This is a Category B project as per IFC's Policy on Environmental and Social Sustainability, because potential adverse environmental or social risks and/or impacts are limited, few in numbers, site-specific, largely reversible and readily addressed through mitigation measures.

Key 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), workers grievance mechanism, nondiscrimination & equal opportunities, forced labor risks associated with the solar PV supply chain; (vi) emergency planning;  (vii) potential legacy site contamination; (viii) community H&S and project's use of security personnel; (ix) land acquisition and livelihood impacts; (x) potential biodiversity impacts.                                              

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

The company acquired the project from a previous developer in 2020. The previous developer completed initial environmental permitting (which the company renewed in 2022), with separate permits issued for components of the PV site and associated project infrastructure. The relevant regulatory authority, the Regional Inspectorate of Environment and Water Use (RIEW) confirmed in 2022 that a national environmental impact assessment was not required for the project.

The company engaged ERM, an international consulting firm, to conduct an E&S Red Flag report in November 2022 to identify significant risks/impacts and assess aspects of the site that may require further investigation through an Environmental and Social Impact Assessment (ESIA). Subsequently, AON was engaged to conduct an ESIA to meet national and international requirements, including IFC PSs. Additionally, AON was engaged to develop an ESIA Non-Technical Summary (NST), Stakeholder Engagement Plan (SEP), and Environmental and Social Management Plan (ESMP) (collectively referred to as the ‘E&S Disclosure package’). A gap analysis of the ESIA was conducted by the IFC and the IESC, which identified that the impact assessment process for the project is generally compliant with IFC PSs; however, several additional studies are required to ensure that it is fully aligned with IFC PSs. As per ESAP#1, the company will update the ESIA (and associated NTS and ESMP) before construction and as a condition of commitment to close the remaining gaps with IFC PSs as outlined in the ESIA gap analysis of the IFC and IESC. Further measures required to address any outstanding E&S risks in subsequent stages of the project are outlined in the ESAP and described below.  The IFC and the company will disclose the final version of the ESIA.

The project's environmental and social management system (ESMS) is being developed. However, a project ESMP has been prepared as part of the ESIA, which outlines key mitigation measures identified via the ESIA and processes that the company will implement during the project construction and operations phases to meet national and IFC E&S requirements. As per ESAP#2, the company 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 all necessary plans/procedures to be developed and executed to address the mitigation measures identified through the ESIA, including, as a minimum, the following management plans: pollution prevention, waste management, contractor management, supply chain (including a PV Module Supply Chain Risk Assessment), community health, safety, and security, emergency preparedness and response, labor management, occupational health and safety, security management, transport and traffic management, biodiversity management, chance finds procedure, and stakeholder engagement plan (including community grievance mechanism) 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 company in the ESIA documentation and through acceptance of the national permits and legal agreements stipulated with the Government of Bulgaria.

The EPC Contractors will be contractually bound to follow E&S requirements, including IFC PS and WBG EHS Guidelines. All contractors, including sub-contractors, will be required to implement those portions of the company’s ESMS that fall within its scope of work as described in the draft framework ESMP. 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 and procedures applicable to the EPC activities (including contractors and sub-contractors) and tailored to the project's construction methodology, engineering design, and commissioning phase. The structure and content of the EPC ESMS will fully align with the company’s ESMS and the adopted project-specific standards (ESAP#3).

Before commercial operations, as per ESAP#4, the company will develop and implement an Operations Environment & Social Management System (OESMS) consistent with the project ESIA, 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, waste management, emergency response, community health, safety & security, biodiversity management, environmental monitoring. The company will require its O&M contractor to develop and implement its own operations OESMS, including policy statements, management and monitoring measures, and aspect-specific management plans applicable to the O&M activities. The structure and content of the O&M OESMS will be fully aligned with the company’s and with the adopted project-specific standards (ESAP#5).

The company will ensure that sufficient staff and contractor resources are allocated to manage E&S performance at all times. The company currently has a limited number of corporate and project-level E&S staff. As per ESAP#6, during the construction phase, the company shall engage, at a minimum, a full-time, qualified, and experienced Environment, Social, Health, and Safety (ESHS) Manager who will have overall responsibility for environmental and social management as well as occupational health and safety (OHS). He/she will also be responsible for compliance with permit conditions and project E&S standards, and implementation of the ESMS, and for coordinating the project ESHS team, which will include, at a minimum, a community liaison officer, OHS specialist/s, social specialist, and environmental/biodiversity specialist. The company’s E&S team will ensure that the EPC contractor and subcontractors comply with E&S requirements. The company and its EPC contractor will share construction E&S management and monitoring responsibilities. To ensure the EPC Contractor has adequate resources to meet its responsibilities, the company shall require its EPC Contractor to appoint suitably qualified counterparts to its staff to ensure sufficient oversight of the entire construction labor force.

The company will engage an ESHS Manager and CLO during the operational phase 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#7).

As part of the ESMS (ESAP#2 - #5), 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 expert consultants to undertake E&S monitoring during construction and operations, if necessary. An independent E&S monitoring consultant will also be engaged during the construction and early operations phases to monitor the implementation of the ESMS and E&S Action Plans and recommend any necessary corrective measures.

To manage E&S risks related to procurement and supply chain, the company has developed formalized processes, including vendor prequalification, selection procedures, and a Partner Code of Conduct, which defines the company’s E&S commitments (including commitments relating to labor practices and human rights). The company incorporates these commitments into the contracts it signs with its suppliers. As part of the project’s ESMS, the company will develop a supplier-contractor management plan including a PV Module Supply Chain Risk Assessment.

PS 2 – Labor and Working Conditions

The project's construction workforce is expected to reach approximately 300 workers at the peak of the construction phase. Most of whom are anticipated to be Bulgarian nationals, largely sourced from the local region. The construction phase is expected to last 12 months. The average workforce is expected to comprise approximately 5 - 10 people during operations.  

The company has developed several policies defining its commitment to adhering to international labor laws and regulations at a corporate level. At a project level, as per ESAP#8, the company will develop and implement project human resources (HR) processes, including a labor-management plan and associated policies consistent with IFC PS2, International Labor Organization (ILO) requirements, and EU and Bulgarian labor codes, which will apply to all project workers (including contractors/subcontractors). The policy/processes will define the company’s commitments concerning labor and working conditions, maximizing local employment, equal opportunities and non-discrimination (including putting in place best practice recruitment policies to encourage and support qualified women to apply for jobs), 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 require all contractors to report annually on the number and % of women employed, disaggregated by job function, level, and pay. The company will develop a code of conduct, including enforceable sanctions aligned with national law, applicable to all workers (including their conduct within worker accommodation facilities), specifically including mitigants related to GBVH. All project workers will receive induction training on the project's human resources policies, including mandatory training on the Worker Code of Conduct (including GBVH requirements). The company will require its EPC Contractor to develop and implement a human resources policy fully aligned with its own.

As per ESAP#09, the company will develop and implement a project-level worker's grievance mechanism (WGM) in accordance with IFC's PS2, and national law. 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 will include specific considerations for receiving GBVH grievances, including multiple entry points to raise and address allegations and options to report anonymously if preferred. The company will appoint an adequately trained grievance officer (including detailed knowledge of Bulgarian labor law and sexual harassment) to attend to the worker grievances and coordinate the implementation of the WGM. The WGM will contain a clear policy on anti-retaliation and retribution of the grievant.  The company will ensure that available WGM communication channels are disseminated in all facilities, accommodating project workers. The company will use the services of a specialist third party to administer a project-level survivor-centric GBVH grievance mechanism, including GBVH grievance case management (informed consent, incident investigation) and identification of a survivor referral mechanism offering independence and confidentiality.

Bulgaria 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 Bulgaria 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 supervise the EPC contractor's (and their sub-contractors’) compliance with the requirements defined within their human resource policies and conduct semi-annual monitoring to assess adherence to local labor laws and project labor and working conditions commitments (ESAP#10). 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#11). 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 plans contained within the project ESMS and national and IFC PS.

The project's accommodation strategy for non-local workers is still being finalized. Non-local workers are expected to be accommodated in hotel/apartment accommodation in Silistra. However, suitable hotels/apartments are yet to be identified. As per ESAP#12, 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 Bulgarian 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#08) 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 GBVH.

Through contractual clauses, the company will ensure through contractual clauses that its EPC and O&M contractor develop and implement a site-specific occupational health and safety (OHS) management system, including the necessary plans and procedures commensurate to the project risks, which will apply to all project workers, including subcontractors. The plans/procedures will include gender-differentiated risks and define a program for workers to complete basic OHS training (including training related to gender-specific risks), as well as specific training for staff undertaking high-risk activities (ESAP#13).

PS 3: Resources Efficiency and Pollution Prevention

The project is estimated to generate 319,813 MWh per year, with greenhouse gas emission reductions of c. 241,588 tCO2 equivalent per year using a grid emission factor of 755.40 gCO2 / kWh.

Water requirements are expected to be low during construction and operations. Construction water will be required for dust suppression and domestic usage (concrete will be sourced via offsite local suppliers). 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 1,500 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 robotic, dry-cleaning techniques. Wet cleaning of PV modules is only anticipated to be required 1 to 2 times per year. Water will be sourced via a municipal water pipeline that crosses the site.

The project is expected to generate minor air, dust, water, and soil pollution, which are anticipated to be readily mitigated by implementing standard pollution prevention and control measures defined within the project ESMS. A pollution prevention plan addressing air emissions, dust management, and liquid effluents will be developed and implemented within the ESMS (ESAP#2).

A portion of the project site is close to residential receptors (the southwest site boundary borders are approximately 10 m from houses within the village of Polkovnik Lambrinovo). A qualitative noise assessment completed as part of the ESIA identified potential moderate to major pre-mitigation noise impacts during construction and moderate impacts during operations (associated with inverters/substation). As per ESAP#14, The company will conduct a quantitative noise assessment assessing potential construction and operational phase impacts. The assessment shall identify sensitive receptors in line with the definitions in the relevant EHS Guidelines and specifically confirm no exceedance of 45dB nighttime criteria at sensitive receptors or 3db (A) change based on measure baseline data (where 45dbA may be exceeded). If either assessment identifies the need for further mitigation measures (above those defined within the ESIA), these will be implemented.  Additionally, as part of the project’s E&S monitoring program, the company will conduct noise monitoring to verify the noise assessment results and compliance with national and project requirements.

No analytical data regarding soil and groundwater conditions at the project site is available.  Given the site's previous land use (former airport), past practices may have caused historic contamination, which may require remediation.  No signs of contamination were noted during a site walkover survey conducted in 2022 (as part of the E&S Red Flag report) or during IFC’s appraisal visit.  This notwithstanding, as per ESAP#15, the company will engage an independent consultant to conduct a phase 1 environmental site assessment (ESA) to identify potential sources of contamination, receptors, and pathways. Should the Phase I ESA suggest possible contamination, the company will complete a Phase II ESA to verify the presence of contamination and take remedial measures as required. 

As a precondition to the company’s project acquisition, the landowner cleared the existing buildings/structures from the project site. Site clearance activities resulted in the inappropriate disposal of demolition waste (concrete, construction rubble, etc.,) on one land plots adjacent to the project site and the village of Polkovnik Lambrinovo.  It is understood that the presence/absence of asbestos-containing material (ACM) was not verified before the demolition.  As per ESAP#16, the company will ensure that an asbestos survey is completed to verify the presence/absence of asbestos-containing material (ACM) in the demolition waste removed from the site. Should ACM be identified, a suitably licensed contractor will be engaged to remove and dispose of the ACM as per national and EU requirements and GIIP. Furthermore, the company will ensure all non-ACM demolition waste is removed from the land plot and disposed of at a suitably licensed facility or re-used on the project site. 

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 the company. The project ESIA identifies no licensed hazardous disposal facilities within the project area and limited general waste facilities. As part of the ESMS (ESAP#2), the company will develop and implement a Waste Management Plan (WMP) for the project 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 4).

PS 4: Community Health, Safety, and Security

The southwest site boundary is adjacent to the village of Polkovnik Lambrinovo (population of approximately 140 persons), with the closest residential property located approximately 10 m from the boundary. Five other communities are located within 5 km of the project site and OHTL.

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#2, 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 will be established (ESAP#08), defining the expected behavior of workers beyond project premises and working hours – including sexual harassment, exploitation, and abuse in local communities, rules for interactions with local communities, and disciplinary procedures. The company will integrate this in the induction training for employees and contractors (including security guards) and in communication campaigns in the workplace and within at-risk communities. Additionally, as per ESAP#17, The company will conduct a GBVH risk assessment, focusing on Silistra (where most project workers are expected to be accommodated) and the villages within the project’s social area of influence. The assessment will utilize socio-economic baseline data, to the extent possible, collected as part of the revised ESIA to identify vulnerable groups at risk of GBVH (e.g., women-headed households and school children). Based on the results of the assessment, the company will develop a GBVH action plan to include prevention and response measures to mitigate and monitor any identified impacts. The areas close to the hotels where workers will be accommodated will be included in the Stakeholder Engagement Plan to ensure they are aware of the impacts and mitigations, the worker’s Code of Conduct, and how to access the Community Grievance Mechanism.

As part of the ESMS (ESAP#2), 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 transporting the PV plant and OHTL components from a yet-to-be-confirmed port to the site (the project is assessing options to transport components via the ports of Varna or Constanta). Additional risks relate to transporting aggregate, concrete, water, and site workers. Risks associated with this transport have been assessed within the ESIA. The project site is accessible via a second-class road connected directly to the Bulgarian motorway network.  The company has completed a preliminary road transport route study, including assessing the road networks to transport solar PV panels and other equipment. As per ESAP#18, the company shall ensure its EPC Contractor completes a detailed traffic transport survey and Social Impacts Register to identify the most appropriate transport routes for the project. As part of the ESMS (ESAP#3), the EPC will develop and implement 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. The EPC will assess local road conditions and complete a dilapidation survey of structures/infrastructure adjacent to community roads (as required).

The entire perimeter of the PV site will be fenced, and entry to the project site will be regulated. The company’s EPC/O&M contractors will engage a security contractor to provide unarmed security personnel during the construction and operational phases of the project. The number of security personnel required to be engaged has yet to be determined. The company will require its EPC/O&M Contractors to ensure that all potential security service providers are screened during the procurement process to verify they have not been involved in past human rights violations.  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 (ESAP#2), the company will develop and implement a security management plan aligned with IFC PS4, which will apply to the company and its contractors (and their sub-contractors). The security management plan 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 GBVH 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

No physical displacement is required for this project. The project will impact agricultural livelihoods associated with temporary land use and land acquisition for the OHTL.

PV Plant Site: The proposed PV site is located on private land. The PV site footprint occupies 164.2 ha and is predominantly within a disused airfield, the remainder being former agricultural lands (two land plots owned by the same landowner as the airfield). The company has secured land for the PV plant on the basis of a limited in rem right to construct (right-to-build) over land owned by a third party.

Overhead Transmission Line: The PV plant will be connected to the national grid via two 110 kV OHTLs (Pelikan OHTL, approximately 3.7 km, and Dorostol OHTL, approximately 2.3 km), which will be built as part of the project and connect to existing transmission lines. The two OHLs will include a right-of-way-, secured via easement rights and ownership, of 11 small land plots, on which the pylons for Dorostor overhead cable line will be constructed. The Pelikan OHL will traverse 75 private agricultural land plots, 1 public road that is state property, and 12 field roads that are municipal properties. The Dorostol OHTL traverses 1 public road, which is state property, 7 field roads, which are municipal properties, and 27 private properties, which are agricultural lands.

The project requires the permanent acquisition of privately owned agricultural land for 31 OHTL pylons (varying between 3 m x 3 m to 7.2 x 7.2 m footprint per pylon), and temporary land access will be required for the RoW during construction. To date, 78 Project Affected People (PAPs) have been identified. The total number of PAPs who use the land (including potential informal land users), 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#19). No easement restrictions are currently foreseen in relation to the OHL right of way as all identified land plots are agriculturally zoned; hence, the building of residential and commercial structures is already restricted in these plots. Livelihood impacts related to land acquisition for the PV site have not been identified in the ESIA; this will be confirmed and, if necessary, addressed as part of the LRP.

As described above, the permanent land required for the pylons of Dorostol has been acquired. The acquisition and OHTL easement rights were secured by a previous developer, aligned with Bulgarian requirements (including compensation payments), and the rights were transferred to the project company. For the temporary access roads, the PAPs will receive compensation as per the LRP, including livelihood programs for eligible land users, and reinstatement measures will be implemented. Impacts associated with temporary land access are anticipated to be minor due to the short-term nature of activities.

As per ESAP#19, the company will engage a suitable, qualified, and experienced consultant to develop, implement, and monitor an LRP aligned with national law and IFC PS5. The LRP, through a baseline socio-economic survey, will be designed to capture all potential impacts on land and livelihoods related to the project’s construction and operations phases.  It will assess the project's land acquisition process, including land acquisition and easement rights secured by the previous developer, and identify any inconsistencies with IFC PS5.  If any consistencies are identified, the project will commit to providing complementary measures (including compensation payments, if deemed required) to address these with a commitment to continue compensatory measures to PAPs until livelihoods have been restored, which may take multiple seasons, depending upon the extent of land disturbance; direct engagement with PAPs 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. The company will report on its monitoring of LRP implementation to IFC through the submission of biannual monitoring reports during the construction phase and annual reports during operations until all the LRP activities are completed.

As per ESAP#20, the company will engage a suitable, qualified, and experienced consultant to complete a closeout monitoring survey one year after all LRP measures have been implemented to confirm alignment of the LRP with PS5 and, as appropriate, propose any closeout measures. Three years after all the LRP activities have been deemed complete, the consultant will conduct a completion audit to assess the implementation outcomes against agreed objectives and confirm whether livelihoods have been restored to pre-project levels or better or if supplemental action is required.

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 details), and is managed by the company.

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

The project is situated in the Balkan mixed forests ecoregion of the temperate broadleaf and mixed forests biome (as designated by the Worldwide Fund for Nature - WWF). Before the company acquired the project, vegetation clearance had taken place on a portion of the PV plant by the site landowner. Before clearance, the area was characterized by airfield infrastructure, xeric grassland habitat, agricultural land and Robinia plantations. The OHTL routes will also pass through patches of the xeric grassland and agricultural land. The project does not overlap with any Protected Areas; however, the site is adjacent to the Ludogorie-Srebarna Natura 2000 Site (Sites of Community Importance designated under the EU Habitats Directive).

Priority biodiversity values associated with the project site, some of which are also Natura 2000 species, include the Common Tortoise (IUCN Red List – Vulnerable), Saker Falcon (IUCN Red List – Endangered), Eastern Imperial Eagle, Red-footed Falcon and European Turtle Dove (all IUCN Red List – Vulnerable), European Ground Squirrel (IUCN Red List – Endangered), Marbled Pole Cat, Giant Noctule, Schreiber’s Bent-winged Bat (all IUCN Red List – Vulnerable), Noctule, Lesser Noctule, Nathusius’ Pipistrelle (all IUCN Red List – Least Concern), as well as migratory bird species that were recorded during Spring migration surveys in 2023. The xeric grassland at the PV site is the only habitat type that likely had maintained its ecological functions prior to vegetation clearance. As for bat species, the buildings of the former airport, which were demolished during land clearance, are anticipated to have provided suitable roosting areas. 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 the xeric grassland habitat and associated priority biodiversity values.

A construction-phase Biodiversity Management Plan (BMP) will be developed and implemented as per ESAP#21, which will include pre-construction surveys to identify habitat features at the PV site that are associated with the Natura 2000 Site, Natural Habitat and priority biodiversity values (i.e. nesting birds, European Ground Squirrel, Marbled Pole Cat and bats). 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 and bat roosts during the construction phase. The company will appoint a biodiversity specialist, who will be responsible for the surveys, overall management, and reporting of all mitigation activities relating to the project.

Along the OHTL routes, to minimize risks of impacting priority biodiversity values using the airspace and which are also subject to Natural Habitat NNL requirements, bird flight diverters will be installed and staggered along the entire OHTL to ensure maximum coverage. A bird-safe design will be incorporated in placing the pylons to minimize the risk of collision and electrocution. Pre-construction surveys along the two OHTL routes will be conducted to identify high-risk areas for priority bird species to inform a post-construction fatality monitoring (PCFM) program. In the operation phase of the project, the company will implement the 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#22). The company will contract an internationally recognized and specialized consultancy to design and develop a fatality monitoring program in collaboration with a local consultancy. The program will take place for at least a two-year period with semi-annual reporting following a standardized template, but the actual timeframe of the PCFM program will depend on fatality results.

In addition to the PCFM program, the company will develop an operations-phase BMP (ESAP#23), informed by the pre-construction surveys and identify measures to meet Natural Habitat NNL objectives. The operations-phase BMP will include a Habitat Restoration Program for the xeric grassland and associated priority biodiversity values. A qualified expert with international experience will be procured to develop the Habitat Restoration Program, which will, at the minimum, include (i) recommendations for restoration measures and opportunities to maintain biodiversity on-site and (ii) a clear demonstration of how NNL will be achieved, including any off-site conservation measures, notably for bats. The company will coordinate with relevant stakeholders in developing and implementing the operations-phase BMP and Habitat Restoration Program, including local experts and the Regional Inspectorate of Environment and Water (RIEW), responsible for managing the Natura 2000 Site.

The Stakeholder Engagement Plan (SEP) developed for the project is consistent with IFC's PSs and establishes the principles for engagement, stakeholder identification and mapping, engagement methods/ plans, and an external grievance mechanism (GM). It also includes engagement with vulnerable groups and is designed to encourage women's participation.

Stakeholder engagement completed to date includes in-person meetings with key local stakeholders, an ESIA scoping survey in August 2023 (110 people), and a Draft ESIA disclosure session ‘Open day’ in March 2023 (31 people in attendance). Stakeholders engaged include local community representatives, landowners, farmers, local authorities, local businesses, representatives of educational institutions, and local police. Future engagement planned includes socio-economic surveys, focus group discussions, key informant interviews (as part of Social Baseline Data collection), and final ESIA disclosure (expected June 2024). The project information disclosure package will include soft and hard copies of NTS, project presentation leaflet, SEP, and grievance mechanism (Bulgarian and English. These documents will also be available via Rezolv’s website: https://rezolv.energy/project/st-george-solar-plant/.

The project’s GM was established and operationalized during the ESIA process and is generally aligned with IFC PS. It is managed (and will be during the construction and operations) by the company and is accessible to all interested and affected stakeholders. The project's GM will be further disseminated and operationalized during the completion of the ESIA process and implemented by the company’s Community Liaison Office. The grievance mechanism sets out clear procedures for receiving, documenting, and addressing complaints in an easily accessible and culturally appropriate language understandable to communities. The mechanism was designed to be accessible for both genders and any vulnerable groups.

As per ESAP#24, the company will update and implement its SEP before the start of construction activities.  The revised SEP will describe the outcomes of engagement activities undertaken to finalize the ESIA and update the 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. The company will ensure that its community liaison officer/team member receives adequate training on implementing IFC PSs and gender inclusivity awareness training before the commencement of construction activities.

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.                                                

R-Engineering EOOD.
11A Aksakov Street, Floor 4, Office 2
Sofia, Sredets Region 1000 Bulgaria