water, sewage facilities or grid power available. There are no local health facilities and very few educational facilities. Water is a major constraint in the semi-arid terrain, with women sometimes walking several kilometers daily to fetch it from wells or boreholes, many of which periodically dry up. During the dry season, villagers may need to move around the landscape in order to find sufficient grazing for their livestock, as feed is too expensive and far away. Crops are grown during the wet season, although rains sometimes fail for 2-3 years at a time, creating hardships. Hand quarrying of rock and stone is widely practiced, involving all family members, as is collection of sand and gravel for sale to building contractors. As a result, community members’ primary concerns in relation to the wind farms to be developed involve potential employment and provision of basic social services.

The project ESMMP contains a draft Stakeholder Engagement Plan aligned with IFC requirements, which identifies key stakeholders and sets out information on ongoing engagement relating to the project. The first engagement was done during the IEE study in April 2014 and more recent engagement was done during the Bird Monitoring baseline Study in 2016 and cumulative impact assessment study processes in May 2016, as well as during supplemental community engagement requested by IFC in August 2019. The latter involved structured meetings with both men and women villagers to i) present key aspects of the project to community members and ii) collect and discuss their views and suggestions. Key issues raised included a request for preferred employment for local people, a request for investment in local infrastructure and services (roads, schools, water supply, healthcare) and – to the extent feasible – in supporting women’s handicrafts. Women are subject to very strict cultural constraints in local villages and are typically not allowed to meet men from outside the village, even with a chaperone, therefore care will need to be taken to avoid interactions with workers during the construction phase.

The SEP will be reviewed periodically during implementation and will be updated as necessary to ensure effective ongoing engagement with local communities. It contains a community grievance mechanism that will be implemented by the EPC contractor with oversight from the company’s Community Liaison Officer (CLO). The EPC and O&M contractors will be required to appoint contact persons for receiving, documenting and responding to community complaints, per ESAP action #3.

The company will provide updates to affected communities (in this case, communities living at some distance from the project site but who are interested in project-related employment and CSR programs) on an annual basis on the project development and ESMMP implementation status with respect to plans or elements that involve impacts on them. In addition, information on project development will be available at the company site office. As mentioned earlier, a Community Liaison Officer will be appointed to ensure smooth interactions with local people and to oversee the working of the grievance mechanism, in coordination with EPC and O&M community liaison staff.

   Muhammad Taufique

General Manager, Operations

ACT Group

muhammad.taufique@actgroup.com.pk