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 majority of the project infrastructure is located within the Natura 2000 site’s Valea Calma?uiului Site of Community Importance (SCI, designated under the EU Habitats Directive), and Valea Calma?uiului Special Protection Area (SPA, designated under the EU Birds Directive). The SPA is designated for breeding and migratory bird species. As such, a key E&S risk for this project concerns avoiding, monitoring, and managing potential adverse impacts on birds during wind farm construction and operations.

 PS 1 - Assessment and Management of Environmental and Social Risks and Impact

The company acquired the project from a previous developer in 2020. As per Romanian regulations, initial environmental permitting for each sub-project was completed between 2010 and 2012, with an update completed in 2017. The initial permitting included the development of a Strategic Environmental Assessment and an Appropriate Assessment. The permitting process included the development of EIAs for each of the five subprojects, which were submitted to the national authorities. The project design underwent several modifications between 2021 - 2023. Following these changes, re-permitting was initiated with a favorable Environmental Final Decision for all sub-projects issued by the Environmental Protection Agency in Buzau. Additionally, the company engaged 'ERM,' an international consulting firm, 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 2023 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, Biodiversity Impact Assessment, Critical Habit Assessment, and Framework Environmental and Social Management Plan. The E&S disclosure documents have been conducted in accordance with IFC PS. Following multiple exchanges and updates during the due diligence phase, IFC considers the 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. Further measures required to address any outstanding E&S risks in subsequent stages of the project are outlined in the ESAP and described below. 

Construction and operations phase E&S management and monitoring responsibilities will be shared between the company and its EPC and O&M contractors. The project's sponsors have corporate-level E&S policies applicable to the project; however, the project's construction-phase environmental and social management system (ESMS) is currently under development. A project ESMP has been prepared, which outlines key mitigation measures identified via the ESIA and processes that the company will implement during the project construction to meet national and IFC E&S requirements. As per ESAP#1, the company will develop and implement a construction phase 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 the company's E&S objectives and principles and include relevant plans/procedures, including but not limited to pollution prevention, waste management, water management, community health, safety, and security, emergency preparedness and response, labor management, security management, transport and traffic management, biodiversity management plan, cultural heritage management, supply chain, and stakeholder engagement aligned with IFC PSs, relevant WBG EHS Guidelines and local requirements. The ESMS will also include a Commitments Register.  The Commitments Register will list all environmental and social commitments made by the sponsors in the ESIA documentation and through acceptance of the national permits and legal agreements stipulated with the Government of Romania.

The company will require its EPC contractor to develop and implement its own Construction ESMS, including policy statements, management and monitoring measures, and aspect-specific management plans applicable to the EPC activities and tailored to the project's construction methodology, engineering design, and commissioning phase. The structure and content of the EPC ESMS will be fully aligned with the company’s ESMS and the adopted project-specific standards (ESAP#2). The EPC’s 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 Construction ESMS that fall within its scope of work.

Before commercial operations, as per ESAP#3, the company will develop and implement an Operations Environment & Social Management System (OESMS) consistent with the project EIA, IFC PS, WBG EHS Guidelines, and national requirements. The OESMS will include an Operations Environmental and Social Management Plan (OESMP), which will address all relevant E&S risks, including, at a minimum, pollution prevention; noise management, water management; hazardous materials; waste management, emergency response; community health, safety & security (including shadow flicker, ice/blade throw); biodiversity management; environmental monitoring; stakeholder engagement (including grievance management). The company will require its O&M contractor to develop and implement an OESMP aligned with the company’s.

The company will ensure that sufficient staff and contractor resources are allocated to manage E&S performance at all times. During the construction phase, the company shall employ at a minimum (either as its staff or contracted as needed) a suitably qualified and experienced project Environmental, Social, Health and Safety (ESHS) Manager, Community Liaison Officer(s), Health and Safety Supervisor(s), Land Acquisition and Management Specialist, Biodiversity Specialist, and Cultural Heritage Specialist. The company shall require its EPC to appoint appropriate counterparts to these staff (ESAP#4). During the operational phase, the company will engage an ESHS Manager and Biodiversity Specialist to implement the ESMS. It shall require its O&M contractor to employ adequate support staff to ensure E&S oversight of their activities and implement applicable project commitments (ESAP#5).

As part of the ESMS (ESAP#1 and #3), E&S monitoring requirements will be included for the construction and operation phases of the project, including monitoring frequency, performance indicators, and targets. The company will oversee the implementation of the project's monitoring actions required and control contractor and subcontractor E&S performance (refer to PS2). Furthermore, the company will hire a nationally accredited E&S consultant to undertake any necessary monitoring activities required by the local authorities. Additionally, an independent E&S monitoring consultant will be engaged during the construction and early operations phases to monitor the implementation of the ESMS and E&S Action Plans and make recommendations to the IFC on any corrective measures needed.

PS 2 – Labor and Working Conditions

Most of the workforce during construction and operations is anticipated to be Romanian nationals, most of whom 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 construction period will vary. The workforce requirement during operations is anticipated to be approximately 20-30  people.

The project sponsors have developed several policies defining their commitment to adhering to international labor laws and regulations at a corporate level, which will apply to the project. The company’s project-specific human resources processes will be defined within a labor-management plan (LMP) currently under development. As per ESAP#06, the company will update and implement the LMP to include project-specific level human resources policies according to IFC PS2, International Labor Organization (ILO) requirements, EU and Romanian labor codes applicable to all project workers (including contractors/sub-contractors). The LMP will define the company’s commitments concerning labor and working conditions, equal opportunities and non-discrimination, anti-sexual harassment and gender-based violence and harassment (GBVH), prohibition of child and forced labor, whistleblower protection, freedom of association, and collective bargaining. The company will develop an enforceable code of conduct applicable to all workers (including worker conduct within project worker accommodation facilities), which will specifically include mitigants related to GBVH. All project workers will receive regular training relating to the project's human resources policies, including mandatory training on the Worker Code of Conduct. 

The company will ensure its EPC and O&M contractor provide all workers, including sub-contractor workers, with written documentation concerning the terms and conditions of their employment, including their rights under local labor regulations, e.g., in relation to hours of work, wages, overtime compensation and so forth, as per IFC PS 2 requirements. It is unlikely that workers’ unions will be involved in the project as the main concentration of workers will be onsite during a short-lived construction period only; as noted above, the operations staff will be small. Nonetheless, the company will not prevent workers from seeking to join unions or other workers’ organizations.

As per ESAP#07, the company will develop and implement a project-level worker's grievance mechanism and implement it, in accordance with IFC's PS2. The WGM will be available to all project workers, regardless of their employer or employment status. 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 sexual harassment/gender-based violence grievances. This should include multiple entry points to raise and address allegations, including options to report anonymously if preferred. The company will appoint an adequately trained grievance officer (including detailed knowledge of Romanian labor law and sexual harassment) to attend to the worker complaints and coordinate the implementation of the WGM.

Romanian has ratified the ILO core labor standards, which are incorporated into the national labor laws. Hereby the core labor standards, as defined in IFC PS2, are part of the national requirements that the company is required and committed to following. The labor code of Romania forbids forced labor. The company and its contractors/sub-contractors will not employ anyone under 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, the company will closely supervise their EPC contractor's (and their sub-contractors’) compliance with the requirements defined within their LMP and conduct semi-annual monitoring to assess adherence to local labor laws and project labor and working conditions commitments (ESAP#08). If non-compliances are identified, the company will implement appropriate corrective measures. To facilitate compliance monitoring, the company will develop a Contractor Management Plan defining its approach to managing the EHS performance of its 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 (ESAP#09). Furthermore, the company will include legally binding obligations in EPC and O&M contracts (and subcontractor contracts) to ensure compliance with the requirements of all relevant E&S and H&S plans contained within the project ESMS and national and IFC PS. 

The project's accommodation strategy for non-local workers is still being finalized. 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. Non-local workers are expected to be accommodated in hotel/apartment accommodation in Buzau (population of approx. 100,000). However, suitable hotels/apartments are yet to be identified. As per ESAP#10, the company will develop a worker’s accommodation policy establishing the basic requirements that any accommodation implemented as part of the project (including contractors and subcontractors’ facilities) should comply with, in line with Romanian regulations, IFC PS2 requirements and align with IFC's and EBRD's Good Practice Note on Workers' accommodation. The company will periodically review and monitor the condition of the accommodation facilities. Furthermore, the requirements defined within the project's worker code of conduct (ESAP#06) 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 (refer to the stakeholder engagement section). The policy will include specific considerations related to harassment/gender-based violence.

The company 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 the necessary plans and procedures commensurate to the project risks (ESAP#11) and will apply to all project workers including sub-contractors. Workers will complete basic OHS training, and specific training will be provided for staff undertaking high-risk activities.

PS 3 - Resources Efficiency and Pollution Prevention

The project is estimated to generate 1,369 GWh per year and avoid approximately 180.000 tons of CO2e annually.

The volume and source of water for the project’s construction phase are yet to be defined (two options have been identified – sourcing from municipal sources and trucked to the site or groundwater abstraction). As per ESAP#12, the company will complete a water resources assessment study, calculating project water needs and assessing the viability of potential water supply options, including for associated and ancillary facilities. If groundwater abstraction is the preferred project water source option, the company will verify whether increases in groundwater abstraction attributed to the project could impact third parties' access to water. If potential impacts are identified, the company will implement appropriate mitigation measures (to be proposed and accepted by IFC), in addition to any permit conditions before water abstraction. 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. The project will establish an onsite concrete batch plant to provide concrete for the turbine foundations. A pollution prevention plan, including a batch plant control sub-plan addressing air emissions and liquid effluents, erosion, and plant decommissioning, will be developed and implemented within ESMS (ESAP#1).

Noise, and shadow flicker impact assessments were conducted as part of the project ESIA. Noise from construction activities is not expected to be a significant issue for this project, as there are no residential receptors within 600 m of a turbine location, and construction activities will be limited to daylight hours. Noise modeling shows operational noise levels will remain within Romanian and WBG noise thresholds at the nearest sensitive receptors. The completed shadow flickering assessment identified exceedances of the WBG Guidelines threshold limits of 30 mins/day or 30 days/year (worst case), which could be expected at 988 receptors. As per ESAP#13, shadow flicker curtailment units will be fitted to turbines expected to cause flickering effects above the WBG thresholds, and mitigation measures will be implemented if these criteria are exceeded.

The project is anticipated to generate significant volumes of solid waste during construction (and more limited volumes of liquid and hazardous waste), with negligible volumes of waste expected to be generated during operations. Solid waste disposal will be managed through licensed third-party waste contractors approved or contracted by the company. The project ESIA identifies that there are no licensed hazardous disposal facilities within the project area and limited general waste facilities. As part of the ESMS (ESAP#1), the company will develop and implement a Waste Management Plan (WMP) for the project that is aligned with local legal requirements, IFC PS3, and WBG EHS general guidelines. The WMP 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. The company 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. The EPC & O&M Contractors will develop and implement WMPs aligned with the company’s (ESAP#2 and 3).

PS 4 - Community Health, Safety, and Security

Risks and impacts to the project's host communities and the public were assessed during the ESIA process. Based on the findings, as per ESAP#1, the company will develop a Community Health, Safety, and Security Management Plan to manage such risks and impacts effectively, including appropriate mitigation measures to be implemented by its contractors and subcontractors. A worker's code of conduct (including worker conduct within project worker accommodation facilities) will be established (ESAP#6), clearly defining project commitments and individual work responsibilities, including specific measures to address GBVH risks. Additionally, an Emergency Preparedness and Response Plan (EPRP) will be developed, incorporating risks to the health and safety of the potentially affected communities and other stakeholders. The EPRP will be developed in consultation with affected communities, including participation in defining measures to be adopted in scenarios affecting these people.

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 the Port of Constanta. Additional risks relate to transporting site workers, construction suppliers, materials to produce concrete, and potentially water. Risks associated with this transport have been considered within the ESIA. Furthermore, the company has completed a preliminary road transport route study, including assessing the road networks to transport turbine components. The road survey identified several road sections that require to be upgraded. As per ESAP#01, the company will require its EPC to develop a Traffic and Transportation 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, identify structures (residential and public) that could be impacted, and determine if specific control measures are required (ESAP#2).  The company will ensure that any damage resulting from project activities is repaired promptly and that local roads used by the project and any structures adjacent to the road affected by the project are left in original or better condition upon the completion of construction activities.  

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 371 m) or the overhead line, and no communities live within the project site. During operations, agricultural activities, including herding of animals, will continue 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 the project poses. These measures will be communicated as per the SEP.

The company’s EPC contractor will engage a security contractor 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 determined. The company will ensure that the security contractors' personnel are appropriately screened, trained, and competent for their scope of work.   As part of the ESMS, the company will develop and implement a security management plan aligned with IFC PS4, which will be applicable to the company and its contractors (and their sub-contractors). The security management will include security selection/evaluation procedures and a security code of conduct to guide the interactions between security personnel, workers, and community members. The plan will include provisions for systematic training regarding GBV and the use of force. All security incidents will be recorded and investigated, and corrective actions will be 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 grievances related to security. 

PS5 - Land Acquisition and Involuntary Resettlement

The project consists of five sub-projects located within the administrative territory units (ATU) of Costesti, Gheraseni, Smeeni, Luciu, and Tinesti communes in Buzau County. The five communes own a total 6000 ha of pastureland, some of which is leased to farmers who use the land for grazing (sheep, goats, and cattle). Grazing occurs year-round, with increased activity between April and June. The ESIA identified approximately 200 farmers leasing pastureland across the AoI in the five administrative territory units, with the remaining land not in use generally due to its poor quality.

The project will not result in any physical displacement. All land required for the project, with the exception of land needed for the substation and five OHL pylons, is public pastureland owned by the local councils, which has been secured via voluntary lease agreements. The agreements were concluded for the respective land plots in their entirety (a total of 2777 ha) and not just for the surface to be permanently occupied by project components (approximately 44.5 ha) or temporarily impacted by construction activities (147.8 ha). The surface of pastureland permanently occupied by the project constitutes less than 2.5% of the total land plots leased for all sub-projects. The remaining public land will continue to be used by the local councils as pastureland. Moreover, the councils have the right to conclude any further contractual agreements regarding farming activities of the remaining land as long as these do not affect the wind conditions on the land, having only to notify the developer and ensure the obligations of the usufruct agreement are assumed by the respective third party. Land has been secured by the project for 30 years via voluntary lease and purchase agreements concluded with public and private landowners. The lease agreements include the possibility of a 15-year extension by the decision of both parties.

The actual number of affected persons (APs) who lease and use the land, together with any potential impacts on ecosystem services and access to natural resources, is currently unclear (however, it will be quantified during the development of a project-specific Livelihood Restoration Plan (LRP); refer to ESAP#15). There are temporary animal shelters (seasonal shelters; these are basic structures, some in poor condition) and wells present on the pastureland that might be affected by the project (some structures may require to be relocated due to overlaps with permanent project infrastructure). Additionally, between 1st of March and the 15th of April each year, farmers who lease pastoral land in the project area apply to The Agency for Payments and Intervention for Agriculture (APIA), which provides agricultural subsidies with certain conditions. APIA implements a satellite detection system and applies sanctions if the land is not managed in line with the payment claims for the respective agricultural year. Lack of timely coordination between the company and the local councils in relation to the exact surfaces that construction works will impact can lead to farmers being fined and/ or risking losing all their subsidies for a period of 3 years. The penalty would apply to all the subsidies received by the respective farmer, including those obtained for arable plots.

As per ESAP#14, the company will develop a Land Acquisition and Resettlement Framework (LARF) aligned with PS5 to be applied by the project. The LARF will define principles and procedures for land acquisition, impacts on assets, assessment, and compensation of impacts on livelihoods, ecosystem services, and access to natural resources to be applied by the project and will include a register identifying all potentially affected persons (including landowners and users) established by a review of administration records and community interviews.

As per ESAP#15, the company will engage a suitable, qualified, and experienced consultant to develop and implement an LRP aligned with national law and IFC PS5. The LRP will be designed to capture all potential impacts on land (defined within the LRF), related to the project’s construction and operations phases. The LRP should include a detailed socioeconomic baseline that reflects the existing livelihood status and the standards of living of APs, including a comprehensive land and natural resources uses and users survey; a commitment to continue compensatory measures to APs until livelihoods have been restored, which may take multiple seasons, depending upon the extent of land disturbance; direct engagement with APs to discuss their eligibility and entitlements, special assistance measures that will be provided to vulnerable groups, and the provision of preferential access to project-related employment and vocational skill development opportunities. Additionally, the LRP will include mitigation measures to address the potential reduction or loss of government agricultural subsidies, including formal and informal land users before accessing the land.

As per ESAP#16, the company will report on its monitoring of LRP implementation to IFC through the submission of annual monitoring reports during the construction and operations periods up until all the LRP activities are completed. The company will engage a qualified third-party independent consultant who was not associated with the LRP previously to conduct a completion audit three years after all the LRP activities have been deemed complete. The completion audit will include, at a minimum, a review of the LRP mitigation measures implemented by the company, a comparison of implementation outcomes against agreed objectives, and a conclusion as to whether livelihoods have been restored to pre-project levels or better or supplemental action is required (ESAP#17).

A grievance mechanism is available for all affected people – not only those affected by land acquisition (refer to the Stakeholder Engagement section below for further detail) and is managed by the company.

PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources

The project is situated in the Carpathian montane forests ecoregion of the temperate coniferous forest biome (as designated by WWF). The area is characterized by dry and salt steppes, which had traditionally been used as a pastureland and transformed into an arable land over time. There are swamps and marshes along the Calmatui River, which passes through the area. At the western edge of the area there is an isolated remnant of a Pinus sylvestris steppe woodland habitat. Types of Natural Habitat that overlap with the project are salt steppes and salt marshes, and water-fringing reedbeds and tall halophytes by the river. The majority of the project infrastructure (i.e., 61 out of 72 turbines) is located within a Natura 2000 site, Valea Calma?uiului Site of Community Importance (SCI, designated under the EU Habitats Directive), and Valea Calma?uiului Special Protection Area (SPA, designated under the EU Birds Directive). The SCI is characterized by two main habitat types; “Pannonic salt steppes and salt marshes” and “Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation. The SPA is designated for breeding and migratory bird species.

Bird flight activity data were collected for one year (2022/23) with monthly counts that were doubled during spring and fall migration seasons, and estimated turbine collision mortality risks with the potential for low to moderate impact on the following priority biodiversity values: Red-footed falcon (IUCN Red List -Vulnerable), Mallard, Common Teal, Eurasian Golden Plover, Northern Lapwing, Eurasian Curlew, White Stork, Ruff, Collared Pratincole, Great White Pelican, Little Egret, Eurasian Buzzard, Common Kestrel, and Hen Harrier (IUCN Red List – Least Concern). The White Stork, Collared Pratincole, Eurasian Curlew, and Ruff are four of the eleven species for which the Valea Calma?uiului SPA is designated. Priority biodiversity values also include 15 bat species, whose activity levels were recorded to be high during the baseline surveys of 2022/23. Of these bat species, Common Pipistrelle, Kuhl’s Pipistrelle, Noctule, and Nathusius’ Pipistrelle (all IUCN Red List – Least Concern, Romanian Red List – Vulnerable), and Western Barbastelle (IUCN Red List – Near Threatened, Romanian Red List – Vulnerable) were the most frequently recorded species. Other priority biodiversity values are the Pannonic salt steppe and salt marsh habitat, European Ground Squirrel (IUCN Red List – Endangered), and Eurasian Otter (IUCN Red List – Near Threatened/Largely Depleted, Romanian Red List – Vulnerable). The project is not in Critical Habitat (CH) for any of the identified priority biodiversity values as per IFC PS6; however, IFC Natural Habitat No Net Loss (NNL) requirements will apply to all of these priority biodiversity values given the potential risk of collision for bird and bat species and construction-phase impacts on the others.

In line with the Habitats Directive Resolution 6 requirements, an Appropriate Assessment (AA) was conducted for the project in 2012 by the previous owner, the outcomes of which were consulted with The National Agency for Natural Protected Areas (ANANP). The company engaged with ANANP again in 2021 with a revised Memorandum on the project, and the agency concluded that the project did not interfere with the reaching the conservation objectives of the Natura 2000 site, the WPP did not overlap with any important migratory corridors for birds, and it was understood there was no requirement for an additional AA. Some of the conditions defined by the ANANP include implementation of a monitoring program to address impacts on habitats and species of the Natura 2000 Site, implementation of lightening systems to reduce disturbance to nocturnal birds, especially during migration seasons, use of ultrasound tools for the European Ground Squirrel to leaves its burrows before construction, and construction activities to be overseen by an Ecological Clerk of Works.

Biodiversity surveys and assessments undertaken by the company addressed some of the gaps that were identified in the AA, where mitigation measures will be designed to avoid and minimize impacts on the biodiversity values of the Valea Calma?uiului Natura 2000 Site. IFC engaged with the Romanian Ornithological Society (SOR), which is the local BirdLife partner in the country, to obtain their views and feedback concerning the project's overlap with the Natura 2000 Site. The company will continue consulting with the ANANP and SOR in implementation of the project’s mitigation strategy, as well as to develop and/or support additional conservation actions for the Natura 2000 site.

The project will have a construction-phase Biodiversity Management Plan (BMP) as per ESAP#1, which will include pre-construction surveys of habitat features associated with the Natura 2000 site, Natural Habitat and terrestrial priority biodiversity values (nesting birds, European Ground Squirrel and Eurasian Otter). The surveys will inform the BMP to set forth all associated measures relevant to these values, including avoidance and minimization of disturbance to bird and mammal nests during the construction phase. The company will appoint a Biodiversity Specialist, who will be responsible for the surveys and overall management and reporting of all mitigation activities relating to the project.

During the operations phase of the project, the key measure will be the development and implementation of a robust fatality monitoring program that follows GIIP and is accurately able to generate unbiased fatality rate estimate. For this reason, as indicated in ESAP#18, the company will contract a specialized wind-wildlife consultancy to design and implement a Post-Construction Fatality Monitoring (PCFM) program. The PCFM program will, at the minimum, include (i) systematic carcass searches conducted at weekly intervals year-round under all turbines with transects 6-m in width, (ii) implementation of an adequate number of industry-standard bias correction measures for searcher efficiency (detectability), carcass removal (scavenging), and unsearched and unsearchable areas, (iii) industry standard statistical calculation of total, bias-corrected bird and bat fatality using GenEst software on a semi-annual (2x/year) basis. For bats, in addition to carcass searches, bat monitoring will also include acoustic bat detectors installed at the nacelle to determine bat activity and inform smart curtailment, if needed. The PFCM program will take place for at least a three-year period with semi-annual reporting following a standardized template, but the actual timeframe of the PCFM program will depend on fatality results. The first strategic review of the PCFM program will take place 6 months after the start of the operations phase, and then continue on a semi-annual (2x/year) basis. In addition to the PCFM program, the company will develop an operations phase BMP (ESAP#20), which 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 strategy. As per the adaptive management strategy, if the review identifies that any of the defined thresholds are exceeded, the company will take additional mitigation measures in consultation with IFC. These will include observer-led shut-down on demand for birds, and blanket and/or smart curtailment for bats, as needed.

In addition to the PCFM program, the company will develop an operations phase BMP (ESAP#19), which 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 strategy. As per the adaptive management strategy, if the review identifies that any of the defined thresholds are exceeded, the company will take additional mitigation measures in consultation with IFC. These will include observer-led shut-down on demand for birds, and smart curtailment for bats, as needed.

Although the project is not considered to be located in CH per IFC’s requirements, the company will develop a fit-for-purpose Biodiversity Action Plan (BAP) and Biodiversity Monitoring and Evaluation Plan given that the project is located in a Natura 2000 Site (ESAP#20). The BAP will be informed by the pre-construction surveys, quantify any residual impacts on priority biodiversity values, and identify measures to meet NNL objectives, including a Habitat Restoration Program for the Pannonic salt steppes and salt marshes habitat. The Habitat Restoration Program will, at the minimum, include (i) a detailed mapping of the habitat, (ii) identification of impacts (iii) recommendations on avoidance, minimization and restoration measures (iv) quantification of residual impacts and (v) a clear demonstration of how NNL will be achieved defining offset requirements, as applicable. If offset measures are required, a qualified expert with international experience on offsets will be contracted to develop an Offset Management Plan. The BAP will also identify additional conservation actions for the Natura 2000 Site, which will be developed and implemented in coordination with relevant stakeholders (i.e., ANANP, SOR).

PS8 Cultural Heritage

A desk-based cultural heritage baseline was completed as part of the ESIA, aligned with local legislation and IFC PS8. The assessment identified 61 cultural heritage sites within the project footprint and the surrounding 1000 m. The majority of the sites are locations where buried, finds comprise ceramics, remains of dwellings, necropolises, archaeological material, and potential human remains dating from the prehistoric to medieval periods have previously been identified. Sixteen of the sixty-one sites are nationally designated. Eleven sites (including three designated ones) are within 50 meters of project infrastructure. The majority of these sites are located within 50 meters of existing roads that will be upgraded or new roads to be constructed by the project. As per the ESIA, the resulting pre-mitigation impacts are only likely to be moderate at one of these, the site of an ancient settlement necropolis at Gheraseni (the remaining are deemed to have a minor impact).

As per ESAP#21, the company will develop and implement a Cultural Heritage Management Plan (CHMP) aligned with national laws and IFC PS8, informed by the nature of each known site and the proposed works in their vicinity. If necessary, site-specific archaeological field surveys will be completed to determine the full extent and importance of known heritage sites. It will include mitigation measures applicable at each site (including micrositing where possible) and, if required, a grave relocation plan. It will also incorporate a chance finds procedures to address potential impacts on as-yet-undiscovered cultural heritage features. The CHMP will be developed in consultation with community members and the Ministry of Culture (as applicable).

A Stakeholder Engagement Plan has been developed for the project consistent with IFC's PSs. The SEP is a framework document that establishes the principles of future engagement in line with IFC PSs.

The company has undertaken a robust stakeholder engagement program during the ESIA process, including in-person meetings with key local stakeholders. Stakeholder identification and mapping were undertaken, ensuring that any vulnerable, minority, or otherwise disadvantaged groups were identified and their needs incorporated in the planning of disclosure and consultation events. Stakeholder feedback has been integrated into the assessment and, where appropriate, project design.

The company started engaging with local communities, authorities, NGOs, and other local representatives during the ESIA scoping in November 2022. ESIA engagement was undertaken between March 16 - July 27 2023; it included socioeconomic and health baseline, key informant interviews, focus group discussions, and meetings with the elected representatives and local farmers. The company disclosed soft and hard copies of the ESIA, NTS, SEP Romanian, and English. These documents were also made available via Rezolv’s website: https://rezolv.energy/project/vifor-wind-farm/. The project grievance mechanism was also disclosed to the affected people.

The company will update its SEP annually and at least two months before each new phase of the project.   As per ESAP#22, the company will develop and implement an engagement action plan for the project's construction phase, defining its engagement program tailored for each stakeholder, clear timelines, and KPIs to facilitate monitoring. The company will inform the community of the project’s workers and security force's code of conduct and the availability of the project’s grievance mechanism to raise complaints. Also, the community will be consulted regarding the EPRP, and their feedback will be incorporated into the final management plan. 

The project's external grievance mechanism was established and operationalized during the ESIA process and is aligned with IFC PS. The company’s Community Liaison Office implements the external grievance mechanism. The grievance mechanism sets out clear procedures for receiving, documenting, and addressing complaints in an easily accessible and culturally appropriate manner in a language understandable to communities. The mechanism was designed to be accessible for both genders and any vulnerable groups.

Broad Community Support (BCS) was determined not to apply to the project as the project is unlikely to generate significant adverse social impacts that would be irreversible, diverse, or unprecedented.                                                  

 First Look Solutions S.A

Piata Charles De Gaulle 15 E. , Sectorul 1, Bucuresti

Republic of Romania 

https://rezolv.energy/project/vifor-wind-farm/