IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
The Project E&S risks and impacts were identified based on ESIAs completed in accordance with Egyptian environmental regulations and approved by the Egyptian Environmental Affairs Agency (EEAA), with environmental permits issued for all sub-projects between 2008 and 2017. To address biodiversity risks and impacts, a CHA, a BMP a BAP and a CEA have been completed for the Project in accordance with PS6.
The Project falls within a wider area for wind farm projects development and within the area covered by the ongoing Strategic Environmental and Social Impact Assessment and Cumulative Impact Assessment (SESA/CIA) for renewable energy in the GoS, whereby the Project is expected to follow its recommendations, to the extent possible, given that it is currently operational, once these studies are completed. The Project has been implementing an ATMP, including observer-led and radar-assisted shut-down on demand (SOD), and PCFM during the operations phase. The ATMP will continue to be implemented by staff contracted by Alcazar Energy as for other wind farm projects in the area. However, Alcazar Energy will be responsible for managing the efficiency and effectiveness of the ATMP for this Project. The ATMP preparedness and response measures are further detailed under PS6.
While environmental approvals have been issued by the EEAA for all sub-projects, Alcazar Energy shall notify the EEAA of the transfer of ownership of the assets and request their confirmation on the validity of the environmental approvals for all sub-projects. Alcazar Energy shall also prepare the necessary documentation and undertake the necessary repairs to obtain approval from the Civil Defense Authority for the Project’s firefighting system and firefighting plan.
Alcazar Energy will develop and maintain a legal permitting and commitments register that identifies applicable legal requirements, permit and approval conditions, ESIA commitments, and corrective actions arising from audits and independent lender monitoring, and track each commitment through closure, ESAP #1.
Alcazar Energy maintains a corporate-level ESMS aligned with the IFC Performance Standards and the World Bank EHS Guidelines for wind energy, comprising E&S policies, an exclusion list, procedures, and tools that cascade to projects through project-specific management plans. The ESMS covers environmental, social, health and safety, security, and quality aspects, and includes performance monitoring and reporting systems to identify, assess, and manage E&S risks against national and IFC requirements. Supporting procedures address HSE risk assessment, permits to work, labor management, E&S screening and due diligence, impact assessment, emergency preparedness and response, contractor procurement, grievance management, accident and incident management, stakeholder engagement, employer requirements, and subcontractor management. The Project will develop and implement a project-specific ESMS based on Alcazar Energy's project-level ESMS and aligned with applicable operational procedures, local legislation, the relevant ESIA measures, environmental approval conditions, and the IFC PSs, ESAP #2.
Alcazar Energy has a dedicated corporate team for the management of E&S risks and impacts. This corporate team comprises the Head of ESG, a Senior E&S Specialist, an E&S Specialist, and a QHSE Coordinator, based in the head office in UAE , who will be supported by country functions including a HSE Manager, E&S Specialist, a Social Specialist and a Community Liaison Officer. Alcazar Energy will update the Project’s organizational capacity by (i) defining an HSE organization for the Project including resources with established E&S and Health & Safety (H&S) roles and responsibilities at the Project, O&M contractor, and sub-contractor levels; (ii) providing training to Project staff on the Project ESMS, IFC PSs, and the WBG General EHS and Wind Energy Guidelines; (iii) recruiting a staff member with responsibility for labor management to ensure compliance with Egypt’s Labor Law 14/2025 and the applicable labor standards; and (iv) appointing a biodiversity manager with a proven record of effectively managing bird impacts at wind energy projects to Good International Industry Practice (GIIP). The biodiversity manager will be responsible for the overall management, compliance and reporting of all activities detailed in the future biodiversity management planning, ESAP #3.
The O&M Contractor’s current HSE resources comprise an O&M HSE Manager supported by HSE specialists from their sub-contractors. The Project currently has a workforce of approximately 23 people (excluding NREA and seasonal bird surveyors).
The Project HSE training program is currently set by the O&M contractor and comprises site induction training, on-job specific training, and regular toolbox talks. The site O&M team are required to complete mandatory HSE training such as advanced rescue training, working at heights and the use of rescue evacuation ropes inside the turbines. Alcazar Energy will require the O&M contractor to develop an HSE training plan with an HSE training needs assessment for the Project workforce, including the security personnel and the seasonal bird surveyors. The Project will develop an annual HSE training matrix including subjects to be covered, target audience, duration and frequency; and will adequately maintain training records. The HSE training plan and matrix will constitute part of the Projects ESMS, as per ESAP #2.
Alcazar Energy maintains a project-level Emergency Preparedness and Response Plan (EPRP) for the operations phase which defines roles and responsibilities, emergency communication protocols, emergency equipment and facilities, requirements for evacuation routes and assembly points, training and drill requirements, monitoring requirements, reporting requirements and record-keeping requirements. The Project EPRP developed by the O&M contractor sets out possible emergency situations and standard response procedures, assembly points, contact details of emergency response teams, and a drill schedule covering rescue from height, fire, high wind evacuation, heat stress, elevator evacuation and spills. Going forward, Alcazar Energy will require the O&M contractor to review and align the Project EPRP with its project-level EPRP template and with PS1. The updated Project EPRP will include (i) Project-specific emergency procedures, including wind turbine rescue and emergencies involving the seasonal bird surveyors; (ii) adequate emergency resources at each sub-project, including life and fire safety equipment, external defibrillators, wind turbine rescue equipment, dummy rescue kits for drills, and snake and scorpion anti-venom; (iii) emergency training and preparedness measures, including the required number of certified first aiders, emergency response drills at a defined minimum frequency, and clearly marked evacuation routes and assembly points, ESAP #4.
The main buildings are equipped with fire alarm, smoke detectors, sprinklers, foam and powder suppression systems, hydrants and two underground firefighting water tanks; however, only the handheld fire extinguishers remain in service and no Civil Defense Authority approval on the Project’s firefighting plan and systems have been obtained. Alcazar Energy will prepare a request to the Civil Defense Authority and undertake the necessary repair and upgrade works to obtain a permit. Alcazar Energy will also commission an independent and holistic review by a wind H&S expert, covering emergency response preparedness, life and fire safety, and general OHS, among others. This review will be undertaken according to GIIP, and all findings will be implemented within the agreed timeframes, ESAP #5.
The project O&M contractor monitors E&S Key Performance Indicators (KPIs) which includes number of hours worked, number of unsafe acts reported, number of near misses reported, number of permits-to-work issued, tracking of resources used (water and energy), waste generated. Although the project monitors and reports on a set of E&S KPIs, there is no Project-specific E&S monitoring plan defining inspection, monitoring, audit, and reporting procedures. Alcazar Energy will require the O&M Contractor to develop appropriate monitoring and review procedures within the based on its Project-specific ESMS templates, as per ESAP #2. The Project will also develop an environmental and hazardous waste and substances register for each sub-project, documenting information such as type and weight of waste generated, type and quantity of wastewater generated and type and quantities of hazardous substances, ESAP #2.
Alcazar Energy has commissioned a forward-looking assessment of the risks to the Project from climate change, ESAP #6. Similarly, Alcazar Energy will also undertake an assessment of the E&S risks and impacts of the OHTLs within the concession as part of the ESMS, including the mitigation measures to be discussed with EETC, ESAP #2.
PS2: Labor and Working Conditions
The Project workforce currently comprises approximately 23 personnel employed by the O&M contractor and its sub-contractors, in addition to approximately 15 NREA personnel per shift, up to 30 seasonal bird surveyors contracted through SafeSoar during the bird migration seasons and approximately 7 informal security guards engaged through the O&M sub-contractor. The Project is run on rotation work based on 8-hour shifts per day (7am-3pm) for 10 consecutive days followed by 5 days of rest, in accordance with national legislation.
The Project works under Egyptian national legislation, including Labor Law 14/2025, and the O&M contractor corporate HR policies and procedures that cover diversity and inclusion, business code of conduct, grievance procedures, among others. Alcazar Energy’s Labor and Working Conditions Management Plan (LWCMP) establishes procedures to manage labor and working conditions risks and impacts of projects, in line with local regulations and international standards. The plan is aligned with Alcazar Energy’s ESMS and related policies and requires contractors to develop and implement a project-level Human Resources (HR) Policy appropriate to the workforce and aligned with applicable laws and international standards. Service providers are also required to commit to this policy. The plan sets requirements on working conditions and terms of employment, transparent and fair recruitment, access to welfare facilities, workers’ rights to organize and bargain collectively, prevention of child and forced labour, prohibition of discrimination, prevention of Gender-Based Violence and Harassment (GBVH), a worker grievance mechanism, among others. Once the asset is acquired, Alcazar Energy will implement Alcazar Energy’s employee handbook and HR policies and procedures and require the O&M contractor to implement Alcazar Energy’s LWCMP in alignment with local labor law and IFC PS2, ESAP #7.
Alcazar Energy will verify and document that all Project employees including contractors have written contracts in line with the Egyptian labor law requirements and IFC PS2. Overtime will be compensated for in money and not only in time off work, ESAP #8.
Informal security guards are hired through the O&M sub-contractor to guard the sites. Alcazar Energy will reassess the welfare conditions of all security guard posts across the site and implement measures to upgrade their welfare and working conditions equally across all informal security personnel. This will include but not be limited to a shaded and protected structure; access to clean, safe and cold potable water; dry and wet food storage facilities; electricity; sanitary facilities; access to medical aid and emergency response arrangements, ESAP #9.
Currently, approximately 50% of project workers are Egyptian nationals residing in Ras Ghareb or Hurghada and are provided with accommodation allowance to make their own arrangements. NREA has four accommodation buildings on site with a total of 48 apartments. These housing units are mainly used by NREA and by the bird observers during bird migration seasons.
Alcazar Energy’s Labor Accommodation Strategy Plan (LASP) provides a framework for managing on-site and off-site worker accommodation; including standards for accommodation facilities, water, sanitation, waste management, food safety, emergency arrangements, security, workers’ rights, and grievance mechanisms, together with accommodation-related training and monitoring KPIs. While the LASP is aligned with the key requirements of IFC PS2, IFC/EBRD Workers’ Accommodation Guidance, and GIIP, the LASP will require to be updated to reflect Project-specific arrangements, local regulations, monitoring targets, and site-specific risks and mitigation measures. Alcazar Energy will require the O&M Contractor to develop and implement a Project-specific LASP. Alcazar Energy will monitor compliance with this plan, ESAP #10. Furthermore, if the NREA buildings are included in the acquisition or are used by the Project on a leased basis, a full assessment against IFC/EBRD accommodation standards and Egyptian firefighting standards will need to be completed before use, together with a corrective action plan, in compliance with the LASP, as per ESAP #10.
Alcazar Energy’s Workers Grievance Mechanism Procedures (WGMP) establish a framework for receiving, managing, investigating, resolving, and monitoring workforce grievances in line with national legislation, international standards, and Alcazar Energy’s ESMS. The procedures apply to all Project workers, including contractors, subcontractors, and service providers, and defines roles, responsibilities, grievance processes, escalation pathways, monitoring, and reporting requirements. They include provisions for grievance registration, investigation, corrective actions, close-out, record keeping, and worker awareness and training. The procedures are aligned with IFC PS2 requirements for worker grievance mechanisms. As per ESAP #7, the Project will include an internal grievance management process within its HR policy and management framework, aligned with Alcazar Energy’s LWCMP, WGMP and IFC PS2 and be communicated to all direct and contracted workers, including all security personnel, and third parties. The WGMP will be accessible through different communication channels and will provide safe and confidential channels, including the option of anonymous reporting, through which complaints relating to GBVH can be raised. The Project will also maintain a grievance register to track all worker grievances from receipt through closure.
The O&M contractor implements OHS procedures and controls including lock-out/tag-out, a permit to work system, working at heights, among others. During the site visit, OHS related signage and instructions were noted relating to firefighting, evacuation, and use of Personal Protective Equipment (PPE). Workers engaged in maintenance work within the wind turbines were observed to be equipped with fall arrest equipment, safety glasses, hardhats with chin straps, safety gloves, safety shoes, lanyards and tool bags. Since operations commenced, the Project has reported no occupational fatalities, permanent disabling injuries or occupational diseases, although a change of the O&M HSE Manager left a gap of approximately six months in reported HSE statistics.
According to national regulations and the conditions attached to the environmental approvals, the Project is required to undertake OHS measurements for noise, heat stress, light intensity, and humidity in the workplace. The Project will perform workplace exposure monitoring at least annually- covering noise, heat stress, illumination and humidity- within a randomly selected hub at each sub-project and assess the results against the limits prescribed under Law 4/1994, ESAP #11.
The O&M contractor engages several sub-contractors, covering switchgear and cable maintenance, mechanical and electrical maintenance, waste management and security services, air conditioning and civil works, crane services, and warehouse management. The O&M contractor has an HSE manual for contractors and a code of conduct for suppliers and third-party intermediaries. The Project will undertake a contractor and supplier due diligence process in accordance with Alcazar Energy’s procurement policy, covering contractors and subcontractors, including key wind component suppliers, and their subcontractors, as applicable. The due diligence process will include desktop screening and assessment of relevant E&S risks and compliance obligations, ESAP #12.
Alcazar Energy’s Supply Chain Management Plan (SCMP) establishes a framework for identifying and managing E&S risks in the Project’s subcontractors and primary supply chain during operations. The plan requires supply chain risk assessments before supplier selection, supplier risk rating, and enhanced monitoring of medium- and high-risk suppliers. It addresses risks related to child labor, forced labor, significant safety risks, habitat conversion, limited supplier transparency, and ethical sourcing of materials and components. Responsibilities are assigned to Project personnel, contractors, and subcontractors, and suppliers are required to complete self-assessment questionnaires to support risk profiling. The SCMP also includes requirements for reporting and investigating supply chain concerns and the use of grievance mechanisms.
PS3: Resource Efficiency and Pollution Prevention
The Project is estimated to generate approximately 2,200 GWh per year based on the P90 (90% probability of exceedance) energy yield assessment, with greenhouse gas emission (GHG) reductions of approximately 1,060,400 tCO2e per year using a grid emission factor of 482 gCO2e/kWh. Overall, the estimates indicate that the Project’s own GHG emissions will remain below the threshold of 25,000 tCO2e per year, while contributing positively to avoided emissions at the system level.
Wind projects have limited requirements for water and energy. The site offices and auxiliary equipment are powered by the wind farm and fuel consumption is limited to vehicles used by the Project. Water is supplied from the municipal network via a pumping station located approximately 500 m southeast of the main operation building and is also trucked from the Ras Ghareb water station; potable water is procured bottled from the market. Water consumption is estimated at 4 to 5 m3 per day during normal operation, increasing by a further 8 m3 per day during the bird migration season when additional personnel are accommodated onsite. Overall, the Project is not considered a significant user of water, fuel, or other raw materials. Alcazar Energy’s Resource Efficiency Management Plan (REMP) establishes measures for managing and monitoring resource consumption and GHG emissions during operations, including water, fuel and electricity, and resource consumption. The plan identifies risks associated with inefficient resource use and includes measures for reducing fuel and energy consumption, water-saving practices, training, inspections, audits, reporting, and corrective actions. The plan will be adapted to the Project to govern the management and monitoring of resource consumption and GHG emissions, ESAP #13.
Noise modelling undertaken during the ESIAs indicated levels of approximately 50.8 dB(A) at 250 m from the turbines. The nearest onsite receptors are the accommodation buildings, the water pumping station and the emergency checkpoint, which are located approximately 0.5 to 1 km from the nearest turbine; no noise measurements have been undertaken at these receptors since commercial operation and these will be included in the monitoring program. Shadow flicker impacts are negligible given the setback of the nearest accommodation building and the absence of other nearby sensitive receptors, with Ras Ghareb city located more than 10 km from the windfarm. Turbine setbacks from buildings exceed 1.5 times the turbine height, consistent with the WBG EHS Guidelines for Wind Energy.
Non-hazardous waste generated by the Project includes paper, plastic, glass, organic and other typical municipal waste, which is collected in color-coded bins and reported to be transported to a dumpsite in Ras Ghareb that does not meet IFC PS requirements and raises biodiversity risks. Alcazar Energy will identify and use an alternative compliant waste disposal facility, ESAP #14. Hazardous waste generated includes spent oil, oil filters, empty oil and grease jerry cans and pails, and contaminated cloths and rags; the hazardous waste storage areas observed during the appraisal had restricted access, bunding, signage, emergency response equipment and impermeable flooring. Hazardous waste is removed by a contractor holding EEAA approval, accompanied by transfer manifests. Sanitary wastewater is discharged to soak-aways at each sub-project and to a holding tank for the accommodation buildings.
Alcazar Energy’s Waste and Wastewater Management Plan (WWMP) establishes measures for managing solid waste, hazardous waste, and wastewater during operations to prevent environmental contamination and related H&S risks. The plan includes requirements for waste minimization, segregation, storage, transport, recycling, and disposal, as well as specific controls for hazardous waste management and wastewater handling. The Project O&M contractor also has a waste management plan with an explicit compliance commitment to IFC PSs and national regulations and applying a waste minimization hierarchy, although it lacks detail and KPIs.
To align with PS3 requirements, Alcazar Energy will update the Project-specific Waste Management Plan to include waste minimization measures based on the waste hierarchy, identification of expected waste streams and disposal infrastructure, assessment of final disposal facilities, monitoring and inspections of waste disposal practices, KPIs and record-keeping to ensure waste is managed by licensed and compliant contractors. Alcazar Energy will also develop a Project-specific Wastewater Management Plan, including the installation of sealed holding tanks, use of licensed wastewater contractors, random inspections, and maintenance of disposal records. In addition, electronic waste, hazardous waste, used oils, and batteries will be managed through licensed contractors and authorized disposal or recycling facilities, with contractor licenses, waste manifests, and disposal certificates maintained and periodically reviewed. The Project will also undertake an E&S due diligence of water supply contractors, waste collection contractors, treatment and disposal facilities, and wastewater collection contractors and disposal facilities to verify compliance with applicable Egyptian legal requirements and the IFC Performance Standards, ESAP #15.
In addition, Alcazar Energy will retain a third-party consultant to undertake a phased environmental site assessment to American Society for Testing and Materials (ASTM) standards addressing potential soil and groundwater contamination associated with abandoned oil wells within the concession, pre-existing infrastructure and historic waste and wastewater practices, and will obtain written confirmation from NREA that any contamination identified and its remediation remain the sole responsibility of NREA, ESAP #16. Alcazar Energy will also confirm with the O&M contractor whether white asbestos is present in turbine brake pads and where present, require the development of an asbestos management plan, ESAP #17.
PS4: Community Health, Safety and Security
Road traffic safety risks in the O&M phase are mainly in relation to the transportation of the workforce given the Project is now in operations phase. To address the elevated contextual driving risk of road traffic accidents in Egypt, Alcazar Energy will (i) ensure that the Project implements a road safety procedure addressing driver qualification and fitness, including defensive driving training; (ii) require that all Project personnel adhere to journey management controls, including avoidance and reduction of impacts on community H&S; and (iii) monitor and audit implementation of driving risk controls, ESAP #18.
The Project concession, as well as the wider area, is guarded by national security forces as well as informal security. The Project relies on the informal security personnel engaged through the O&M sub-contractor Petrotec Engineering. Alcazar Energy will undertake a security risk assessment and develop and implement a Project-specific Security Management Plan (SMP) aligned with IFC PS4 and consistent with the Voluntary Principles on Security and Human Rights. The plan will be informed by stakeholder engagement on the security context of the area and will identify the required security infrastructure, including CCTV coverage, access gates and personnel numbers. Security arrangements will include the interaction between the security personnel and the national security forces, security equipment, incident response procedures and training, identity checks, security inductions, and toolbox talks, ESAP #19.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The Project is situated in the Red Sea Coastal Desert ecoregion, in hyper-arid hamada desert between the Red Sea coast and the mountain chain running alongside it. The area is characterized by flat or gently sloping sand and gravel desert cut by shallow drainage channels (wadis). Vegetation is sparse and restricted to the wadis, and all plant species present are common and widespread; the resident fauna is limited, the only resident non-bird threatened species being the Egyptian Spiny-tailed Lizard (Uromastyx aegyptus), listed as Vulnerable on the International Union for Conservation of Nature (IUCN) Red List. The Project (which began operations between 2014 and 2018) is sited within the GEZ IBA, which is also a KBA. The GEZ IBA/KBA is situated within the Rift Valley/Red Sea flyway, a globally important migration corridor for MSBs, particularly storks and raptors, and constitutes a bottleneck site at the narrowest crossing point of the southern GoS through which migratory soaring birds are funneled.
The Project is regarded as within a critical habitat (CH) based on its location within the GEZ IBA/KBA. A CHA was completed in August 2026 and concluded that the Project is within CH for six MSB species: Steppe Eagle (IUCN Red List – Endangered); Levant Sparrowhawk, European Honey-buzzard, Black Stork, White Stork, and Great White Pelican, all (IUCN Red List – Least Concern). These species will be subject to net gain requirements.
The Project has conducted a CEA following IFC guidelines to identify those species at highest risk from Project related activities. The assessment identified ten species with a moderate or high potential for turbine collision mortality and classified them as priority biodiversity values. These comprise the six CH species and four additional species: Black Kite, Common Crane, Eurasian Buzzard and Greater Spotted Eagle, all listed as Least Concern on the IUCN Red List. These four additional bird species will be subject to IFC Natural Habitat no net loss requirements. Baseline bat studies indicated a potentially low risk to bats; however, two priority bat species, Desert Pipistrelle and Ruppel’s Pipistrelle, both listed as IUCN Red List - Least Concern - together with Egyptian Spiny-tailed Lizard (IUCN Red List – Vulnerable), were also identified as priority biodiversity values and will be subject to IFC Natural Habitat no net loss requirements.
The three sub-projects are already implementing programs to avoid, minimize and monitor bird collision impacts, comprising an ATMP with observer-led and radar-assisted SOD, implemented from 20 February to 20 May in spring and from 10 August to 30 October in autumn. The 2026 appraisal found that radar assistance continues to be provided during the spring season only, pending armed forces approval for autumn use; that SOD reports were not available for 2024 and 2025; that bias-corrected fatality estimates have been reported only for 2022; and that fatality monitoring along the OHTL is not undertaken systematically, with no carcass searches at met mast locations. The ESAP will build on the existing good practice by ensuring a unified monitoring and mitigation approach across all sub-projects, verifying and enhancing mitigation and monitoring standards, and further improving the overall safeguarding of priority birds and other impacted biodiversity.
Alcazar Energy will contract an internationally recognized wind-wildlife consultancy to: (i) collate and analyze existing bird monitoring and fatality data from the Project, to appraise PCFM and ATMP performance over the operational life of the Project to date, and better understand fatality trends across the migration periods; (ii) conduct a desk-based and on-site assessment of the ongoing PCFM program and ATMP, including the effectiveness of the radar-assisted component of the SOD program and the efficiency and siting of the current radar system, and the effectiveness of ATMP to safeguard roosting MSBs within and near to the Project, including the area in the south of the JICA sub-project where shutdowns are most frequently required for roosting storks and pelicans (iii) update the BAP based on the review and effectiveness findings; Results from these studies will be used to enhance the existing monitoring and mitigation programs, to ensure ATMP and PCFM protocols are operating consistently and efficiently across the Project. The appointed consultant will also finalize the operational-phase Biodiversity Management Plan (BMP). The BMP will set out: (i) biologically derived fatality thresholds for priority bird species; (ii) an adaptive management framework; and (iii) protocols for all on-site operational monitoring and mitigation activities, including systematic recording of birds roosting within and adjacent to the Project area. It will also include a semi-annual reporting template for centralized reporting of biodiversity monitoring, mitigation, and adaptive management actions. The BMP will undergo strategic review after 2.5 years and again after 4.5 years. Alcazar Energy will extend the autumn ATMP operating period to align with that at other GoS projects to cover the entire migration season and will apply for the necessary permissions from the Egyptian Armed Forces so that radar assistance is provided during the autumn migration as well as in spring, in line with the EIA permit conditions, ESAP #20.
Alcazar Energy will contract nationally recognized wind-wildlife consultancies to revise, implement and manage the PCFM program for turbines, the OHTLs within the Alcazar Energy acquisition project footprint, and meteorological masts, as well as the ATMP. These programs will be carried out for the operational life of the Project. The ATMP protocol will align with current and future iterations of the regional ATMP program for the GoS. To mitigate against future ATMP personnel shortages, Alcazar Energy will demonstrate that the Project has secured an adequate number of trained staff to conduct the ATMP programs effectively over the first 3 years, including radar operators trained in all aspects of radar-assisted SOD, and will develop initiatives to build capacity to safeguard against potential staff shortages during the lifetime of the Project, ESAP #21.
The Project is already operational, and Alcazar Energy does not control operation or maintenance of the associated OHTL. Through engagement with the OHTL operator and regulator, Alcazar Energy will seek to secure a Memorandum of Understanding or a written agreement with EETC to ensure that: (i) Bird Flight Diverters (BFDs) are installed along the entire OHTL within the Project concession as well as in the guy lines of the met masts; (ii) BFD design and configuration are aligned with current good practice within the GoS; and (iii) all OHTL will be inspected and faulty BFDs replaced before each migration season, ESAP #22.
A BAP was completed in March 2026, including a draft Offset Feasibility Study. Alcazar Energy will select from the list of offsets from this study that it agrees to finance, which together will achieve net gain and no net loss goals for the operational life of the wind farm. IFC will approve the offsets and their associated budgets. Alcazar Energy will contract a consultancy with international experience in developing offsets to develop a Biodiversity Offset Management and Implementation Plan (BOMIP.). The consultancy will be retained to oversee the early implementation of agreed offsets and to implement the BOMIP, ESAP #23.
To fulfil the interrelated biodiversity requirements for the Project, as well as to coordinate and manage multiple biodiversity risks and interrelated monitoring and mitigation measures, Alcazar Energy will contract or assign a dedicated biodiversity manager as set forth in ESAP #3, who will be responsible for the overall management and reporting of all mitigation and monitoring activities detailed in the operations phase BMP.
