PS7 n/a;

No IPs were identified

PS8 n/a;

This is a Category A project as per IFC's Policy on Environmental and Social Sustainability as the project activities have the potential to cause significant adverse E&S risks and/or impacts that are diverse, irreversible, or unprecedented. The project is located approximately 3.5 km from Mount Aktau an Important Bird Area (IBA) which supports breeding and resident populations of raptors of international and national conservation status. Mount Aktau has a unique ornithological value because of the presence of isolated populations of several species nesting to the south in the Pamiro-Alay mountains and found in the Kyzylkum only here. As such, a key E&S risk for this project concerns the avoidance, monitoring, and management of potential adverse impacts on raptors during wind farm construction and operations.

The E&S disclosure package shared with this E&S review summary comprises a project focused ESIA and Non-Technical Summary, ESMMP, Stakeholder Engagement Plan, Livelihood Restoration Plan, and Critical Habit Assessment. The E&S disclosure documents have been conducted in accordance with IFC PS. Following multiple exchanges and updates during the due diligence phase, both the Lenders and the IESC consider the final E&S disclosure package fit-for-purpose for a wind project of this scale and character, i.e., covering all relevant E&S risks and impacts at an appropriate level of detail. In addition to the above, the project is required to develop an EIA in accordance with national legislation and seek regulatory approval before the commencement of construction activities. Masdar has engaged a local consultancy to assist in the development of the national-level EIA documents. A Concept Statement for Environmental Impact (PZVOS) was submitted to the national authorities with approval obtained on the 16th of July 2021.

Construction and operations phase E&S management and monitoring responsibilities will be shared between Masdar and its EPC and O&M contractors. Masdar's project environmental and social management system (ESMS) is currently under development. However, Masdar has developed an ESMMP that outlines key mitigation measures identified via the ESIA and processes that the company will implement during the project construction and operations phases to meet national and IFC E&S requirements. Masdar is currently developing a Construction Environmental and Social Management Plan (CESMP), which will be finalized prior to the commencement of any site activities. As per ESAP#1 Masdar will develop and implement an overarching Environmental & Social Management System (ESMS), appropriate for the scale & complexity of the project, per the general requirements of IFC PS1. This ESMS will include an overarching E&S policy defining Masdar's E&S objectives and principles and incorporate all necessary policies, procedures, and plans required, including those described within the project ESIA.

Before commercial operations, as per ESAP#2, Masdar will develop and implement an Operations Environment & Social Management System (OESMS) acceptable to IFC and consistent with the project ESIA, IFC PS, and national requirements. The OESMS will address all relevant E&S risks including, at a minimum, pollution prevention; water management; hazardous materials; waste management, emergency response; community health, safety & security; biodiversity management; environmental monitoring; stakeholder engagement (including grievance management).

Masdar will ensure that sufficient staff and contractor resources are allocated to manage E&S performance at all times. During the construction phase, Masdar shall employ, at a minimum, a project Environmental and Social Manager, Biodiversity Manager, Human Resources Officer, Social Manager and Community Liaison Officer, who will be supported by the Project Management Consultant's (PMC) Health, Safety & Environment (HSE) staff and, as needed, E&S consultants. Masdar shall require its EPC contractor to appoint appropriate counterparts to these staff, including suitable health & safety, environmental & social, HR, medical & emergency response resources to ensure sufficient oversight of the entire construction labor force. During the O&M phase, Masdar shall employ, at a minimum, a Biodiversity Manager and adequate support staff to implement project commitments (ESAP#3). The O&M contractor shall appoint sufficient resources to ensure E&S oversight.

As part of the ESMS (ESAP#1), EHS monitoring requirements will be included in the ESMS for the construction and operation phases of the project, including monitoring frequency, performance indicators and targets. Masdar will oversee implementation of project’s monitoring actions required and control contractor and subcontractor E&S performance (refer to PS2).

 During construction, the number of workers at the site will vary according to the activities that are being undertaken, although during the peak of the construction, it is expected that approximately 700 workers will be required. This construction workforce is anticipated to consist of roughly 350 Uzbek workers and 350 expatriate workers (predominately Chinese nationals). Masdar will ensure that all unskilled and semi-skilled workers are sourced from the local region. During the operational phase, the workforce is expected to consist of approximately 35 – 45 workers, the majority of which will be Uzbek nationals.

Masdar has developed several policies defining its commitment to adhering to international labor laws and regulations at a corporate level. At a project level, as per ESAP#4, Masdar will develop and implement a project human resources (HR) policy and associated plans/procedures according to IFC PS2, International Labor Organization (ILO) requirements, and local labor codes which will apply to all project workers. The policy/procedures will define Masdar’s commitments concerning labor and working conditions, maximizing local employment, equal opportunities and non-discrimination, anti-sexual harassment and gender-based violence, prohibition of child and forced labor, whistleblower protection, freedom of association, and collective bargaining. Masdar will further develop an enforceable code of conduct applicable to all workers (including worker conduct within project worker accommodation facilities). All project workers will receive regular training relating to the project's human resources policy, including mandatory training on the Worker Code of Conduct. 

Masdar's human resources procedures will include the establishment and implementation of a worker's grievance mechanism (WGM) aligned with IFC PS2. The WGM will be made available to all project workers, irrespective of their employer and employment status. Masdar will disseminate information about its use to the workforce (in a language the workers understand). The WGM will include specific considerations related to the harassment/gender-based violence grievances. This should include multiple entry points to raise and address allegations, including options to report anonymously if preferred. Masdar will appoint a grievance officer to coordinate the implementation of the WGM (ESAP#5).

The project will not use child or forced labor at any time. Proof of identification and age will be required at the time of employment. During the project's construction and operational phase, Masdar will closely monitor compliance against the requirements defined within their human resources procedures and will implement corrective measures when needed. This monitoring will be extended to contractors and the contractor workforce. Additionally, Masdar will hire a suitably qualified and experienced independent consultant to undertake semi-annual monitoring during the project's construction phase to assess contractor and sub-contractor adherence to local labor laws and project labor and working condition commitments (ESAP#6).

The project's accommodation strategy for non-local workers is still being finalized. However, an existing accommodation unit, located on the outskirts of Zarafshan city, has been identified and assessed by the EPC as suitable for project use. This accommodation unit will be upgraded to meet national and international standards before occupation. As part of the project ESMS, the EPC will develop a Worker Accommodation Management Plan, including specific Covid-19 measures, defining how this facility will be managed. Masdar will monitor the implementation of this plan via regular inspections and audits. Furthermore, as per ESAP#7, Masdar will conduct an audit of the project-provided worker accommodation facilities before occupancy. The audit will assess the accommodation facilities' compliance with IFC/EBRD 'Workers' accommodation: processes and standards, internationally recognized life & fire safety standards, and ensure adequate considerations have been made related to Covid-19 management and gender aspects. All material non-compliances identified will be addressed before the use of accommodation facilities. 

The bulk of the project workforce will consist of contractor and sub-contractor workers. As per ESAP#8, Masdar will develop, as part of their ESMS, a Contractor Management Plan defining their approach to managing the EHS performance of their contractors, subcontractors, and other third parties during the various phases of the project. The contractor management approach will be consistent with the general principles described within IFC Good Practice Note: Managing Contractors' Environmental and Social Performance. Furthermore, to appropriately manage E&S risks related to procurement and supply chain, Masdar will contractually require the WTG O&M contractor to commit to adopting a robust supplier management and traceability system for their pre-screened project primary suppliers in order to ensure that project level requirements integrated in the ESMS are applied systematically. Supply chain management requirements will be incorporated in the procurement policy and processes for the project (ESAP#9).

Masdar will ensure through contractual clauses that its EPC and O&M contractors develop and implement site-specific occupational health and safety (OHS) management system, including plans and procedures of a scale appropriate to their scope of work. The requirements defined within these documents will apply to all project workers, including sub-contractors (ESAP#10). All workers will complete basic OHS training, and supervisory staff and employees undertaking high-risk activities will complete specific OHS training. Operations and maintenance work will generally be undertaken by trained technicians engaged by the turbine supplier familiar with the turbines, tasks, and specific OHS risks involved with their operation.

The project is estimated to generate 1,095 GWh per year, with greenhouse gas emission reductions of             c. 675,615 tCO2 equivalents per year using a grid emission factor of 617 tCO2e/MWh.

Based on the project ESIA, the estimated water consumption during the construction phase is approximately 125,432 m3. This volume includes water required for concrete production, general construction purposes (dust control, fire protection, washdowns, etc.), and domestic use. A detailed breakdown of expected water use is provided within the ESIA. Drinking water will be supplied as bottled water. Water for domestic use and construction water will be provided via the municipal water source (the latter trucked to the site). Water required for concrete production (approximately 56,000 m3) will be supplied by an existing groundwater well. As per ESAP#11, Masdar will conduct a water resources assessment study, assessing the viability of the proposed water supply options, including for associated and ancillary facilities. The study is to verify whether increases in groundwater abstraction attributed to the project will impact third parties' access to water. Considering the general water scarcity in the region, Masdar will require its EPC to develop a water management plan as part of their ESMS (ESAP#1), which will assess water reduction and efficiency measures. Water usage will be negligible during project operations.

The project is expected to generate minor pollution to air, water, and soil, which are anticipated to be readily mitigated through the implementation of standard pollution prevention and control measures defined within the project ESMS. Shadow flicker is assessed not to be a significant risk. Noise from construction activities is not expected to be a significant issue for this project, as there is limited nearby sensitive receptors and construction activities will be limited to day light hours. An assessment of operational noise impacts was completed as part of the ESIA. Based on this assessment, potentially significant effects on sensitive receptors are not anticipated. However, this assessment's methodology is not fully aligned with IFC guidelines. As per ESAP#12, Masdar will reassess project operational noise impacts. The reassessment methodology used shall be aligned with WGB guidelines. If the assessment identifies the need for mitigation measures, these will be implemented. If an alternate turbine supplier is to be used (differing from the model assessed in the ESIA), Masdar shall conduct a supplementary noise assessment assessing impacts specific to this turbine.         

Volumes of liquid, solid, and hazardous waste generated by the project during construction and operations are expected to be low. Domestic wastewater generated onsite will be collected in temporary holding tanks and removed by authorized contractors for offsite disposal in a licensed wastewater treatment plant. Solid waste disposal will be managed through licensed third-party waste contractors approved or contracted by Masdar. As part of the ESMS (ESAP#1), Masdar will assess potential waste disposal and treatment facilities. The assessment will determine whether the facilities are reputable and legitimate enterprises licensed by the relevant government regulatory agencies and whether they are operated to acceptable standards. Masdar will only approve facilities for use on the project if they are suitably licensed and wastes are disposed of and treated safely for human health and the environment. Furthermore, Masdar will develop a Waste Management Plan for the project aligned with local legal requirements, IFC PS3, and WBG EHS general guidelines.

Risks and impacts to host communities of the project and the public were assessed during the ESIA process. Based on the findings, as per ESAP#1, Masdar will ensure that appropriate mitigation measures are defined within its ESMS and will be implemented by its contractors and sub-contractors to manage such risks and impacts effectively. A worker's code of conduct will be established (ESAP#4), clearly defining project commitments and individual work responsibilities.

The main road traffic risk associated with the project is related to the transport of the turbines, blades, and wind tower components (abnormal loads) to the site from vendor facilities located in China via Kazakhstan. Additional risks relate to the transport of aggregate, concrete, water, and site workers. Risks associated with this transport have been assessed within the ESIA. Furthermore, Masdar's EPC has completed a detailed route survey and assessment of the road networks to be utilized to transport turbine components.   The road survey identified several road sections which require to be upgraded. As per ESAP#13, Masdar will require its EPC to develop and implement a traffic and transport management plan (TTMP) aligned with national requirements, IFC PS4 and GIIP, applicable to all sub-contractors. The TTMP will include appropriate control measures to address risks posed to road users and communities related to construction traffic, abnormal loads, and any road upgrade work required to be executed due to the project. Furthermore, the EPC will conduct a detailed pre-construction route survey of the local road network to assess existing road conditions and determine if specific control measures are required.  

No households are resident within the safety buffer zone around each turbine (defined as 1.5 times the length of the WTG blade [tower, plus rotor radius], approximately 375 m) or the overhead line, and there are no communities living within the project site. However, 11 active and 14 abandoned herders' shelters are located inside the project area (of which eight shelters are located on leased farmland), the closest being approximately 0.825 km from the nearest WTG. Masdar will engage with stakeholders including lease owners/herders to discourage any temporary or permanent use of lands within the safety set back of the turbines. In the event of any adverse impacts on sensitive receptors within the safety setback, Masdar will implement the mitigation measures as described in ESIA and LRP. During operations, herders will continue to graze their animals between the WTGs, which will be safe. However, particular care will need to be taken during winter periods, when snow and ice throw could occur. Appropriate mitigation measures will be defined within the project ESMS, including installing warning signs, and active engagement to inform local people of the dangers posed by the project. These measures will be communicated as per the SEP.

Masdar's EPC Contractor/O&M Operator will engage a security contactor to provide unarmed security personnel during the construction and operational phases of the project. The number of security required to be engaged is yet to be confirmed. As part of the ESMS Masdar will develop and implement a Security Management Plan aligned with IFC PS4 and the Voluntary Principles of Security & Human Rights. The plan will include a Code of Conduct for site security personnel, a security risk assessment and incident reporting, and an investigation process. The EPC will ensure that reasonable inquiries are taken to ensure private security personnel are not implicated in past crimes/abuses and are appropriately trained. Masdar will monitor the implementation of this management plan via regular audits. The project's community grievance mechanism will be available for members of the community or employees in the event of a violation of the code for security personnel or other grievance related to security personnel (ESAP#14).

The project is situated in the Central Asian southern desert ecoregion within the Kyzylkum Desert region. The area is characterized by shallow sloping plains, steep rocky slopes covered with sagebrush vegetation. It is located approximately 3.5 km south of the Mount Aktau Important Bird and Biodiversity Area (IBA), which is also a Key Biodiversity Area (KBA). Mount Aktau IBA/KBA is characterized by bird species typical of the low desert areas of this region especially wheatears, warblers, shrikes, finches, partridge and raptors. The IBA and surrounding area contain several endemic plants and invertebrates. 

Bird flight activity data collected across five seasons (2020/1) estimated turbine collision mortality risks with the potential for moderate to high impact on five raptors ('priority biodiversity values'); Egyptian Vulture (IUCN Red List – Endangered, Uzbekistan Red List – Vulnerable/Declining) and Steppe Eagle (IUCN Red List – Endangered, Uzbekistan Red List – Vulnerable/Declining), Griffon Vulture (IUCN Red List – Least Concern, Uzbekistan Red List – Vulnerable/Declining), Cinereous Vulture (IUCN Red List –  Near Threatened, Uzbekistan Red List – Near Threatened) and Golden Eagle (IUCN Red List –  Least Concern, Uzbekistan Red List – Vulnerable/Rare).  The Egyptian Vulture (breeding) and Cinereous Vulture (resident) are two of four bird species for which the Mount Aktau IBA is designated.  These priority biodiversity values will be subject to IFC Natural Habitat no net loss (NNL) requirements. Other priority biodiversity values include Russian Tortoise (IUCN Red List and Uzbekistan Red List – Vulnerable), Caspian Monitor (IUCN Red List and Uzbekistan Red List – Vulnerable); two invertebrates (Feruler Flowerfly [IUCN Red List – not assessed, Uzbekistan Red List – Endangered] and Fedtschenkia Sapigid Wasp [IUCN Red List – not assessed, Uzbekistan Red List – Endangered]).  These priority biodiversity values will be subject to IFC Natural Habitat no net loss (NNL) requirements. Two plants Astragalus centralis (IUCN Red List – not assessed, Uzbekistan Red List – Endangered) and Silene tomentell (IUCN Red List – not assessed, Uzbekistan Red List – Endangered) qualify as Critical Habitat and will be subject to net gain requirements.

Masdar will implement a comprehensive program to avoid and minimize risks. Concerning priority values for birds, Masdar has relocated 15 turbines away from high-risk areas, is deploying an independently proven automated shutdown on demand system (IdentiFlight®) to avoid and minimize raptor collision fatalities at all turbines and will implement a Priority Raptor Food Management Program to remove livestock carcasses that may attract scavenging raptors close to turbines. IdentiFlight combines imaging, artificial intelligence, and machine learning to detect target flying bird species and will automatically trigger a shutdown of turbines if a bird approaches within a threshold distance of turbine blades. To verify the system's effectiveness, Masdar will employ a team of observers to monitor flight activity at turbines and observe IdentiFlight shutdowns for a three-year period.

Raptor nest and roost sites exist within and in close proximity to the project and, if active, will likely be disturbed by construction activities and operating turbines. As per ESAP#17, before construction, Masdar will hire a qualified consultant (ecologist/ornithologist) to develop and implement a raptor breeding survey based on good international raptor monitoring methods. The program will be designed to survey potential raptor breeding/roosting habitat within the project site buffered to 1-km to identify raptor breeding and roosting locations. The first surveys will be conducted during the breeding season before the start of the construction phase. Raptor surveys will be conducted for the first 2 years of the operations phase and then every 3 years for the following nine years. Also, as part of ESAP#17, Masdar will conduct a winter season bat roost survey with a qualified consultant (bat biologist) to assess the scale of a roost initially detected during ESIA surveys on the western edge of the project.

As indicated in ESAP#18, Masdar will develop and implement a construction phase Biodiversity Management Plan (BMP) that will include preconstruction surveys of habitat features associated with the Critical Habitat plant species and the terrestrial priority biodiversity values (the tortoise, monitor and invertebrate species) and will recommend any associated avoidance and minimization measures relevant to these species.  The same approach will apply to the opening of trenches and installation of towers with respect to IdentiFlight infrastructure. The construction phase BMP will include a (raptor) Nest/Roost Protection Plan based on results from the raptor breeding survey (ESAP#19) with recommended measures to minimize disturbance to nests during the construction phase and during O&M activities of the operations phase. As part of the Nest / Roost Protection Plan, Masdar will avoid construction activities in high-risk locations (i.e.,, T108A) near to the nest selection period of the target species (1st March to 15th April).

With respect to the operations phase, as per ESAP#19, Masdar will contract an internationally recognized, specialized wind-wildlife consultancy/experts to collaborate with their locally contracted ecological consultancy to finalize the design of the Post Construction Fatality Monitoring (PCFM) program and develop an operations phase BMP. As part of the PCFM workstream, the international consultancy/experts will be retained for the first two years of operations to provide technical support to the local consultancy on PCFM analysis and reporting, training, and capacity building. The contract will include two site visits per year (1-month per visit) to conduct independent verification of the PCFM program. The PCFM program as a whole will be carried out for an initial 5-year period with semi-annual reporting following a standardized template, but the actual timeframe will depend on fatality results.

In addition to the PCFM program, the operations phase BMP will include the following: i) confirmation of priority biodiversity values based on PCFM results (and any other new regional data available); ii) threshold setting for priority biodiversity values following the potential biological removal method; and iii) an adaptive management framework. The operations phase BMP will include protocols for all onsite operational phase monitoring and mitigation activities, such as the automated (IdentiFlight) shutdown on-demand program, IdentiFlight observer monitoring protocol, any ongoing breeding surveys, and raptor nest/roost protection activities, the Priority Raptor Food Management program. It will also include a semi-annual reporting template for centralized reporting of all bird and bat monitoring, mitigation, and documenting of adaptive management. The operations phase BMP and accompanying protocols (including the PCFM program) will be subject to a strategic review after a 2.5 year period and a 4.5 year period as other types of mitigation, including curtailment (e.g., bats), might be required in the future on the basis of the results of fatality monitoring and per the adaptive management framework.

With respect to the Critical Habitat plant species, as indicated in ESAP#20, Masdar will develop a fit-for-purpose Biodiversity Action Plan (BAP) and Biodiversity Monitoring and Evaluation Plan.  The BAP will include a loss/gain assessment informed by the pre-construction surveys and will identify measures to further guide habitat restoration measures in the ESIA to meet net gain objectives, including a replanting program to convert degraded agricultural land over a wider area.  If offset measures are required, a qualified expert with international experience on offsets will be contracted.  

To provide expert external evaluation and advice on conservation priorities for globally and nationally threatened bird species using the project site, Masdar will establish a Scientific Advisory Body (SAB) of relevant international and national stakeholders (e.g., ornithologists) who will oversee the implementation and effectiveness of the mitigation strategy for priority bird biodiversity values and advise on adaptive management (ESAP#21). The SAB will review semi-annual reports, highlight emerging risks to priority bird populations and recommend actions to help maintain the long-term viability of priority bird biodiversity values using the project site.

Lastly, to manage the multiple biodiversity risks and interrelated mitigation measures, Masdar will contract a dedicated Biodiversity Manager per ESAP#3 who will be responsible for the overall management and reporting of all mitigation and monitoring activities relating to the project (e.g., PCFM, IdentiFlight, implementation of the construction and operations phase BMPs). The manager will be an ecologist with experience managing field programs and reporting results. To effectively work with the IdentiFlight team and lenders, it is expected that the manager will need to speak and provide reports in English.