No Indigenous Peoples or areas of high archeological value have been identified within the project footprint, or nearby. As a result, Performance Standards (PS) 7 and 8 are not considered applicable to this project.  The project will develop a Chance Finds Procedures as part of its ESMS in the event archeological artifacts or areas are identified during construction.                        

This is a Category A project as per IFC's Policy on Environmental and Social Sustainability, as the company's business operations have the potential to cause significant adverse E&S risks and/or impacts that are diverse, irreversible, or unprecedented.

The project is adjacent to Divjaka-Karavasta National Park, a Candidate Emerald Site encompassing Karavasta Lagoon Ramsar Site, a highly important natural area. The project site also partially overlaps with the Karavasta Lagoon KBA/IBA designated for globally threatened bird species, important congregations of wintering and breeding waterbirds, and the endemic Albanian Water Frog. As such, a key E&S issue for this project concerns avoidance, monitoring, and management of potential adverse impacts on protected areas and biodiversity values.

Other E&S risks and impacts are expected to include: (i) adequacy of the E&S impact assessments; (ii) the company's & contractor's E&S management capacity & systems; (iii) contractor E&S management; (iv) stakeholder engagement & grievance mechanism; (v) labor & working conditions including Occupational Health and Safety (OHS), potential COVID19 impact, workers grievance mechanism, nondiscrimination & equal opportunities; (vi) emergency planning;  (vii) water availability; (viii) community H&S and project's use of security personnel; (ix) land acquisition; (x) potential impacts on sensitive biodiversity receptors with a particular focus on risks posed to avifauna by OHLs.                 

An Initial Technical, Environmental and Social Assessment was conducted before the project tender, commissioned by the Albanian Ministry of Infrastructure and Energy (MIE). The purpose of the assessment was to identify and assess aspects and features of the site that required to be further investigated through a full Environmental and Social Impact Assessment. On project award, Voltalia engaged 'Abkons,' a consulting firm based in Albania, to undertake an ESIA study to meet national and international requirements including IFC PSs. Environmental and social risks and impacts identified in the ESIA prepared in 2021 and 2022 are summarized in a non-technical summary.

The E&S disclosure package shared with this E&S review summary comprises a project focused ESIA and Non-Technical Summary, Stakeholder Engagement Plan, Livelihood Restoration Plan, Guide to Land Acquisition and Compensation, Ecosystem Services Assessment, 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 IESC consider the final E&S disclosure package fit-for-purpose for a project of this scale and character, i.e., covering all relevant E&S risks and impacts at an appropriate level of detail.

The project's environmental and social management system (ESMS) is currently under development. However, a project ESMMP has been prepared, which outlines key mitigation measures identified via the ESIA and processes that Voltalia will implement during the project construction and operations phases to meet national and IFC E&S requirements. As per ESAP#1, Voltalia will develop and implement an ESMS appropriate for the scale & complexity of the project, per the general requirements of IFC PS1. The ESMS will include an overarching environmental and social policy specifying that the project will comply with IFC PS and EHS Guidelines, applicable laws and regulations, including those laws implementing host country obligations under international law. The ESMS will include all necessary policies, procedures, and plans (including a construction environmental & social management plan) to be developed and executed to address the mitigation and compensation measures identified through the ESIA and the supplementary studies. Contractor/sub-contractors will be contractually bound to follow applicable E&S requirements, including IFC PS and WBG EHS Guidelines, and implement those portions of the ESMS that fall within its scope of work.

Before commercial operations, as per ESAP#2, Voltalia will develop and implement an Operations Environment & Social Management Plan (OESMP) acceptable to IFC and consistent with the project ESIA, IFC PS, WBG EHS Guidelines and national requirements. The OESMP will include a suite of sub-plans, 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).

Voltalia will ensure that sufficient staff and contractor resources are allocated to manage E&S performance at all times. At a corporate level, Voltalia's E&S Team consists of an E&S Corporate Manager who reports to the Health, Safety, Environment, and Social Director (who is part of the ExCom). At a regional level, Voltalia has engaged a Regional E&S Officer (Europe and Africa Region). This Regional Officer will be supported by an E&S Officer (Europe-focused). At a project level, to oversee construction activities, Voltalia has engaged an HSES Manager, Environmental Coordinator, Social Coordinator, Health and Safety Coordinator, and a Community Liaison Officer and has contracted biodiversity, archaeological, and resettlement experts for additional support. Voltalia will ensure its contractor/sub-contractors appoint appropriate counterparts to these staff to ensure sufficient oversight of the entire construction labor force. During the operational phase, an HSES coordinator will be engaged to implement the ESMS. Voltalia will hire expert consultants to undertake E&S monitoring during construction and operations, as necessary. There will also be an independent E&S monitoring consultant engaged during the construction and early operations phases to monitor the ESMS, and E&S Action Plans implementation and make recommendations to the Lenders on any corrective measures needed.

To manage E&S risks related to procurement and supply chain, Voltalia has developed formalized processes, including vendor prequalification and selection procedures, a PV Module Supply Chain Risk Assessment, an Ethics Guide, and a Code of Conduct, which defines Voltalia's E&S commitments (including commitments relating to labor practices and human rights). Voltalia incorporates these commitments into the contracts it signs with its suppliers.

As part of the ESMS (ESAP#1 and #2), EHS monitoring requirements will be included in the CESMP and OESMP for the construction and operation phases of the project, including monitoring frequency, performance indicators, and targets. Voltalia will oversee the implementation of the project's monitoring actions required and control contractor and subcontractor E&S performance (refer to PS2). Furthermore, Voltalia will hire a nationally accredited E&S consultant to undertake any necessary monitoring activities required by the local authority.                                      

Most of the workforce during construction and operations is anticipated to be Albanian nationals, the majority of which are expected to be from the local region. At the peak of the construction phase, approximately 200 - 300 workers are expected to be onsite; however, the average number of workers throughout the c.14-month construction period will vary. The workforce requirement during operations is anticipated to be approximately 20 people.

Voltalia has established several corporate-level human resource (HR) policies and procedures that define its commitment to international labor laws and conventions. Voltalia's project-specific human resources processes are currently under development. As per ESAP#3, Voltalia will update and implement the existing country and project level human resources policies and procedures according to IFC PS2, International Labor Organization (ILO) requirements, and local labor codes applicable to all project workers (including contractors/sub-contractors). The updates to the policy/procedures will stipulate terms of employment and will define the company’s commitments concerning non-discrimination and equal opportunity, anti-sexual harassment, a proactive approach to employing women on the project, working conditions (including occupational health, safety, and security), equal facilities for men and women workers, employee termination, retrenchment, freedom of association, and collective bargaining, prohibition of child and forced/bonded labor, disciplinary action. Terms of employment will meet national and IFC PS2 labor requirements and be included in employee contracts.

Furthermore, Voltalia will update its existing code of conduct to apply to all workers and contractors and subcontractors and to include elements on labor and working conditions, interaction with affected communities, behaviour after working hours in the labor accommodation, etc. All project workers will receive regular training relating to the project's human resources policy, including mandatory training on the Worker Code of Conduct. The project’s HR processes will be overseen by Voltalia’s Corporate team, supported by local HR resources to be engaged by the project. 

Voltalia has developed a project-level worker's grievance mechanism (WGM). The WGM covers all project workers, including subcontractor personnel and third-party workers, irrespective of their employer or employment status. As per ESAP2, Voltalia will revise its worker's grievance mechanism and implement it, in accordance with IFC's PS2. The WGM will be made available to all project workers, irrespective of their employer. The company will disseminate information about its use to the workforce (in a language the workers understand). The WGM is to include specific considerations related to the sexual harassment/gender-based violence grievances. This should include multiple entry points to raise and address allegations including options to report anonymously if preferred. Voltalia will appoint an adequately trained (included detailed knowledge of Albanian Labor Law and sexual harassment) grievance officer to attend the workers complaints and coordinate the implementation of the WGM.

Albania has ratified the ILO core labor standards, and they are incorporated into the national labor laws. Hereby the core labor standards, as defined in IFC PS2, are part of the national requirements that Voltalia is required and committed to following. The labor code of Albania forbids forced labor. Voltalia and its contractors/sub-contractors will not employ anyone under the age of 18 years on the project, and the employee's age will be verified and recorded during the recruitment process. During the project's construction phase, Voltalia will closely supervise their contractor/sub-contractors' compliance with the requirements defined within their HR procedures and conduct semi-annual monitoring to assess adherence to local labor laws and project labor and working conditions commitments. If non-compliances are identified, Voltalia will implement appropriate corrective measures. To facilitate compliance monitoring, Voltalia will develop 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, Voltalia will include legally binding obligations in EPC contract (and subcontractor contracts) to ensure compliance with the requirements of all relevant E&S and H&S plans contained within the project ESMS as well as national and IFC PS (ESAP#4). 

As most project workers are anticipated to reside locally, and the project site is situated in relative proximity to regional centers, a worker's camp is not required to be established. It is expected that non-local workers will be accommodated in hotel/apartment accommodation in Fier (population of approx. 120,000). However, suitable hotels/apartments are yet to be identified. As per ESAP#5, Voltalia will develop a worker accommodation strategy that will define mechanisms to ensure accommodation facilities provided to project workers, irrespective of their employer, align with IFC's and EBRD's Good Practice Note on Workers' accommodation. Voltalia will periodically review and monitor the condition of the accommodation facilities. Furthermore, the requirements defined within the project's worker code of conduct (ESAP#3) shall be extended to all workers while accommodated by the project, and the project’s community grievance mechanism shall be made available for any grievances related to offsite accommodation (ESAP#14)

Voltalia has a corporate Occupational Health and Safety Management System (OHS MS) accredited with ISO 45001 and has developed project-specific plans/procedures, including establishing an 'HSE Minimum Requirements' procedure defining project OHS obligations applicable to all workers. Voltalia contractually requires its contractors/sub-contractors to adhere to its 'HSE Minimum Requirements' and develop and implement a site-specific OHS MS, including plans and procedures of a scale appropriate to their scope of work. Voltalia will assess the adequacy of their contractors/subcontractors OHS MS and shall ensure any deficiencies identified are addressed before their mobilization to the project site. All workers will complete basic OHS training, and supervisory staff and employees undertaking high-risk activities will complete specific OHS training.                                         

The project is estimated to generate 265,000 MWh per year, with greenhouse gas emission reductions of c. 26,205 tCO2 equivalent per year using a grid emission factor of 0.1469 tCO2e/MWh.

Water requirements are expected to be low during construction and operations. Construction water will be required for dust suppression, concrete production, and domestic usage. The primary water use during operations will be for cleaning the PV modules. Based on the project ESIA, the estimated water consumption during the construction phase is expected to be approximately 8592 m3. During the operation phase, the estimated water consumption is estimated at 1,200 m3 per year. To minimize water consumption during operations, the PV modules will be cleaned monthly using dry cleaning techniques. Wet cleaning of PV modules is only anticipated to be required two to four times per year. Water will be sourced offsite, from locally permitted water suppliers, or from municipal water sources.

The project site contains an extensive network of irrigation channels constructed between 1946 -1983 as part of a reportedly unsuccessful agricultural scheme. The irrigation-drainage network is currently not fully functional, and only a small portion of the agriculture land in the area benefits from these services due to limited maintenance, and several of the channels are filled with sediment and blocked by other materials. Earthworks may disrupt the channels and may increase erosion, especially during rainfall events, which may increase the suspended sediment concentrations and pollute water resources. Furthermore, the OHL alignment crosses the Semani River, and two OHL transmission towers will be constructed near this river. To mitigate against potential impacts, as per ESAP#6, Voltalia will develop an Irrigation and Drainage Preservation Procedure defining specific mitigation and management measures related to any channel improvement works or temporary diversions required during construction activities. The procedure will detail processes to engage with relevant authorities (as necessary) and communities during implementation of this procedure. The procedure should complement the biodiversity management plan as it relates to maintaining the biodiversity values of the drainage network. Additionally, as part of the project ESMS (ESAP#1), Voltalia will develop an Erosion and Sediment Control Plan, defining measures to prevent and/or reduce impacts and control risks of erosion and sedimentation impacts on existing water bodies in the project area.

The project is expected to generate minor to moderate amounts of pollution to air, noise, and soil, which are anticipated to be readily mitigated through the implementation of standard pollution prevention and control measures, defined within the project ESMS.

Volumes of liquid, solid, and hazardous waste generated by the project during construction and operations are expected to be low. Domestic wastewater generated will be collected in a septic holding tank 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 Voltalia.  

The project ESIA identifies that nearby municipality waste disposal facilities (including wastewater, non-hazardous and hazardous disposal facilities) are of a poor standard and are unlikely to be suitable locations to dispose of project waste. As part of the ESMS (ESAP#1), Voltalia 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. Voltalia will only approve facilities for use on the project if they are suitability licensed and wastes are disposed of and treated safely for human health and the environment. Furthermore, Voltalia 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, Voltalia will develop a Community Health, Safety, and Security Management Plan designed to manage such risks and impacts effectively. Additionally, an Emergency Preparedness and Response Plan (EPRP) will be developed incorporating risks to the health and safety of the affected communities and other stakeholders.

Hydrodynamic modeling for the proposed PV site (base case) shows that the site will be flooded from a 24-hour storm. The most conservative modeling scenario (modeling over a 24-hour storm hyetograph with a return period of 1 in 100 years, with a nearby pumping station not functional) resulted in a flood depth of up to 85 cm. The ESIA assess flood risks to be minor; however, several mitigation measures have been defined, including the requirement for Voltalia to undertake periodic maintenance works on the drainage channels inside the PV plant.  The EPRP will included considerations relating to flood related emergency scenarios.

The PV plant and OHL components will be transported from Port of Durrës, situated 96.9 km from the construction site, by trucks through the National Highway and then directed to the site through secondary roads. Risks related to this transport have been assessed within the ESIA. Furthermore, Voltalia has completed a Traffic and Transport Survey Report and Social Impacts Register to identify the most appropriate transport routes to be utilized by the project. Additionally, Voltalia has developed a Traffic Management Plan (TMP), including a traffic risk assessment, which defines appropriate traffic management and accident prevention measures to mitigate any impact on local communities and general road users. Voltalia will assess local road conditions and complete a dilapidation survey of structures/infrastructure adjacent to community roads. Findings from the survey will be utilized to update the traffic risk assessment contained within the TMP (ESAP#7). Voltalia will ensure that any damage resulting from project activities is repaired promptly and that local roads used by the project are left in original or better condition upon the completion of construction activities.

The design of the overhead line route underwent several revisions to ensure that it does not directly impact any residential or commercial buildings. As all land plots located close to the OHL are agriculturally zoned (hence building restrictions are already in place), no easement restrictions will be established. However, should land plots designated as urban land be identified during the land entry process, a 25m wayleave will be established. Potential impacts on community health, safety, and security specific to the OHL, including electric and magnetic fields, the potential for electrocution, lightning strike, fire, and issues associated with unauthorized access and vandalism, were assessed within the ESIA. Appropriate mitigation measures have been recommended within the ESIA, with no significant residual impacts anticipated. 

The entire perimeter of the PV site will be fenced, and entry to the project site will be regulated. Voltalia will engage a security contactor to provide unarmed security personnel during the construction and operational phases of the project. The OHL construction contractor will also hire unarmed security personnel during construction. Voltalia will ensure that their security contractors' personnel are appropriately screened, trained and competent for their scope of work.   As part of the ESMS, Voltalia will develop and implement a Security Management Plan (SMP) aligned with IFC PS4, which will be applicable to Voltalia and its contractors/sub-contractors. This plan will include a security risk assessment and an, incident reporting and investigation process. The SMP will include a security selection/evaluation procedures and security code of conduct to guide the interactions between security personnel, workers and community members. The SMP will include provisions for systematic training regrading GBV, human rights and use of force. All security incidents will be recorded, investigated, and corrective actions implemented. 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 (including trucking, and other community security concerns).              

The project is located in the Divjaka-Karavasta region of Albania, which falls within the Illyrian deciduous forests terrestrial ecoregion of the Palearctic Mediterranean forests, woodlands, and scrub biome (as designated by WWF). The Divjaka-Karavasta region is characterized by coastal lagoons, marshes, reedbeds, estuaries, dunes, and forests.  Karavasta is the largest wetland in Albania, with the Karavasta Lagoon forming the largest part of the complex and being separated from the Adriatic Sea by the sandy bar of Divjaka covered with pine forests.

Types of natural habitat that overlap with the project are coastal marshes and reedbeds (Salicornia) at the PV site and riparian woodlands along the OHL alignment. In contrast, the majority of the project infrastructure lies within degraded areas of cultivated land, pastures, and built-up areas. The PV site is predominately composed of the Salicornia habitat and a pre-existing irrigation-drainage channel network. The OHL route will pass mostly through agricultural land, crossing the Semani River and its riparian zone dominated by poplar and willow trees at a single location. The PV site lies adjacent to Divjaka-Karavasta National Park (a candidate Emerald Site) and has a partial overlap of approximately 50% with Karavasta Lagoon Key Biodiversity Area (KBA) and Important Bird and Biodiversity Area (IBA).

Priority biodiversity values associated with the project include the Salicornia habitat at the PV site, riparian woodland habitats along the OHL route, amphibian, crayfish, fish, mammal, and bird species. Of these, the Albanian Water Frog (IUCN Red List – Vulnerable), Prespa Barbel (IUCN Red List / Albanian Red List – Least Concern), , Albanian Red List – Critically Endangered), European Eel (IUCN Red List – Critically Endangered), and Bleak (IUCN Red List – Least Concern) are Critical Habitat (CH) biodiversity values. IFC Natural Habitat No Net Loss (NNL) requirements will apply to all priority biodiversity, while Critical Habitat Net Gain (NG) requirements will apply to the above-listed CH values.

The project has in place a construction Biodiversity Management Plan (BMP), which sets forth mitigation measures to avoid and minimize risks to CH and priority biodiversity values and is being implemented under the supervision of the project's appointed biodiversity expert. For the Albanian Water Frog, the BMP includes measures to ensure construction works will be undertaken in the dry season, new drainage channels will be built to allow animal movement, and frogs will be moved to immediate surroundings in the event of imminent impacts from construction activities. At the PV site, NNL of the Natural Habitat will be achieved through implementation of good international industry practice (GIIP) captured in project management plans and procedures, including implementation of erosion, sedimentation, and drainage control measures. As indicated in ESAP#11, the operations-phase BMP will further include detailed reinstatement actions and restoration measures for the coastal marsh and reedbed (Salicornia) habitat. Impacts on other priority values at the PV site will be avoided through establishing 'no-go areas' around active nests of breeding birds and burrows of mammals, between drainage channels, around waterbodies, among other places. The natural drainage at the site will be enabled through maintenance of existing drainage channels.

Along the OHL route, construction in riparian woodlands has been avoided in design, so there will be no impacts on terrestrial Natural Habitats. There are several bird species identified to be at risk of collision with the transmission line. To minimize risks of impacting priority biodiversity values using the airspace and which are also subject to Natural Habitat NNL objectives, fixed firefly-style bird flight detectors will be installed and staggered along the entire OHL from the onsite substation to the grid connection to ensure maximum coverage. A bird-safe design has been incorporated in placing the pylons to minimize the risk of collision and electrocution. In the operation phase of the project, Voltalia will implement a post-construction fatality monitoring (PCFM) program based on GIIP to monitor bird flight activity, assess the effectiveness of mitigation, and identify any further measures to be taken in line with an adaptive management approach (ESAP#12). Voltalia will contract an internationally recognized and specialized consultancy to design and develop a fatality monitoring program in collaboration with a local consultancy and incorporate it into its operations-phase BMP.

As part of their overall biodiversity screening and assessments, Voltalia engaged with local and national authorities, as well as Albanian conservation NGOs. With respect to Karavasta National Park Candidate Emerald Site, Voltalia engaged and consulted with representatives of the National Agency of Protected Areas (NAPA) and Divjaka-Karavasta National Park on the outcomes of the Appropriate Assessment Screening with respect to the Emerald Site. Voltalia also engaged with BirdLife International and their local partner to obtain their views and feedback concerning the project's overlap with the Karavasta Lagoon KBA/IBA, as well as the scope of the project's biodiversity assessment and mitigation strategy. Voltalia will continue consulting with the National Park authorities, and Birdlife International and their local partner, to develop and/or support additional conservation programs for Divjaka-Karavasta National Park and Candidate Emerald Site.

Voltalia has developed a draft Biodiversity Action Plan (BAP), which outlines the project’s biodiversity mitigation strategy, focusing on actions for CH species. In addition to measures in the BMP aimed to achieve NNL, actions with respect to NG include creating over-wintering and additional aquatic habitats for the Albanian Water Frog. The draft BAP also makes provision for continued engagement with relevant stakeholders (e.g., Divjaka-Karavasta National Park authorities, BirdLife International, and local partners) to implement and support additional conservation actions in the protected areas. As indicated in ESAP #13, the BAP will be finalized and updated periodically as the project progresses.                   

A Stakeholder Engagement Plan has been developed for the project, consistent with IFC's PSs. Voltalia implemented a robust stakeholder engagement program throughout the ESIA process, including in-person meetings with key local stakeholders. The SEP includes the mapping, identification, and analysis of stakeholders, including vulnerable groups and gender sensitivity.

Voltalia has implemented consultation and information disclosure activities as per the SEP. Voltalia started its engagement with local communities, local authorities, NGOs, and other local representatives in 2020. This engagement included a series of public hearings to disclose the national EIA. The international ESIA, NTS, and other project documents were disclosed in June 2022, and subsequently, another round of consultation was organized with interested and potentially affected stakeholders. Voltalia’s disclosure included soft and hard copies of the ESIA, NTS, LRP, SEP, and other relevant project documents. The project documents were disclosed in Albanian for a minimum of 2 weeks prior to the consultation events to ensure informed and meaningful participation of stakeholders. The consultation events could be reached via video conference, and participants had the opportunity to share feedback before, during, and after the event online. Several of the consultation events were attended by the Lenders' IESC to ensure that the organization and management of the events followed international best practice and IFC requirements. The engagement activities during the ESIA and pre-construction phase were adequate. Engagement related to the LRP was initiated in September 2021 with the socio-economic surveys, and disclosure of the final LRP document concluded in September 2022. Disclosure of project documents is in line with IFC's requirements. All project documents, including updates based on community feedback, are available on the project website (https://karavastasolar.com/ ).               

Karavasta Solar Sh.p.k

NUIS number : M02020001J

 Ndertesa ETC, Bvd. Bajram Curri, Kati 9, Zyra 3

Tirana, Albania, +355 44 81 33 64

info.voltalia@voltalia.com

www.voltalia.com