This is an E&S category A project according to IFC's Policy on Environmental and Social Sustainability (2012). Although it is expected the project will bring economic and social benefits, it will be a potential source of significant, diverse, and irreversible E&S impacts during construction and operation as discussed below.

Key E&S risks and issues for this project include adequate development and implementation of a comprehensive corporate E&S management system including procedures for assessment of future projects; effective procedures and practices at site level management of contractors labor standards and working conditions, and implementation of occupational health and safety (OHS) measures; adequate management of natural resources and solid and hazardous wastes, emergency preparedness; biodiversity conservation; land acquisition and involuntary resettlement; and related impacts on communities including those on vulnerable communities and indigenous peoples.

Environmental and Social Assessment and Management System 

Celsia has documented corporate environmental and social management system (ESMS) based on ISO 9001:2015, ISO 14001:2014, and OHSAS 18001:2007 standards. The system addresses risk assessment, mitigation, and validation; training programs; etc., and is set to ensure compliance with country regulations and Good International Industry Practice (GIIP). As the ESMS is based on continuous improvement principles, to assess the effectiveness of its ESMS, Celsia conducts periodic E&S internal and external audits. https://www.celsia.com/es/quienes-somos/sostenibilidad/dimensiones/dimension-ambiental/. Even though neither the ESMS for solar nor the transmission or the distribution operations are certified, the ESMSs applied to these operations are also aligned with the ISO standards. 

Policy 

The company has overarching corporate sustainability and E&S policies and principles that guide the management of the E&S issues across Celsia’s operations and are aligned with the IFC PSs. These policies, which are updated as needed, are communicated through the employees’ induction process, periodic trainings, and will be applied to the proposed project. The Environmental Policy, which addresses biodiversity, climate change, water, and solid residues, highlights the importance of environmental conservation and the rational use of natural resources and encourages the use of low-carbon energies by diversifying its offer of products and services to improve people's quality of life.

The  Social Policy establishes the social engagement principles based on respect, transparency and building trust; aims to recognize, respect, and value the importance of each interest group, its particularities and characteristics; prioritizes social investment initiatives that contribute to the well-being of communities in the areas of influence of the operations; promotes partnerships with other organizations to develop impactful projects; manages the social inherent risks in its operations; and develops strategies for participation, dialogue, and ongoing communication.

Celsia also has a Human Rights Policy through which it commits to conduct its business operations in accordance with the Universal Charter of Human Rights and in accordance with the regulatory systems applicable in Colombia.

Identification of Risks and Impacts

The company conducts environmental and social assessments to identify risks and mitigation measures for its future projects (including greenfield / acquisition projects). Specifically, for greenfield projects it follows the Ministry of Environment requirement whereby it needs to prepare ESIAs and ESMPs for projects generating greater than 10 MW. For those generating less than 10 MW due diligence assessments using detailed E&S checklists are conducted and ESMPs are developed.

The E&S checklists include, among others, aspects such as soil erosion, air quality, noise, water management, liquid effluents, solid residues, hazardous materials, biodiversity and landscape, access roads, signaling, housekeeping, local hiring, training, community engagement, and archeological aspects. However, the checklists do not adequately reflect aspects on social impacts such as land acquisition, livelihood loss, among others. The examples of ESIAs and ESMPs that IFC reviewed during the appraisal, indicate that these documents comply with the local environmental and social requirements established through Terms of Reference (ToR) issued by the Ministry of Environment which also, for the most part, comply with IFC PSs. For acquisitions, the company also conducts due diligence assessments as per the E&S checklists it has developed to identify potential E&S risks and impact mitigation measures. 

For the future investments to be included in the proposed project, Celsia will develop a corporate procedure for screening and assessment of the proposed projects as per the requirements of PS1 to ensure that the proposed projects will be aligned with Good International Industry Practice (GIIP) and comply with the objectives of IFC Performance Standards and the applicable requirements World Bank Group (WBG) Environmental Health and Safety (EHS) Guidelines. To supplement this documented procedure, Celsia will also develop standard ToRs for external consultants to conduct the due diligence of future opportunities, to be considered for IFC financing under this facility (see ESAP action No. 1).

For instance, as per this procedure, Celsia will undertake the screening and assessments of the proposed wind projects as per the World Bank Group (WBG) Environmental, Health, and Safety Guidelines for Wind Energy of August 7, 2015. Accordingly, the company will consider and incorporate GIIP measures in the project design and implementation, and develop a corrective action plan, in case any gaps vis-à-vis IFC PS or WBG EHS Guidelines are identified.

Management Programs   

Celsia’s ESMS has environmental, health and safety procedures (EHS), aligned with the IFC PSs and WBG EHS guidelines, for conducting assessments to identify, evaluate and monitor the E&S risks and impacts of greenfield and brownfield operations during construction and operation, manage wastes, assess and oversee forest/biodiversity aspects; monitor EHS requirements; etc. In addition, it also has guidance documents for conducting and issuing incident investigation and E&S contingency reports, and GHG emissions data gathering.

Moreover, Celsia also has an effective contractors EHS Management Manual aligned with IFC PS requirements including contractors’ contractual EHS obligations (i. e., existence of a functional ESMS system, induction training; occupational, safety and health requirements; emergency response; use of PPE; safe driving; audits and inspections, etc.), follow up actions for non-compliance situations, and establishes the procedures to oversee their performance. Thorough the EHS contractual obligations to be established to the contractors for the new projects, the company shall require them to develop, implement and maintain their own adequate ESMPs and associated procedures aligned with project requirements, including the IFC PS requirements.

Celsia’s corporate social procedures are based on the compliance with national requirements to address: (i) stakeholder engagement; (ii) external and internal grievances; (iii) land acquisition; (iv) involuntary resettlement; (v) employment; and (vi) free, prior, informed consultation and consent of IPs. Social Management Plans are prepared for each project under development as per Colombian regulations.  There are several gaps identified in the relevant PS 1, 5, and 7 sections related to current procedures and management plans.

To align with IFC Performance Standards Celsia will (i) update its corporate procedures for stakeholder engagement, land acquisition, involuntary resettlement and livelihood restoration; and indigenous people; (ii) update and develop social management plans for each of its projects; and (iii) the Management Plans will include robust monitoring based on established social KPIs to measure (quantitative and qualitative) progress in implementation (see ESAP action No. 2).

Organizational Capacity and Competency 

The Generation area has a team that manages the corporate E&S aspects. It is composed by an E&S leader, who reports to the Generation leader, and supported by forestry, biologists, environmental, and social specialists. Additionally, the transmission and distribution area, that manages the E&S aspects of the operations, has an E&S management team made up of an E&S leader and forestry, environmental, and social specialists. Thus, each project, both during the construction and operation stages, has its respective E&S team that receives guidance from the corporate E&S leader and is responsible for the E&S management of the operations. The current E&S organizational structure is appropriated to ensure the implementation of the company E&S processes. Celsia also has qualified personnel dedicated to overseeing the HR procedures and practices of its current operations. For the wind projects, Celsia will ensure having qualified biodiversity experts to assess the project impacts during development construction, operation, and maintenance, and decommissioning and has already engaged experienced experts on Indigenous People supported by specialized external consultants to ensure the adequate implementation of the processes of Prior Consultation (PC).

At corporate level, the Company deals with the planning of the E&S process (policies, guidelines, definition of methodologies, corporate E&S programs and budget); management of the ESMS and sustainability aspects,  and dealing with the  authorities; implementation of the E&S corporate program and training plan for stakeholders; follow-up to the implementation, monitoring, and reporting  of the E&S programs and compliance with policies and guidelines; development of guidelines, technical concepts, and E&S support in the different processes; etc. At operational level it focuses on the E&S management by implementing the ESMS; ensuring compliance with legal requirements and corporate guidelines; supporting in the planning and execution of operation and maintenance activities; conducting environmental inspections; monitoring E&S indicators, managing corrective, preventive, and improvement actions; preparing compliance reports, managing E&S liabilities; managing grievances and community requests; maintaining stakeholder engagement, etc. Moreover, the Board of Directors conducts annual follow of the environmental and social aspects. It checks into risks and opportunities as well as improvements, and associated budget allocations.

The company also conducts at-induction and periodic in-depth EHS training, as well as special training for identified risky activities. The training programs forms part of the broader ESMS and will be extended to the new developments as part of this proposed project. Also, the outcomes and implementation of resulting recommendations are confirmed and budgeted by senior management and the related conclusions reached at senior level are shared with the employees through the workers/management committee that is in place.

Emergency Preparedness and Response

Celsia develops robust disaster risk management plans for each site, including operation details; ?internal (applicable requirements) and external (areas of influence) context; risk identification of potential worst-case scenarios (i. e., fire, earthquakes, extreme weather conditions, medical emergencies, etc.); actions to reduce identified risks; emergency response measures; emergency response equipment and response personnel; crisis committees, internal/external support groups; communication protocol; protocols to conducting the emergency response drills; and management of change. As developed, these plans are aligned with IFC PS 1 and PS 4 requirements. Each operation has yearly predetermined emergency response drills timetables. In turn, the company requires its contractors to develop corresponding emergency response plans as part of their own ESMS, in accordance with IFC PS1 and PS4.  In addition, all operations have installed fire prevention measures (i. e., smoke detectors, alarm systems, fire extinguishers, fire hydrant systems with dedicated fire water storage and sprinklers, water mains and fire hydrants, portable first aid kits, emergency warning alarms, emergency shutdown procedures, etc.)

COVID-19 Response

Celsia has not had any lay-offs recently not even resulting from the COVID-19 pandemic; however, it has made temporary adjustments to its workforce by adapting to the national as well as respective local labor directives. The company has been paying full salaries to the employees during the lockdown period and has incorporated more than 250 employees, as an additional way to contribute to the economic reactivation. Furthermore, the company has established social distancing protocols for workers at its operations; it has contracted qualified companies to conduct periodic/rigorous disinfection at all premises; it distributes and requires use of masks at all times by all employees, while at premises; and it scans temperature of all persons coming into the premises.  As part of its COVID-19 prevention program, the company has conducted awareness training on hygiene at the workplace as well as at home.  There have been no significant health impacts on the company’s workforce due to the pandemic. Furthermore, the company developed, and it is implementing a COVID-19 infection prevention, control, and response plan, consistent with the provisions under PS2, PS4, and the Interim Advice for IFC Clients on Preventing and Managing Health Risks of COVID-19 in the Workplace. Also, worth noting that Celsia hires local workers and has no migrant workers or worker accommodations thus reducing the likelihood of additional challenges posed by the COVID-19 pandemic.

Monitoring and Review

As part of its broader ESMS, the Company, conducts periodic evaluations addressing aspects such as policy adequacy, overall management system implementation, effectiveness of the workers’ committee, compliance with legal requirements, contractors’ management, risk identification, communications, and stakeholder engagement, etc. Outcomes of these audits include establishing annual safety plans based on risk assessments; updating risks and vulnerabilities assessment; assessing further epidemiological conditions; etc. Specifically, the 2019 audit revealed that in general, all operations comply with all legal requirements.

Celsia has a well-established EHS monitoring program, aligned with the IFC PSs, through which it assesses the EHS performance of its operations. For instance, it conducts monitoring during constructions to include air emissions, noise, solid wastes generation, and biodiversity indicators. For the new developments as part of this project, Celsia will extend the current monitoring program to also include locations assessments, identification of the specific EHS parameters to be measured, frequencies, and monitoring sites for the new projects.

Furthermore, it will supervise the contractors to ensure they comply with the contractually agreed EHS aspects during the construction phase, as applicable. Celsia periodically reports the results of its environmental and social performance to the Colombia environmental authorities and will do so to IFC as well. In addition, Celsia annually publishes a sustainability report.  https://reporteintegrado2020.celsia.com/. 

Human Resources Policies and Procedures

Celsia Human Resources corporate department is responsible for implementing the Human Resources Policies and protocols, published in its website https://www.celsia.com/es/nuestra-empresa/gobierno-corporativo/celsia/documentos-corporativos which are applicable to all direct and indirect employees, as well contractors. They reflect the Colombian labor law and regulations and are consistent with IFC Performance Standard 2 requirements including gender equality and non-discrimination; equal opportunity; prohibition of forced and child labor; fair treatment of workers; prohibition of workplace harassment and sexual harassment; and freedom of association. In 2020, Celsia was awarded the silver seal of Equidad Laboral Equipares, a United Nations Development Program (UNDP) and Colombian Ministry of Labor initiative that honors companies that effectively implement gender equality policies with fair and equitable practices for men and women employees.

Internal Grievance Mechanism

Celsia has implemented two mechanisms with various access channels available for direct employees, suppliers and contractors to file grievances related to the labor environment: (1) Line of Transparency and (2) The Committee of Coexistence in the Labor Environment (CCLE), required by the national labor requirements.

The ‘Linea de Transparencia’ (Line of Transparency or hot line in English) is set up to report grievances related to breaches to its Code of Conduct including, company's HR policies and incidents of Gender Based Violence and Sexual Harassment (GBVSH). The Line is also available for external stakeholders, including complaints from communities. The existence of the Line of Transparency is communicated to the workforce and to communities. It has dedicated phone number and email, accepts anonymous complaints and is open 24/7. To address the complaints raised and logged by the Line of Transparency, Celsia has appointed a corporate conduct committee composed of at least two vice-presidents. The corporate conduct committee is responsible for tracking and resolving grievances, as well as following up their status in an internal register.

The ‘Comité de Convivencia Laboral’ (Committee of Coexistence in the Labor Environment (CCLE) is available for all workers, to file grievances related to the workplace Harassment and GBVSH (H&GBVSH). The CCLE is composed of both Celsia and workers' representatives. CCLE responsibilities are described in the company's internal rules and Celsia’s Protocol to Prevent and Manage the Workplace H&GBVSH grievances according to the national legislation. This protocol outlines the process, steps, timing, and responsibilities to address H&GBVSH; and indicates the CCLE as the main mechanism to report grievances through several channels. As part of the protocol, the Lead of “Talento Humano” (Human Resources) address the administrative and GBVSH grievances and as needed redirect them to the CCLE or to the Labor (legal) Affairs team, or to Corporate Affairs team. For the improvement of their internal grievance mechanism and to ensure all complaints from the workforce are effectively addressed, Celsia to review and update their procedures and protocols to manage internal grievances as detailed in ESAP action No. 3. All Celsia internal grievance procedures should not impede nor delay access to other judicial or administrative remedies available under the national law.

Occupational Health and Safety

Celsia’s safety philosophy is to provide sufficient process safeguards to protect personnel, equipment, and the surrounding communities.  Thus, as part of its management system, the company has programs, safety manuals, and procedures, applicable to own and contractors’ employees, to prevent injuries and fatalities and to ensure a strong safety culture including job safety analyses; use of the permit-to-work; and compulsory use of personal protective equipment (PPE); etc. As part of its operational safety approach, it also has in place a rigorous maintenance management system (i. e., pre-defined preventive based on standard procedures and predictive maintenance checks). It also has in place an OHS training program including use and handling of PPE, safety conditions during operational tasks and other specialized training such as confined spaces, safety audits, job hazard analyses, emergency preparedness, CPR, fire prevention and electrical hazards, etc.

The company’s combined operations lost time injury frequency rate of the combined operations for its own workers was 6.7 in 2018 and 3.4 in 2019 and for contractor workers, the rate also reduced from 24.6 in 2018 to 14.1 in 2019.  In addition, the lost time injury severity rate for its own workers reduced from 32.2 in 2018 to 16.1 in 2019.  This rate was significantly reduced from 175.4 in 2018 to 127.3 in 2019 for its contracted employees.  Celsia had not have fatalities among its own workers.

As part of the management of the OHS aspects of the operations, the Company also has a joint committee of management and workers on occupational health (COPASST - Comité Paritario de Seguridad y Salud in Spanish) that meets monthly and actively engages in the management of the OHS system and ensures that all employees are properly informed about applicable occupational hazards and trained to prevent or control those. All observations and investigations results are shared with all workers through the COPASST. Celsia conducts periodic occupational medical assessment of the overall and occupational health for all its employees, it conducts at-hiring and periodic check-ups and along with the health and safety managers determine the best workplace conditions for the workers.

Workers Engaged with Third Parties

As Celsia relies on contractors for the construction and operation and maintenance (O&M) of its operations, it has a dedicated Supply Chain department for their management and oversight and has developed a robust contractor management. All Celsia construction and O&M contractors include the E&S requirements the contractors ought to satisfy, while engage with Celsia. In addition, Celsia conducts periodic contractors’ supervisions.

As current practice Celsia will extend its practices requiring that all new contractors establish effective ESMSs by developing E&S plans and setting adequate organizational E&S structures with qualified labor, and EHS and community engagement professionals on-site. They will be also required to meet national labor legislation, Celsia’s Human Resources Policies and Code of Conduct, as well as the IFC PSs. As per its contractors EHS Management Manual, Celsia will include these provisions in their contracts and will monitor the implementation of these requirements on an ongoing basis to assess their E&S performance and compliance with contractual requirements. Monitoring will include regular audits, review of the contractors’ internal monitoring reports and documentation as well as review of grievances logged by the contractors and subcontractors’ employees.

Supply Chain

Celsia conducts due diligence on its solar suppliers to confirm that the supplied products are not or will not be produced using forced labor and that the solar suppliers associated with its contractors neither use force labor nor purchase solar power products for use in Celsia projects from any solar supplier produced using forced labor. Celsia will update its Supply Chain Policy to include specific provisions covering child and forced labor requirements as per IFC PS2 and International Labor Organization requirements.  (See ESAP action No. 4).

Resource Efficiency

Celsia’s environmental policy describe its commitment to optimize natural resources. Thus, it has programs to ensure saving and optimal use of water and energy for existing and new projects. Furthermore, it also promotes renewable energies (wind, solar) For the anticipated solar projects, the water requirements during operation are largely to be for panel cleaning. As the water needed for panel washing requires special physicochemical characteristics, Celsia acquires it through third parties that have the corresponding environmental permits to treat it and distribute it.  As part of the assessments to be conducted for the future solar projects, Celsia will assess the potential impacts of water intake to assist in the selection of efficient cleaning technologies. For instance, if ground water is to be used, the company shall first undertake the hydrological studies to determine the availability and suitability of groundwater.

Air Emissions

For the proposed projects, temporary impacts to air quality will occur during the construction phase and this includes fugitive dust; particulate matter (PM), sulfur dioxide (SO2) and oxides of nitrogen (NOx) emissions from construction equipment and vehicles, and from stationary sources like diesel generators (DG) at the project sites. Thus, the contractors will be required to implement mitigations such as ,  water spraying in vehicle movement areas for dust suppression; covered transport of material; management of fill/excavated earth and construction material, wetting stockpiles; restricting excavations and construction material handling during high wind conditions; wheel washing; minimizing drop heights for friable material; minimizing time for which excavated/fill earth is left loose at site; management of pollution from vehicular and equipment emissions including through regular maintenance of DG sets and transport vehicles to minimize PM, SO2 and NOx emissions; and other measures for minimization of fugitive dust emissions (e.g., covering stockpiles).

Wastewater

Generation of wastewater for future projects will be, mainly limited to sanitary wastewater/sewage. During the construction phase, Celsia will require contractors to ensure that construction wastewater (from equipment cleaning, transit mixer washing and other equipment washing/maintenance work) to be disposed through an oil water separator and settling tank prior to being discharged and the sewage will be treated prior to being discharged to meet WBG EHS Guideline standards. The company will require the contractors to provide portable toilets with holding tank at sites where fixed toilets is not possible. 

GHGs

Celsia is seeking to develop innovative, low-carbon products and services, thereby helping to reduce the impacts associated with greenhouse gas (GHG) emissions and their impacts on ecosystems and to ensure the availability of natural resources.

Potential greenhouse gas emissions from the new proposed developments will be minor and will be generate from their construction and will be predominantly associated with the use of fuels for 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). 

Solid Waste Management

For the new projects, Celsia will have specific procedures and ensure that the non-hazardous construction waste generated by the contractors will be used for site filling or disposed in authorized municipal locations and that other inert non-hazardous wastes (packing material, metal, debris, cement bags, drums, etc.), be segregated, stored, reuse and/or disposed of in government authorized disposal facilities.

Noise

An increase in ambient noise levels will be also expected during the construction periods due to increased traffic, use of earthmoving and other construction equipment. However, they will be required to be adequately controlled as per Celsia’s Contractor Management Manual and the EHS requirements to be imposed to the contractors (i. e., limit use of heavy noise and vibration generating equipment to daytime; mufflers in place to noise generating equipment; equipment tuning programs undertake transportation planning to minimize traffic through communities at night in residential areas, etc.) Contractors will also implement monitoring programs at sensitive receptors to demonstrate compliance with the WBG EHS Guideline limits.

As per ESAP action No. 1 above, to assess potential receptors (human, livestock, or wildlife) noise impacts from wind turbines either from mechanical (gearbox, generator, and yaw motors) and/or aerodynamic sources (radiated by the surface of the turbine and by openings in the nacelle housing), Celsia will conduct preliminary noise modelling for any new wind project to determine whether more detailed noise assessment is warranted.

Wind Towers

Prior to the installation of wind towers, Celsia will conduct rigorous risk assessments, including modeling, as per ESAP action No. 1 above, to identify the potential impacts to communities such as noise, shadow flicker, electromagnetic field exposure, among others and, as needed, it will develop and implement prevention and mitigation measures to address shadow-flicker impacts, whenever those cannot be avoid completely. Celsia will also consider the visual interferences on the local landscape and existing elements resulting from the installation of wind turbines; for which, it will consider siting and design to minimize off-site visibility from visually sensitive areas, etc.

Project-induced in-Migration

As part of its E&S assessments, Celsia evaluates the possibilities and defines measures to prevent and manage the migratory influx and its associated impacts on public services (i.e., medical, schools, water, and sanitation), public security, and communities regarding GBVSH The assessments include (i) identification and assessment of risk and potential impacts associated with the project-induced in-migration; (ii) definition of strategies to prevent and mitigate the risk; (iii) implementation of activities such as training and inductions aimed at direct and indirect workers; and (iv) monitoring and reporting. In addition, Celsia has developed a code of conduct applicable to direct workers, contractors’, and suppliers, which includes rules of behavior mirror its corporate policy. In projects and operations with the presence of indigenous peoples, Celsia develops manuals of intercultural relations to orient the expected behavior of workers in the influence area, explicitly referred to the interaction with indigenous and ethnic groups.

Transportation

As part of the risks and impacts assessment process, Celsia develops prevention and mitigation measures related to safe transportation to address (i) potential vehicular accidents with particular attention on critical areas (e.g., nearby schools); and (ii) impacts on communities (e.g., noise, dust, and traffic).  Celsia also includes stakeholder engagement activities to sensitize, orient, and inform local communities about the risk due to transportation activities, and mitigation measures, likewise the existence of an External Grievance Mechanism accessible to the communities. Celsia will implement specific measures to ensure the communities along transportation routes and resting areas have access to the External Grievance Mechanism to file concerns and potential complaints regarding Gender-Based Violence as is included in ESAP action No. 12 below.

Security Personnel

Celsia uses both, private and public forces to handle the security of its operations. Its private armed security is handled by an ISO 18788-2015 certified security provider for Private Security Operations. The company also has a signed agreement with the Ministry of National Defense to allocate military guards for the property and assets protection of Celsia’s sites.  Both, the private security and the public security providers are trained on the Voluntary Principles on Human Rights. The private provider has been awarded for its efforts on gender equality by the Score Program of ILO (2015), ALAS Colombian award on Human Rights and non-discrimination principles (2018), and Equipares granted by Labor Ministry of Colombia (2019). Celsia has developed a corporate Manual for Security Management which includes the general methodology and sequence to assess security risk and implement activities for prevent and mitigate associated impacts. However, the Manual for Security Management does not include detailed and specific means to (i) an adequate assessment of security risks and effective response, (ii) vetting criteria for guards’ recruitment, appropriate use of force, (iii) training on prevention and management of GBVSH, (iv) nor protocol to manage grievances related to incidents associated to guards’ actions. To further align the Security Management Manual for private and public services to PS4 and the Voluntary Principles on Human Rights, Celsia will update its Manual as detailed on ESAP action No. 5.

Celsia’s Biodiversity Policy, which is aligned with IFC PS6, provides the basis for the plans, programs, and tools that Celsia uses to assess and manage the biodiversity aspects of its operations during construction and operation. The Policy aims to protect and conserve biodiversity, maintain the ecosystem services, and sustainably managing natural resources.  To address the biodiversity impacts, Celsia follows the mitigation hierarchy approach (avoidance, reduction, restoration, mitigation, and compensation) within legally protected areas and/or internationally recognized areas. Celsia follows the local and national environmental guidelines and the terms of reference issued by Competent local and national authorities for biodiversity management along with the IFC PS6 requirements. Prior to starting any construction, it conducts rigorous risks and impacts assessments to assess direct and indirect project-related impacts on biodiversity and ecosystem services to determine the biodiversity suitability for selecting a potential project location. It conducts baseline assessments focused on habitat loss, degradation, and fragmentation, among others; and considers the differing values attached to biodiversity and ecosystem services by affected communities. As part of the assessment, it looks to avoid siting projects in areas of in high biodiversity value; it assesses for the presence of critical habitat and species either in the International Union for the Conservation of Nature (IUCN) red list and/or the Colombian red list; and gets guidance and support not only from local, national, and international biodiversity experts but also partners with national and internationally biodiversity focused organizations (CSOs, educations centers.) 

Prior to starting any intervention, and aiming primarily to avoid any impact, it conducts a forest inventory (i. e., plant cover types, areas, volumes of vegetation to be affected) and considers the relevant mitigation actions to be evaluated and approved by the competent environmental authority. When not possible to avoid, it also assesses loss, fragmentation, and degradation of habitat, for all areas and particularly for the protected areas and the disturbance and displacement of fauna. In addition, it develops a compensation plan for biodiversity loss prior to the clean-up of all types of vegetation, including grasslands, which includes ecological restoration actions, with planting of the species affected in ecologically equivalent areas, with plants of the same type of those affected and promoting the creation of plant cover that serves the fauna and conform biological corridors aiming for a no net loss or net positive gain depending on the habitat identified.

Celsia oversees and monitors the implementation of the biodiversity management plans developed for each project. As part of the monitoring, it also focuses on the seasonality to measure the effectiveness and progress of the mitigation measures. If expected results have not been achieved, it proposes new measures or adjustments so that the actions to prevent, reduce, mitigate, and compensate are in line with what is being required.

While the company has a biodiversity policy, qualified personnel, and has biodiversity management plans site by site, as part of this project, Celsia will develop a corporate biodiversity procedure aligned with PS6 requirements, to systematically carry out biodiversity assessments, management and mitigation measures based on the type of habitat identified. (See ESAP action No. 7.)

For example, as per this procedure, for the proposed wind projects, Celsia will conduct full year seasonal baseline studies for birds and bats and for the operation phase, it will establish fatality monitoring to determine the actual impacts of the project.

The Colombian legislation recognizes Indigenous groups, and the national authority determines the rights and obligations of these groups and has requirements to address potential impacts and implement mitigation measures in accordance with these requirements. Celsia in coordination with the appropriate government agency for IPs is responsible for implementation of this process where there are projects with presence of IPs. 

Participation and Consent

According to Colombian Legal Framework, ‘Consulta Previa’ (CP) applies to projects where IP with recognized or non-formal territories are present within their areas of influence, including lands on which natural resources are under IP use. Consulta Previa is prior consultation of indigenous and ethnic groups on matters that will affect their use of natural resources and cultural heritage by a proposed project. Following Consulta Previa and a determination of potential impacts the National Authority can require ‘Consentimiento, Previo, Libre e Informado - CPLI (Free, Prior, and Informed Consent-FPIC) in cases of: (a) physical displacement of IPs; (b) significant impacts on cultural heritage or its livelihoods; and (c) the project requirement to storage or discharge of hazards or toxic materials on IP formal or non-formal territories.

Celsia’s has developed a procedure for Consulta Previa which applies to IPs with recognized or non-formal territories, describing  the steps for its implementation  based on the national law which includes: (i) the implementation of engagement activities with IPs in a culturally appropriate manner, including the use of interpreters to communicate in the communities’ languages; (ii) the seeking of a framework agreement on the methodology to conduct the joint process of impacts’ identification and mitigation; (iii) consultation and information about the specific risk and impacts on communities by conducting workshops, meetings, participatory field verifications, and other actions to ensure that relevant stakeholders are aware of potential project’s risk; (iv) informing communities about mitigation measures and proposes management measures; (v) deliberation and agreement on mitigation and compensation measures; (vi) participatory and consensual definition of a community development plan. Celsia also allows the necessary time for the information analysis and internal deliberation according to the communities’ traditional approaches and bylaws.

National requirements are largely aligned with PS7 but with variation related to impacts on natural resources and economic displacement. To close the gap between national requirements and PS7 Celsia will update  its Consulta Previa and FPIC procedure accordingly by, at a minimum, (i) identifying the gaps against PS7 requirements and complement needed actions to ensure that CPLI and FPIC is satisfied when required; (ii) including clear guidance on the definition of IPs and impacted IPs; (iii) identifying different land uses  through the implementation of a robust stakeholder engagement with potential affected people; (iv) including the preparation and implementation of indigenous people plan; (v) establishing mechanism of monitoring and periodic reporting for each agreement, due date, responsible and status; (vi) ensuring accessibility to an external grievance mechanism specifically for IPs by establishing appropriated channels, and clearly disseminating its existence; (vii) verifying the legitimacy, and inclusion of formal and informal leaders part of the decision making organizational structure of the affected  communities; (viii) assessing the gender-related risks and include gender perspective in consultation, mitigation and project benefits. (See ESAP action No. 8).