The ESIAs have determined that impacts on cultural property including sites, structures, or groups of structures, having archaeological (prehistoric), paleontological, historical, cultural, artistic, and religious values; unique natural features or tangible objects that embody cultural values, such as sacred groves, rocks, lakes, and waterfalls (PS8: Cultural Heritage) are not expected on account of the Project.

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability, as it is expected to have limited adverse environmental or social risks and/ or impacts that are limited in scale, few in number, generally site-specific and readily addressed through mitigation measures, by adhering to good international industry practice (GIIP) procedures, guidelines and design criteria, as described in the following sections.

The key risks and impacts related to the Project include: (a) economic displacement of 35 Raglai ethnic minority land use rights owners in LH2 project who are considered indigenous peoples as per IFC Performance Standard 7 criteria and 39 Kinh ethnicity land use right owners in PL2 project; (b) potentially physical displacement of 38 agriculture field based structures individually belonging to members of Raglai ethnic minority community to meet noise and safety set back requirements in LH2 project (to be confirmed through detailed measurement survey); (c) potential shadow flicker impact on up to 180 structures/houses (from a total of 417 mapped receptors) in LH2 project and up to 642 structures/houses (from a total of 1550 mapped receptors) in PL2 project; (d) potential bird and bat mortality; and (e) other typical risks and impacts related to construction and operation of wind power projects.

Impacts from shadow flicker will be permanently prevented and/or mitigated through a hierarchical approach that will include curtailment during potential shadow flicker events and during the periods of implementation of mitigation alternatives which will be selected based on consultation and agreement with affected communities.

Risks to biodiversity from the Project are primarily concerning potential bird and bat mortality during windfarm operations. These risks will be managed through the development and implementation of a birds and bats adaptation management plan that will trigger mitigations (such as shut-down, blade feathering and changes in cut-in speed) on wind farm operations based on monitoring of bird and bat mortality. Transmission line design measures to reduce perching and optimize the location of wires will be included and bird diverters will be installed and maintained along the transmission line route to reduce risks of bird collisions.

 Environmental and Social Assessment and Management System

TBW does not yet have in place a corporate ESMS. However, as part of the ESIAs for the Project, a construction stage environment and social management plan (ESMP) has been prepared and an operation stage ESMP will be prepared. TBW has shared the construction stage ESMP with the EPC company and required the EPC company to develop an E&S implementation plan. TBW will, prior to start of construction and as mentioned at ESAP # 2, put in place a construction-stage environment, health, safety and social management system (construction ESMS) for oversight of the construction stage of the project that meets IFC Performance Standards (IFC PSs) and which it will apply to the construction of the LH2 and PL2 projects. The EPC contractor for civil works and Wind Turbine have in place an environment, health and safety management system certified to ISO 14001 and ISO 45001/OHSAS 1800.

Identification of Risks and Impacts

TBW has prepared an environmental impact assessment (EIA) for LH2 project in line with the national regulations, which has been approved by Ninh Thuan People’s Committee in 2017. For the PL2 project, as the project scope is within the Phu Lac 1 project EIA, describing the entire project area of influence and which has been approved by Binh Thuan People’s Committee in 2009, no further environmental assessment was required under national regulations. In addition to the regulatory EIA, the company is preparing third-party ESIAs in accordance with IFC PSs for LH2 and PL2 project. The draft ESIAs and management plans will be updated based on further field surveys to be undertaken in accordance with the timeline mentioned at ESAP # 1.

The ESIAs provide baseline data including: climate and meteorology (temperature and precipitation, relative humidity, sunshine hours, winds, natural hazards), topography, geological condition, ambient air quality, noise, biodiversity (land classification, natural and modified habitat, important sites, invasive species, survey results for avifauna, floral and other fuanal species) and socio-economic baseline (demographic, economic, livelihood, health education, employment, ethnic minority, land use, infrastructure, vulnerability, gender profile, asset, income, expenditure, housing, energy sources, water and sanitation).

The ESIAs address key risks and impacts and identify mitigation measures for construction and operation stages covering: air quality (dust and vehicular emissions), water quality, erosion control, noise, vibration, hazardous materials, solid waste, hazardous waste, wastewater, greenhouse gas emission and avoidance, electromagentic interference, shadow flicker, visual amenity, biodiversity (critical/natural habitat screening, bird/bat mortality, ecosystem services), economic displacement, physical displacement, loss of livelihood, employment, labor working conditions, occupational health and safety, worker accommodation, traffic, influx of workers,  impact on indigenous communities, monitoring, reporting and supervision.

Alternatives analysis has been undertaken as part of the ESIAs that covers the no project scenario and alternate methods of power generation. The alternative analysis included environmental and social considerations like land requirement, efficiency, emissions and waste besides cost and technical aspects. In light of the fact that: Project plans were fixed and approved by regulators well before these ESIAs was undertaken; assessed impacts in the previous EIAs indicated absence of significant scale impacts, and since preliminary construction activities have commenced (access road development) there is limited scope for alternative siting and alignment decisions.

Cumulative impact assessment (CIA) covering noise, loss on terrestrial habitat, impacts on birds and bats has been undertaken and mitigation and monitoring measures proposed. The CIA identified noise emissions, visual quality, avifauna and chiropteran at risk of collision with the turbines; and terrestrial habitat loss and particular interest in flying fauna as the valued environmental components.

Management Programs

TBW will contractually require the EPC contractors to implement the mitigation/management measures that meet good international industry practices (GIIPs), including IFC’s Performance Standards and WBG EHS Guidelines as per ESIAs and the ESMPs, including those discussed below in construction of the project.

A construction stage ESMP has been prepared as part of the ESIAs. TBW has shared this with the EPC contractor. Prior to construction, the EPC contracators arerequired to prepare an environmental, social, health and safety (ESHS) Implementation Plan (ESHS Plan) aligned with the mitigation measures delineated in the ESMP for approval by TBW. The construction stage ESMP provides mitigation measures for: air quality management; water quality management; noise and vibration management; waste management; biodiversity management; social impact management; occupational health and safety management; emergency response; community health and safety management; monitoring plan; institutional arrangements and project responsibilities; stakeholder engagement and grievance redress mechanism; biodiversity management and monitoring.

The EPC contractor for civil works has submitted to TBW a draft construction HSE and social plan that covers: policy on labor safety and environmental management; organization and responsibilities; training on labor safety; working procedures for labor safety; technical guidance on labor safety; site organization; personal protective equipment; management of health, labor, social and environment; emergency response; HSE Reporting; stakeholder engagement plan; and reporting forms. The EPC contractors’ HSE plan needs to be, prior to start of construction as per ESAP # 3, further upgraded into an ESHS plan to include: construction management plan for excavation/backfilling at site, transportation of construction material; dust management plan; noise management plan; vibration management plan; lighting and illumination management plan; solid waste management plan; surface water, groundwater and contaminated runoff management plan; wastewater and sewage management plan; worker code of conduct (including procedures for gender based violence and sexual harassment prevention and remediation), traffic management plan; equipment operation and maintenance plan; hazardous materials and hazardous wastes management plan; labor influx and worker accommodation management plan; worker medical checkup, vectors and disease management plan; occupational health and safety management plan; emergency response plan; security management plan; grievance mechanism; internal and third party audit plan;  contractor/sub-contractor management plan; and labor working and living condition oversight plan. The requirements for developing and implementing the ESHS plan will be formalized in the contractual agreement between TBW and the EPC contractors. Periodic implementation reports will be provided to IFC during construction.

TBW will, as mentioned at ESAP # 5, prior to start of operation of PL2 or LH2 projects develop and implement an operation-stage ESMS aligned with the findings of the ESIAs and the operation stage ESMPs. The ESMS will be consistent with IFC PSs, and will set forth: (a) operational control procedures and measures to mitigate risks and adverse impacts; (b) monitoring and reporting requirements for ensuring the mitigation measures are implemented effectively and in a timely manner; (c) organizational, personnel and financial resources for carrying out the measures; (d) an implementation schedule for these activities; and (e) an appropriate incentive structure to ensure plans are implemented.

The ESMS procedures for operation will include: E&S impact and risk identification; compliance with regulatory requirements, and with IFC’s Performance Standards; development and implementation of management programs, including standard operating and operational control procedures; incident and accident handling, recording, reporting, investigation and analysis; stakeholder engagement and grievance redress; onsite and offsite emergency preparedness and response; maintaining a legal register and a commitment register; E&S compliance and performance monitoring; contractor management and oversight; worker accommodation; security personnel; E&S organization, responsibility and resource allocation; training and awareness; monitoring, recording, reporting and documentation of environmental and social compliance and performance; internal and external audit of the ESMS; management review; and E&S reporting to lenders and other stakeholders. The detailed operation control procedures, which will be developed as part of the ESMS, will include, among others, procedures for the management and monitoring of: noise impacts; shadow flicker impacts; hazardous material and hazardous waste handling, storage and disposal; occupational health and safety;  waste management; biodiversity management as per the biodiversity management plan and birds and bats adaptive management plan; emergency and disaster response plan; compliance requirements for contractors; community health and safety; and security management

A draft Livelihood Restoration Plan (LRP) and Resettlement and an Ethnic Minority Development Plan (REMDP) have been developed for implementation by TBW to address the social impacts of the two projects.

Organizational Capacity and Competency

TBW currently has one staff appointed as HSE officer at corporate level, tasked with ensuring supervision of effective implementation of ESHS plans, delivery of internal training and guidance in complying with Vietnamese environmental regulations for the existing and future projects. Further, TBW has already deployed one HSE lead at each of the two project sites, one community liaison officer at each of the two project sites and one CSR Manager who is common for both sites. This team be duly supported by the team to be deployed by the EPC contractors. Each of the EPC contractor’s site managers will be responsible for ESHS Plan implementation. Each of the the EPC contractors will deploy suitably qualified HSE managers and HSE deputy managers supported by emergency response team, security team, nurse and HSE supervisor (ESAP # 4). 

The EPC contractors will be required to implement a training plans covering safety, worker code of conduct, and biodiversity as part of ESHS induction training, daily toolbox talks and weekly training covering both EPC contractors’ and their subcontractors’ workers. TBW’s HSE and Social team will be responsible for oversight of EPC contractor’s compliance with the ESHS Plan and monitoring and reporting E&S compliance and performance to TBW management, Board, investors and lenders. Further, TBW will require the EPC contractors to employ a human resource officer supported by appropriate number of staff to manage labor working and living condition related aspects during construction, as discussed under the section on Performance Standard 2 and mentioned at ESAP # 4.

Emergency Preparedness and Response

The ESIAs have prepared the outline of an emergency response plan covering emergencies like fire, explosion of unexploded ordnance, hazardous material (fuel, oil, chemical etc. spill), traffic accident, occupational accidents, blade throw, transmission line snapping and transmission tower collapse. This outline will be developed into a full emergency preparedness and response plan as part of the ESHS Plan to be developed under ESAP # 3 and the ESMS to be developed under ESAP # 5. The EPC contractors during the construction phase and TBW in the operation phase will appoint a suitably qualified emergency coordinator; communicate the emergency response plan to key stakeholders including local/district emergency response authorities and neighboring communities; undertake awareness training including drills for building awareness on emergency response. The offsite plan will have procedures for awareness training including drills for building awareness on emergency response; participation in any drills conducted by district/local government emergency authorities; and continuous improvement of the emergency plan based on outcome of the drills.

Monitoring and Review

External monitoring is required as per the national environmental regulations and TBW is in the process of contracting qualified third parties for monitoring. The construction stage ESMP has outlined a monitoring plan covering air quality, noise, surface water, domestic wastewater, construction waste, domestic waste, hazardous waste, invasive species, faunal mortality, CSR, employee and community grievances, LRP and REMDP implementation, stakeholder engagement, grievance redress, occupational health and safety, community health and safety, employment, employee training and physical site inspections. This monitoring plan will be developed to meet IFC PSs and will be embedded in the ESHS Plan to be developed under ESAP # 3.

As part of the ESHS Plan, TBW and EPC contractors will implement a joint monitoring program during construction stage, among others, comprised of daily/weekly joint safety walks, weekly fire extinguisher checks, tool/tackles/lifting material/machinery checks, safety signage and personal protective equipment (PPE) checking, training, accident/incident monitoring and compliance with labor working and living condition requirements. Procedures to document findings, follow up and close out of the findings from the safety monitoring program will be put in place as part of the ESHS Plan. Feedback from the monitoring program will be provided to the subcontractors, corrective action plans developed, and upon implementation of corrective action, subcontractors will submit an action taken report with appropriate evidence for tracking and closure. Accident/incident data will be reported to TBW management in monthly project progress reports. TBW, will engage a qualified third party ESHS auditor with experience in GIIPs, as mentioned at ESAP # 6, to undertake semi-annual audits during construction to obtain assurance that the construction ESMS and ESHS Plan are being adequately implemented.

As discussed above, a comprehensive monitoring program for the operations phase will be established as part of the ESMS (ESAP # 5) to comply with regulatory monitoring requirements, and be consistent with IFC Performance Standard requirements and applicable and relevant sections of WBG EHS Guidelines, taking into account the identified risks and impacts, and information requirements of key stakeholders and affected communities.

As part of the ESMS, TBW will implement procedures for annual third party and bi-annual internal ESMS audit. The analysis of information from the monitoring and audit programs will feed into periodic management system review process to assess efficacy of the ESMS and identify measures to further strengthen the ESMS. The results of the monitoring program, the findings, deviations and corrective actions implemented will be periodically reported to TBW management and Board.

Human Resources (HR) Policies and Procedures

During construction, most of the workforce is expected to be sourced from the local region. Each project will employ approximately 84 workers (peak number of workers per shift) during the construction phase of about 8 months for both projects. The proportion of the local workforce is expected to be 95% of the total construction workers. 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 source employees from local area, subject to the availability of candidates with the required skills and experience.

TBW has adopted and recently updated an Internal Labor Regulation which covers most of the six objectives of PS2, including, among others, working hours, overtime limits and payments, annual and maternity leave, salary and benefits, social insurance, health insurance, accident insurance, and resolution of labor disputes. Per the 2019 Labor Code, all companies must permit employees to join a trade union. The Code defines the right for all employees to work without being discriminated against based on their gender, nationality, social class, beliefs, or religion. Moreover, employers are strictly prohibited from discriminatory behavior toward female employees or conduct that degrades female employees’ dignity and honor. Employers must implement the principle of gender equality regarding recruitment, utilization, wage, and wage increase. The construction stage ESMP also highlights all key PS2 requirements that the EPC contractors and its subcontractors will be responsible for, to ensure onward transmission to the EPC contractors and third-party workers. The company will monitor these requirements during construction on a regular basis, and implement corrective measures when needed, per the monitoring program to be included in the ESHS Plan (ESAP # 3). TBW will, as part of the ESHS Plan (ESAP #3), require the EPC contractors to deploy a human resource officer to oversee compliance with labor working and living conditions.

Working Conditions and Terms of Employment

Terms of employment and the rights and responsibilities of workers are formalized into employment contracts and communicated to all direct employees along with the Internal Labor (HR) Regulation. Working hours and overtime work are as per national labor law requirements, i.e. not more than 8 hours a day and 40 hours a week. Employees in the operation and production facility work in a shift system of not more than 40 hours a week with limited overtime. Employees receive time-off or cash compensation in lieu of any overtime work at rates regulated by the national labor authority. All employees are enrolled in social insurance, covering pension, unemployment, medical, injury, and maternity. In addition, a female employee nursing a child under 12 months of age shall be entitled to 60 minutes off in every working day. On top of the basic salary, employees are also provided with various allowances, including meal allowance, mobile phone expense, uniform and personal protective equipment expense, hazard pay. Employees also receive annual health check.

Labor Accommodation

During construction, the EPC contractors and subcontractors may arrange for about 20 workers to live in purpose-built accommodations. As part of the ESHS Plan mentioned at ESAP # 3, the EPC contractors will develop and ensure implementation of a Workers Accommodation Plan in line with IFC-EBRD guidance on workers’ accommodation. If female workers are employed and/or reside in labor camps, provisions and safeguards (statutory as well as PS) for welfare, social protection, security and benefits will be made available.

The EPC contractors will ensure that the accommodation provided to its workers or subcontractors workers during construction, whether onsite or offsite, meets construction labor camp guidelines in accordance with PS2 provisions including related to: appropriate construction material for the accommodation and protection from extreme weather; adequate space and facilities; ventilation; amenities and utilities provided; access to electricity; access to water supply and sanitation; safe cooking place; protection against vector- borne diseases; facilities to meet the needs and safety of women workers/women family members of workers; handling, treatment and disposal of waste, wastewater and sewage from the accommodation; fire safety and emergency response; hygiene, disease prevention and vector control; access to medical facilities; avoidance of conflict with host communities; transportation to work, if accommodation is offsite; and safety and security. 

Workers’ Organization

Per the Labor Code in Vietnam, all companies must permit employees to join a trade union. At present, close to 100% of TBW’s workforce belongs to a labor union and membership is voluntary. A Collective Bargaining Agreement (CBA) has been successfully agreed upon in 2017 and recently been renegotiated and updated between the labor union and TBW to reflect changes in the revised Labor Code, which came into effect early 2021. This agreement complements TBW’s HR Policy and related procedures.

Non-discrimination and Equal Opportunity

TBW will, as part of the HR Policy and Procedures Manual commit to non-discrimination and equal opportunity and make employment decisions based on equal opportunity and fair treatment, and in accordance with Vietnamese regulations on non-discrimination. The company has recently amended its HR policy and employment terms and conditions to include commitment to address gender-based violence (GBV) or reports of sexual harassment through appropriate disciplinary measures. Going forward, as part of ESAP #7, the company shall strengthen its mechanism for receiving complaints that protects the identity of the complainant, investigates the complaints based on a “survivor centered” approach, and applies remediation in accordance with the HR policies and procedures and national regulations. The company will provide training to the workforce and contractors, including during induction on the policy, new procedures and grievance mechanism to address sexual harassment/GBV.

Grievance Mechanism

A worker grievance mechanism has been developed in the ESMP, which will be incorporated into the ESHS Plan (ESAP # 3) and ESMS (ESAP # 2 & 5) and will ensure that all workers, including company employees, contractors and subcontractors, are made aware of it and trained in its use, such that worker grievances are systematically recorded, tracked and addressed with feedback given. The grievance procedure will enable employees to raise anonymous complaints, and will have provisions for protection of confidentiality, non-retribution and protection against retaliation. 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 under the ESHS Plan (per ESAP # 3) and ESMS (ESAP # 5). The grievance mechanism shall be made available in 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 contractors 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.

Protecting the Work Force

TBW and the EPC contractors will implement a process for checking and recording age of employees and contract workers to prevent child labor on its project sites. The Sponsor will, as part of its HR Policy and Procedures Manual (ESAP # 7), put in place policies and procedures relating to prevention of child labor and forced labor, consistent with the national requirements as well as IFC PS. These policies will be applicable to the EPC contractors and their sub- contractors hired for the project and for contractors engaged by TBW for the O&M stage.

Occupational Health and Safety

The EPC contractors will implement their ISO 45001/OHSAS 18001 certified OHS Management System for the project and the implementation will be reflected in the their ESHS Plan for construction and in TBW’s ESMS for operations. (ESAP # 3 and #5). The OHS procedures in both the ESMP and ESMS will include, among other relevant aspects, procedures for: health and safety (H&S) Policy; H&S objectives; hazard and risk assessment and Job Safety/Hazard Analysis for each key activity; roles and responsibility allocation; safety signage; provision and use of personal protective equipment; safety induction; safety awareness and training to employees including contract workers; worker competency assessment for key high risk activities; work permit system; safe work procedures for various activities that exposes workers and employees to hazardous conditions (working at height, confined spaces, temperature, poor weather); safe design, provision of adequate amenities and maintenance of hygienic conditions in the  of workplace and accommodation; periodic medical checkup and surveillance program; disaster management; emergency response; mock drills; joint disaster and emergency response exercises with relevant external authorities/agencies; firefighting and other emergency response infrastructure and equipment; composition, terms of reference meeting and decision procedures and follow up of joint worker management EHSS  committee; leading and lag OHS indicator monitoring; near miss, accident, incident investigation, reporting and corrective action; training on safe procedures for drivers; contractor/service provider safety evaluation and control; asset safety investigations; procedures for periodic internal and third party audits; check lists for onsite physical situation checks; adoption and implementation of safety risk mitigation hierarchy in risk evaluation and accident prevention;  and ensuring availability of doctors or para-medical staff and access to emergency medical facilities and ambulance together with facilities for administering first aid.

Workers Engaged by Third Parties

The EPC contractors will as part of the ESHS Plan (ESAP # 3) and TBW will as part of the HR Policy and Procedure Manual (ESAP # 7) for O&M contractors implement a Labor and Working Conditions Policy in line with local laws, the Company’s HR Policy and IFC PSs  including the following procedures, among others: Workers Code of Conduct; workers grievance mechanisms, anti-harassment; treatment of in-migrant workers; and avoidance of child and forced labor.

TBW will as part of the ESHS Plan (ESAP # 3) for construction and ESMS (ESAP # 5) for operation stage, implement contractor management procedures including: (i) a compliance checklist against the applicable legal requirements and IFC PS; (ii) labor working conditions performance criteria as part of contractor qualification and selection; (iii) a workers code of conduct including provisions to prevent gender based violence; and (iv) ESHS monitoring and audit procedures to obtain assurance on contractor compliance with relevant requirements. The required set of procedures will ensure, among other aspects, the following: compliance of the contractor and its subcontractors with applicable statutory requirements and IFC PS on labor; consistency of worker accommodation with IFC guidance; implementation of grievance mechanism; harassment prevention; prevention of child labor and protection of the work force, including engagement of migrant workers, if any, on substantially equivalent terms as non-migrant workers performing same work. These requirements will be included in the contractual agreements with contractors. TBW will ensure that it has procedures, capacity and resources in place to regularly review and monitor the performance of its contractors especially with respect to working conditions, workers’ accommodation, OHS and protection of work force.

Resource Efficiency and Greenhouse Gas (GhG)

This is a renewable energy project. The GhG emission avoidance for PL2 and LH2 projects are estimated at 84,000tCO2e and 78,000tCO2e per annum respectively. The project will use LED lighting within the plant and offices and for 35 outdoor light posts within the premise to save power.

LH2 project will source construction water from Ba Rau reservoir while domestic water will be supplied from Loi Hai commune water supply station. For PL2 project, construction water will be taken from drilled wells, from communal water supply system, from nearby rivers or streams or existing household wells, and will be treated to meet technical requirements. Domestic water demand is roughly estimated to be 7m3 per day and will be taken from drilled wells in project area, stored in water tanks and will be treated before use.

Pollution Prevention and Control during Mobilization

Access road construction is underway and the EPC contractor for civil works is undertaking this in accordance with its ISO 14001 and 45001 certified standards, national regulation and the HSE Plan submitted to TBW. The EPC contractor for civil works will implement the upgraded ESHS Plan (mentioned at ESAP # 3).

Pollution Prevention and Control during Construction

The environmental impacts from construction activities for the projects are those typical of most construction sites and include: dust generation; soil erosion and sediment loading increases; noise; waste management; potential spills of hazardous and other material; construction debris disposal; domestic solid waste and wastewater from construction camps; increased water usage; and construction vehicle traffic. As indicated under Performance Standard 1, prior to construction, the EPC contractors will develop and implement a ESHS Plan (ESAP # 3) , that includes specific mitigation measures, as per commitments in the ESIAs, and that meets applicable aspects of IFC PSs and applicable and relevant aspects of WBG EHS Guidelines. Some of the specific mitigation measures to be applied include: installation of sediment traps to reduce sediment in runoff generated during land clearing/filling, implement measures to minimize risk of spill and overflow during transportation; constructing paved roads early where feasible and cleaning of paved roads; provision of water sprays to control dust on roads and stockpiles; wheel washing of transport vehicles; and covered transport of construction materials in trucks.

Temporary impacts to air quality may occur during the construction phase. The main sources of air emissions at the project sites are: fugitive dust emissions; and particulate matter (PM), sulfur dioxide (SO2) and oxides of nitrogen (NOx) from construction equipment and vehicles, and from stationary sources like diesel generators (DG) at the project sites.  The EPC contractors will as per the ESHS Plan, will be required to undertake: 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; vehicular movement planning to minimize trips; 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). An increase in ambient noise levels is expected during the 12-month construction period due to increased traffic, use of earthmoving and other construction equipment. The EPC contractors will: limit use of heavy noise and vibration generating equipment to during day time to the extent possible; ensures mufflers are provided in noise generating equipment; implement equipment tuning program to minimize noise at source; not undertake high noise generation activity at night ; and undertake transportation planning to minimize traffic through communities at night in residential areas. Concrete will be bought and transported from existing batching plants. EPC contractors will implement a monitoring program covering ambient air quality and ambient noise levels at sensitive receptors to demonstrate compliance with WBG EHS Guideline limits.

Generation of wastewater will mainly be limited to sanitary wastewater/sewage from labor accommodation and project office areas during construction. Total construction wastewater generation for LH2 project is estimated at 2.5 m3/day. The EPC  contractors, as part of the ESHS Plan implementation, will ensure that construction wastewater (from equipment cleaning, transit mixer washing and other equipment washing/maintenance work) will be disposed through an oil water separator and settling tank. The treated wastewater will be used in dust suppression if it meets treatment quality objectives as specified in the ESMP. The construction stage sewage will be treated through septic tank and soak pit at both PL2 and LH2 project sites. The company will require EPC contractors to provide portable toilets with holding tank at sites where fixed toilets is not possible.  EPC contractors will ensure that non-hazardous construction waste will be used for site filling or disposed in authorized municipal locations. Other inert non-hazardous wastes (packing material, metal, debris, cement bags, drums/carbuoys etc.), garbage from worker accommodations are collected, segregated, stored and disposed of to re-users or in government authorized debris treatment and disposal facilities.

Hazardous materials that will be stored at project sites during construction include: fuel, lubricating oils, transformer oil, paints, batteries and other chemicals, and hazardous wastes (used oils, waste/residual paint, oil/paint soaked rags/material, filters, empty oil/paint/chemical drum/barrels, spent batteries etc.) are expected to be generated during construction. These hazardous materials and hazardous wastes handled/generated at site during construction will be: stored under segregation and containment; handled/used with appropriate care and personal protective equipment; and hazardous waste will be transported and disposed through entities authorized to handle, recycle and dispose hazardous wastes.

Surplus excavated earth will be used for area leveling, back filling and for localized leveling work at site. In both the projects, the amount of construction waste and domestic waste generation in construction phase is estimated to be 0.032 tons and 20 kg per day respectively. Hazardous waste including spent oil and grease, oil-impregnated cloth, is estimated to be 1,480kg during one year of construction.

The EPC contractors will segregate and store construction solid waste in designated areas within the project sites and dispose these through authorized agencies. The EPC contractors will identify wastes that can be recycled and will dispose these to re-users/recyclers. Waste that cannot be reused/re-cycled will be stored in bins and disposed of through licensed waste contractors. At the end of construction, a post-construction survey of the construction area will be conducted to confirm that all debris and wastes have been removed and appropriately disposed of.

Pollution Prevention and Control during Operation

In LH2 project, the baseline daytime noise at 52.7-56.7 dB(A) are within the national ambient noise standards and marginally higher than WBG EHS Guideline limits. The nighttime noise levels at 48.1-56.1 dB(A) is marginally higher than the national ambient noise limit and well above the WBG EHS Guideline limits. For PL2 project, the daytime noise levels at 48.3-51.4 dB(A) is within both national and WBG EHS Guideline limits. The nighttime noise levels (47.7-49.6 dB(A)) are within national standards but higher than WBG EHS Guideline limits. The predicted noise impact in residential villages in the AOI of LH2 project Ba Rau 1, Ba Rau 2, An Dat and Suoi Da is less than 37.2dB(A) though it is predicted at more than 47.3dB(A) in areas about 250 m from the turbine locations. There are 32 structures (built in the agricultural fields) that fall within this zone and potentially to be relocated (to be confirmed through detailed survey).

In PL2 project, noise modeling indicates that sensitive receptors are exposed to less than 44.6dB(A) requiring no further mitigation action. TBW will, as part of the ESMS, implement a plan for periodic monitoring of ambient noise levels to demonstrate performance levels aligned with the applicable WBG EHS Guidelines.

Domestic wastewater is the primary wastewater during operation phase, which will be treated in a 3-chamber anaerobic septic tank.

It is expected that 10 staff will be working permanently throughout the operation phase of the wind farm. It is estimated that total 2.5 to 3.0kg of waste will be generated every day from the wind farm. The waste will mainly comprise of: Organic waste such as discarded vegetables, leftovers; food and drink packaging; discarded plastic and glass products; and Metals, such as empty food cans. Domestic waste shall be disposed through authorized agency. TBW will as part of its ESMS (ESAP # 5) require staff to: categorize domestic waste into 1) Recyclable/Reuse waste, 2) Organic waste and 3) Other waste. Separated bins and appropriate disposal for each type of waste shall be arranged; and workers shall be trained on waste management and storage practices (e.g. handling, storing and disposal) as a part of environmental awareness program.

The hazardous wastes expected to be generated at each of the sites include used left-over paints, leftover chemicals, empty drums/containers for oils, paints, chemicals, used lighting bulbs/CFLs/LEDs. Spent oil from maintenance and repair of WTGs and transformers; oil-contaminated cloth, discarded ink cartridges, broken fluorescent lamps, used batteries from office activities. It is estimated that the WTGs and transformers will be maintained once every four to five years. Expected amount of waste oil to be generated in each maintenance is 350litres, while the amount of oil-contaminated cloth is estimated to be 2kg.

TBW will as part of the ESMS implement procedures to segregate, label and store hazardous wastes within contained areas and dispose them through authorized entities for treatment, reuse/recycling or disposal. TBW will implement duty of care procedures to confirm that the hazardous material / waste operators are transporting, handling, storing, treating and disposing of the materials / wastes appropriately in line with GIIP.

 Community Health and Safety

The project construction activities may cause nuisance to communities from: traffic disruptions; noise; dust; illumination; drainage disruptions; and potential for impact on groundwater or surface water. Most of residents of Loi Hai Commune live in Ba Rau 1, Ba Rau 2, An Dat villages (about 1.7km to the south from the nearest WTG) and Suoi Da Village (about 1.0km to the west from the nearest WTG), given the short construction period, the magnitude of impact from dust, noise, water quality, solid waste, and air quality on local residents are predicted to be small as it would likely intermittently affect a few agricultural huts among more than 3,000 households of Loi Hai Commune. Nevertheless, there is a potential danger to local community members from increased construction traffic in the area.

The company will, as part of the ESHS Plan (ESAP # 3) , require the EPC contractors to implement procedures to address community health and safety risks including: material movement planning; timely information to affected communities on commencement of key construction activities; traffic management; speed controls and vehicle monitoring; drive through arrangement; backup alarms; training of equipment operators and drivers in safe driving techniques; provision of patrols/traffic marshals/flagman where required; barricading of excavated areas; safety signage; illumination;  reducing fugitive emissions; restriction of night time activities to low noise generating work; developing a materials movement plan to ensure that vehicle movement during construction has minimal impact on daily life patterns of nearby communities; and undertaking community safety awareness. The project ESMP sets out measures 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, and maintaining worker behavior standards through mandatory training on the project Worker Code of Conduct (which is incorporated into the ESMP).

Further, to address traffic safety risks, as part of the ESHS Plan, (ESAP # 3), the EPC contractors will develop a Traffic Safety Plan which will be incorporated into the ESMP, the implementation of which (by the EPC contractors and their workers) will be monitored by the company. Contractors will be required to ensure situation 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 community activities, market days, school timings, or village processions.

Safety Setback

As per national safety set back requirements, wind power work must be 300 m away from residential area. Although the huts/houses/structures near the wind turbine are built on agricultural land/ in the cultivation area and are not considered a residential area, many of the Raglai community members stay all day long in the huts/houses/structures. 38 houses/structures were identified within the total 300 m zone of the safety set back (which include the 32 that potentially need to be relocated due to noise). However, the exact number of affected structures and people should be determined upon the finalization of detailed measurement surveys (DMS) and consultations with affected households that will be undertaken by TBW. . In PL2, there are no structures within the 300 m safety setback area.

Shadow Flicker

Shadow Flicker modeling, using worst case scenario (sunshine from morning to evening, cloudless days, each house considered greenhouse (akin to having glass walls and roof), no physical barriers considered, no screening by vegetation considered, rotor operational during the entire duration perpendicular to the sun) predicts that potentially up to 180 structures/houses are impacted for LH2 project and up to 642 houses are potentially impacted for PL2 project. For LH2 project, of the 180 affected structures, approximately two-thirds are in the 30-45hr/year exposure zone and the balance in the more than 45hr/year exposure zone. For PL2 project, approximately 75% of the structures are in the 30-45hr/year exposure zone and the balance above that. It is expected that upon ground survey, the number of affected structures will decrease further due to direction of openings in the structures with respect to turbine alignment, presence of existing vegetative screens and presence of other physical barriers. No physical relocation of structures is envisaged due to shadow flicker. As described in ESAP # 9, TBW will develop and implement a prevention and mitigation plan to permanently address shadow-flicker impacts, including detailed household level survey of potential exposure to shadow flicker, curtailment during shadow flicker periods up until a time that other permanent mitigation measures have been implemented (i.e. establishment of vegetative screening and/or blinds and other measures that are acceptable to affected households based on prior consultation during planning and based on monitoring of implementation effectiveness).  The plan will include a detailed assessment of prevention and mitigation alternatives prepared by an internationally recognized expert on the subject, contents and results of consultations and proposed monitoring efforts, including independent verification of the effectiveness of its implementation and appropriateness and effectiveness of the associated grievance mechanism.

Electromagnetic Field

EMF for 110kv overhead transmission line and 22kV underground cables and wind turbines was estimated. Based on modelling, the calculated maximum EMF is below allowable public and occupational exposure limits in accordance with ICNRP and the Government Decree.

Visual Amenity

The installation of wind turbines and movement of large construction vehicles from the two projects are identified as sources of visual interferences on the local landscape and existing elements. It is predicted that visual impact is moderate to high. Accordingly, additional mitigation measures are proposed including: siting and design of roads and other infrastructure to minimize off-site visibility from visually sensitive areas; use of unobtrusive colors to minimize contrast; use of materials that will minimize light reflection; and retention of existing vegetation.

Ecosystem Services

EPC contractors will use groundwater and surface water for construction. Typically, groundwater is used for domestic purposes in the villages in the project area.  In addition, EPC contractors will implement measures described above in the construction stage ESMP to mitigate risk of ground water contamination.

Community Exposure to Disease

The company will require EPC contractors to maximize local hiring but there will be an influx of about 20 workers at each of the Project sites. To minimize the risk of increased incidence of communicable diseases (including Covid19), health check-up of all migrant workers will be undertaken and access to medical assistance/facility will be enabled while minimizing interactions with communities. The worker accommodation will meet IFC standards as discussed above and worker awareness programs will be implemented including on worker code of conduct. 

Security Personnel

The company will, as part of ESAP # 3 require the EPC contractors to undertake a security risk assessment and based on that determine the security arrangements. Both the EPC contractors and TBW will integrate their Security Management Plan in line with IFC PS4 as part of the ESHS Plan and ESMS to be developed per ESAP # 3 & 5 respectively, which will  include procedures for ensuring that: past records of security personnel employed are screened; permissible and impermissible actions including in relation to firearms are laid out; security personnel are trained in avoidance of human rights violations including among other aspects related to sexual harassment, gender based violence, community and employee interactions; bona fide complaints against security personnel are investigated/disciplinary actions implemented. 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 towards workers and affected communities; and required them to act within applicable law.. 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.

 Both windfarms are located in the Southeastern Indochina Dry Evergreen Forests and Southern Annamite Montane Rain Forests Eco Regions.  These Eco Regions in coastal Vietnam have been heavily modified due to agriculture and armed conflict.

The nearest Protected Area (PA) and internationally recognized area (IRA) is the Nui Chua Key Biodiversity Area (KBA)/Nui Chua National Park that is 1km east of the LH2 Project.  The KBA has been designated due to a population of Black-shanked Douc Langur Pygathrix nigripes IUCN CR. There are no PAs/IRAs within 10km of PL2.

Regarding habitats of both sites, they are extensively modified, consisting of agricultural fields of rice and market gardens and adjacent plantation forests that are modified habitats.  Both Projects are adjacent to Protection forests designated under Vietnamese law that consist of non-native timbers.  As highlighted above, LH2 is adjacent to the Nui Chua National Park which consists of tropical evergreen forest, that has been degraded by human encroachment but is considered to be natural habitat. The airspace of the windfarm is considered to be natural habitat given its utilization by avifauna and hence a no-net-loss outcome will be required for this species group.

Literature reviews and biological surveys for both windfarms have been completed and will be further assessed / confirmed in the update of the ESIAs (see ESAP # 1 & 10). The survey results identified a total of 25 bat species, including one species of Vietnam endemic bat being Griffin's Leaf-nosed Bat (Hipposideros griffini) IUCN NT. Twelve IUCN LC listed bats do have flight characteristics that mean they will fly in open spaces making them susceptible to windfarm operations.  Sixty-one species of IUCN LC listed birds were detected during the surveys, 6 of which are considered migratory. The Greater Spotted Eagle, Clanga clanga IUCN VU which is a soaring bird of concern to windfarm operations was predicted to occur but was not identified during survey. No other non-avifauna or flora considered to be conservation significant was detected.  The results of critical habitat assessment for the biodiversity values did not identify any species or habitats that met the critical habitat thresholds of PS6.

Considering cumulative impacts to biodiversity values, there are several existing windfarms around the two windfarms.  Cumulative impacts to local bird/bat populations is possible, however this is likely to be a low risk and will be further assessed / confirmed in the update of the ESIAs (see ESAP # 1 & 10). Coordination of monitoring activities to determine cumulative impacts is recommended.

The assessment of impacts according to the mitigation hierarchy identified that mortality of birds and bats was a potential risk to local populations, particularly for bats. These risks will be managed through procurement of turbines that allow mitigation (shut-down on demand, changes to cut-in speed and blade feathering).  The design of the transmission line will also be required to reduce electrocution and strike risks by adopting measures to reduce perching and optimize the location of wires.  The transmission line will use bird diverters to improve visualization of the line to flying birds.  For operations, the Project will be required to prepare prior to operations and implement a Bird and Bat Adaptive Management Plan (ESAP item # 10) .  The Plan will include measures to respond to any mortality events detected through operational monitoring with mitigations that manage windfarm operations at times of high bird/bat movement, if required.  In order to factor in any potential losses to electricity generation, a 2% Environmental Curtailment Loss Factor in the EYA is to be considered in the financial sensitivity analysis of the Project.

The other impacts considered included the loss, fragmentation and degradation of habitat (particularly for the protected area adjacent to the LH2 project site) and the disturbance and displacement of fauna. To mitigate these impacts, a Biodiversity Management Plan has been prepared to implementclearance protocols to stop clearing outside of the project footprint and education of the community and workforce to reduce risks of collection of forest products. Management of invasive alien species will also occur to reduce risks of transmission into the protected area (Nui Chua National Park).

As described under PS5 above, LH2 project involves acquisition of 7.53ha land causing economic displacement of 35 households and potential physical displacement of about 38 houses/structures (to be confirmed through detailed measurement survey) belonging to Raglai ethnic minority group in Vietnam. The Raglai community have been living for years in the South-Central Coast region. The Raglai population in Ninh Thuan Province is 70,366 people in 2019, or 47.29% of the total Raglai population in Viet Nam and constitute 82% of the Loi Hai commune. It was determined that Raglai people have ancestral presence in the project’s area and meet the definition of indigenous people as per PS7. Nevertheless, it is confirmed by the local authorities, village heads and surveyed households that the individual households have legal use rights over land parcels acquired for the project. No land or natural resources that are under traditional ownership or customary, collective use of the Raglai community will be impacted by the project nor will any cultural heritage be impacted by the project. Given that the project impacts were limited to land and assets under individual land use rights, as opposed to collectively held or used land under traditional ownership or customary use, the impacts will be mitigated in accordance with PS5 as described above taking into consideration their vulnerability and any cultural differences. An Indigenous People Plan (IPP) outlining the actions to minimize and/or compensate for adverse impacts in a culturally appropriate manner has been developed as a component of a broader community development plan under the REMDP as discussed in PS5 section above. As part of the ESAP 3 & 5, the company will follow an informed consultation and participation (ICP) process that involves systematic and continuous consultation with the affected Raglai communities in the project area. An ICP plan with detailed plan for consultations will be prepared for the project with clear timelines, activities, and outcome indicators leading up to ICP, as part of the Stakeholder Engagement Plan (ESAP # 3 & 5).