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 proposed investment involves the construction and operation of a large-scale solar energy project and associated power transmission lines, which entail potential risks related to workers' conditions and supply chain risks, use of natural resources, community health and safety, land acquisition, and biodiversity.

Key E&S aspects associated with the project are: (i) adequacy of E&S assessments in line with IFC PS; (ii) E&S oversight capacity during the construction phase of the Project to be undertaken by external contractors; (iii) potential labor influx (iv) corporate and project-specific Environmental and Social Management System (ESMS); (v) labor and working conditions; (vi) management of supply chain risks; (vii) use of natural resources; (viii) land acquisition and involuntary resettlement; (iv) potential biodiversity impacts; (x) cumulative impacts; (xi) stakeholder engagement and community grievance mechanism.

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

Policy

At the corporate level, the Company has detailed E&S policies, which are applicable to all ACWA Power’s subsidiaries, new projects and contractors. The policies form an important component of ACWA Power’s E&S management framework, which includes a HSSE Policy Statement that commits the company to providing a safe and healthy working environment and promote a culture of zero harm in the workplace.

As per ESAP #1, ACWA Power will update its HSSE Policy statement to include a commitment to comply with national HSSE legislation in the countries of operation, applicable IFC PS, and the protection of human rights.

Environmental and Social Management Systems

ACWA Power implements an integrated corporate ESMS which transfers corporate policies into protocols aligned with the IFC PS. ACWA Power’s ESMS Implementation Manual (“Manual”) covers several E&S topics including leadership and management, internal organizational capacity, effective communication and consultation, contractor management, hazard identification and risk management, construction and commissioning, emergency preparedness and response, monitoring audit and inspection, incident reporting, and performance evaluation.

The corporate HSSE Management System cascades to all projects implemented by the Company in the various countries of operation and provides the corporate guidance for the ESIAs, ESMS and ESMPs that are developed for each project. The HSSE documentation covers four levels: zero (corporate), one (business unit), two (country) and three (project/SPV level).

ACWA Power’s subsidiary for operation & maintenance, NOMAC, is also ISO certified (14001, 9001, 45001). NOMAC’s Environmental Policy includes a commitment to comply with national legislation and lender requirements. The Company’s Occupational Health and Safety (OHS) policy includes a commitment to promote a positive safety culture, provide training to employees, identify and assess risk, and reduce residual risk by implementing a hierarchy of controls.

In accordance with ESAP #2, ACWA Power will prepare a series of framework documents that provide guidance on how to apply the IFC PS so that there is overall consistency in the approach used. The framework documents will address, inter alia, the approach to ESIAs (including standard terms of reference), mandatory stakeholder engagement planning and implementation requirements, risks associated with the use of contracted workers, forced and child labor in the supply chain, details of how workers organizations can be established amongst EPC contractor workforces, minimum standards for worker accommodation, approach to resettlement and biodiversity management. The framework documents will detail the approach to be used when IFC PS requirements are triggered with respect to the above issues.

Identification of Risk and Impacts

During the feasibility assessment and development or acquisition phases for new assets, HSSE issues are identified and managed by undertaking HSSE due diligence assessments and then commissioning ESIAs completed by external consultants in accordance with national legislation and IFC PS. At the start of construction, project specific HSSE and social action plans are established and cascaded to the EPC contractors as part of their contractual obligations.

ACWA Power is currently updating the ESMS Implementation Manual which, as per ESAP #3, will include an E&S risk assessment procedure, including site screening, within the general Compliance Procedure. The risk assessment and site screening will be applied by ACWA Power at an early stage of project development to identify potentially significant sources of E&S adverse risks and impacts during site selection and project design, so that the mitigation hierarchy can be used to avoid/minimize adverse risks and impacts to the extent possible. The E&S risk assessment procedure will include the use of screening tools and methods associated with the avoidance and minimization of adverse impacts to receptors as defined in each IFC PS.

The Project that will be financed with IFC’s proceeds has been broadly defined and the locations for the PV plants, BESS facilities, substations, and the indicative route of TLs are known and have been agreed with the government. The ESIA Scoping Reports for the Project include details of its physical footprint, except for the TL towers which are yet to be defined and contain detailed terms of reference (TOR) for the ESIAs that are currently being prepared (separately) for Samarkand 1 and 2. The ESIA Scoping Reports and TOR for the ESIAs reflect the applicable requirements from ACWA Power’s HSSE Management System Framework and the IFC PS.

As per ESAP #4, prior to the start of construction, the SPV will complete the ESIAs and ensure that they are compliant with the IFC PS and use the outcome to inform the development of Project specific E&S documentation (see below) and the detailed routing, siting and design aspects of the Project.

Upon further delineation of the technical and E&S aspects of the Project and, as per ESAP #5, the Project will be subject to an E&S Due Diligence (ESDD), that will be undertaken by independent Lenders’ advisors. The ESDD will benchmark the Project against IFC Performance Standards and relevant WBG Environmental, Health & Safety (EHS) Guidelines as applicable E&S assessment criteria.

Management programs, Monitoring and Review

ACWA Power’s Global HSSE Performance Monitoring and Reporting Procedure describes the way in which E&S performance data are gathered from business units, country-level performance, and project level, in a consistent manner using Key Performance Indicators (KPIs), so that HSSE performance can be benchmarked between countries and individual projects. ACWA Power also has an Occupational Health, Safety & Environment (OHSE) Audit Procedure which is applied to projects and includes an audit scoring and classification system, so that the outcome of audits can be benchmarked across individual assets.

Typically, over 50 HSSE audits of operational and construction sites are carried out every year by the Company, supported by about 40 HSSE audits undertaken by independent third-party auditors.

For projects under construction or operated by SPVs, compliance with applicable ESIAs is monitored by both the project company’s and the corporate HSSE teams, who are supported by independent environmental consultants that conduct audits on behalf of the projects’ Lenders.

ACWA Power uses a digital platform called 'Synergy Life’ to collect and analyze HSSE performance data including the HSSE performance from projects and EPC contractors. ACWA Power has also recently launched a HSSE scorecard system with 25 KPIs for each project, as a tool to incentivize the HSSE performance. External HSSE audits are performed quarterly and reported in Synergy Life. As per ESAP #6, the Company will expand the functionality of the digital platform used to capture social KPIs including those relating to stakeholder engagement and grievance management, EPC Contractor’s compliance to PS2 and national labor laws (including the workers grievance mechanism), and Company/SPV audits undertaken on EPC Contractor’s worker accommodation facilities.

As per ESAP #7, the SPVs will develop an ESMS and relevant project-specific E&S Management Plans (ESMPs) to address risks and potential impacts identified through the ESIA process and provide framework guidance to the EPC contractor and its subcontractors. The ESMS and ESMPs will comply with the IFC PSs and WBG EHS Guidelines, will address the construction phase of the Project and will be approved by IFC before mobilization of the contractor and before any civil and ground works commence.

As part of the EPC contract for construction of the Project, the SPVs, as per ESAP #8, will request that the appointed EPC contractor develop and implement an ESMS and ESMPs before mobilization, specifically addressing Project construction activities, that mirror the SPVs’ ESMS and ESMPs, and assigns adequate resources to E&S management. The EPC contractor’s ESMS and ESMP will be approved by the SPVs before any construction activities begin.

Organizational Capacity and Competency

The Company, its subsidiaries and affiliates have over 100 staff members with HSSE responsibilities deployed at corporate offices, operational sites and construction sites. The Company holds annual HSSE strategy workshops with regional HSSE Managers and Site HSSE team members to recognize the team achievements, discuss gaps and develop strategic targets and KPIs for future years.

ACWA Power has a Vice Presidency for HSSE at the corporate level, reporting directly to the Chief Executive Officer, under which there are a number of operational units responsible for: HSSE Construction, HSSE Operations, Management Systems and Process, People Based Safety and Human Operational Performance, HSSE Governance and Assurance.

ACWA Power’s organizational charts demonstrate a clear commitment to manage ESHS issues during design, construction and operations of their assets. The Company’s organization includes staff at corporate level in charge of ESHS management, as well as dedicated staff at country and project level, including country HSE coordinators, asset HSE managers and E&S personnel. Interviews with E&S staff at headquarters and during the field visit to the Bash wind farm undertaken as part of IFC’s appraisal confirmed that E&S staff have the necessary expertise and competencies to develop and implement E&S plans to manage E&S risks and impacts of new and existing projects. As per ESAP #9, the Company will hire a Social Manager and a Biodiversity Manager at corporate level to oversee the social and biodiversity aspects of the corporate ESMS, to support implementation of the E&S site screening procedure and impact assessments, and to provide guidance across the 12 countries of operations and individual project teams on PS2, PS4, PS5, PS6 and PS8 aspects.

In Uzbekistan, the Company has an in-country E&S team that consists of an E&S Manager and a Biodiversity Manager (this position is currently vacant and being recruited). In addition, each active project has an E&S team that typically includes an E&S Manager, E&S engineers, OHS professionals, a Social Manager and one or more Community Liaison Officers (CLOs). All of the Company’s projects in Uzbekistan have been developed according to the E&S requirements stipulated in the respective ESIA studies, which are disclosed on the Company’s website: www.acwapower.com/en/sustainability/hsse-management/.

The E&S aspects of the existing assets under construction or operational in Uzbekistan are managed by the country team, based in Tashkent, with the support of the project teams, including the respective asset/project director and internal E&S specialists based in the country or on site. For both Samarkand 1 & 2, project-specific and site-based staff are yet to be hired and the EPC contractor has yet to be selected. As per ESAP #10, the SPVs shall appoint the following site-based, qualified E&S related personnel for each project: i) E&S Manager who will have overall responsibility for environmental, social and health and safety management, compliance and implementation of the ESMS and ESMPs (this shall include compliance with PS2 and national labor laws); ii) a Social Manager; iii) a CLO and iv) an OHS Manager to be supported by a suitable number of OHS inspectors commensurate to the size of the workforce that will be deployed during construction.

As per ESAP #8, the SPVs will contractually require the EPC contractor to appoint and retain appropriate counterparts to its E&S staff including: i) competent and qualified Health, Social, Safety, and Environment (HSSE) manager and ii) deputy HSSE manager, iii) qualified CLOs, iv) OHS Officers at a ratio of one (1) for every forty (40) workers at each site; and v) an ecologist to implement the Biodiversity Management Plan.

Emergency Preparedness and Response Plan (EPRP)

ACWA Power’s ESMS Implementation Manual describes the requirements under PS1 for an Emergency Preparedness and Response Plan to be prepared by the EPC Contractor and includes an outline content and checklist. As per ESAP #8, a project-specific Emergency Preparedness and Response Plan will be prepared as part of the EPC Contractor’s ESMS. Details of this plan shall be based on engagement with local communities and relevant government agencies to share emergency contact details and ensure that response measures are agreed upon and effective for each reasonably foreseeable emergency.

As per ESAP #11, an Emergency Preparedness and Response Plan for operation of the facilities will be prepared by the SPVs or by the operating company of the Sponsor’s group of companies, as appropriate. The plan will be based on ACWA Power’s ESMS Implementation Manual, as well as on national regulations and engagement with regulatory agencies and communities, as appropriate.

E&S Contractor Management

ACWA Power has a systematic process in place to screen EPC contractors, and O&M contractors when these are retained. E&S requirements are included in the Invitation to Tender documents to ensure that EPC contractors make adequate provisions to address the Company’s requirements during construction of the projects.

ACWA Power applies its Global HSSE Performance Monitoring and Reporting Procedure to supervise and report on the E&S performance of the EPC Contractor during the construction stage. HSSE data is compiled and reported through the (updated) ‘Synergy Life’ digital platform. Regular audits and inspections will be undertaken on the EPC Contractor in accordance with the ACWA Power OHSE Audit Procedure. During the operation & maintenance stage, the E&S aspects will be managed, and performance monitored, by NOMAC, a subsidiary company of ACWA Power.

The Project will be constructed by an EPC contractor, who will mobilize a substantial workforce to the Project areas. As part of its ESMS and ESMPs (ESAP #7), the SPVs will develop a Contractor Management Plan defining its approach to managing the E&S performance of their contractors, subcontractors, and other third parties during the various phases of the project. The approach to contractor management will be consistent with the general principles described within IFC Good Practice Note: Managing Contractors’ Environmental and Social Performance (https://www.ifc.org/en/insights-reports/2017/publications-gpn-escontractormanagement).

PS 2 – Labor and Working Conditions

As of February 2024, the Company employed approximately 3700 employees, of which 90% are men and 10% are women. There are no gender targets established although the participation of females in the Company’s workforce has been increasing over time. In accordance with ESAP #2, ACWA Power will develop a corporate Gender Strategy to demonstrate its commitment for increased participation of women in the workforce. The Gender Strategy will include gender targets which will be established at a corporate level, and country-level, and at projects level to reflect the temporary and local recruitment of women by EPC Contractors. A Gender Management Plan will be prepared by the SPVs and included in the ESMPs, to implement the Strategy at Project level.

ACWA Power has corporate HR policies, which are aligned with IFC PS2, and cover aspects such as hiring, working conditions and terms of employment, freedom of association, non-discrimination and equal opportunity, dismissals. HR policies also include a Code of Conduct and Ethics Policy. Additionally, ACWA Power implements a Human Rights Policy which explicitly makes commitments rejecting child and forced labor, respecting freedom of association and collective bargaining, and non-discrimination. These policies apply to all subsidiaries of ACWA Power.

Worker’s Organizations

The Employment Handbook prepared for the Bash Wind Project reviewed during the Appraisal does not include details of worker’s organizations. As per ESAP #2, ACWA Power will prepare a PS2 framework document that will include details of how workers (including the EPC Contractor’s workforce) are to be informed of their right to join or form a union and undertake collective bargaining activities.

Non-discrimination and Equal Opportunity

In accordance with ACWA Power’s HSSE Policy, Human Rights Policy, and Code of Conduct and Ethics Policy, discrimination in the workforce is prohibited and equal opportunities are provided to all employees. SPVs prepare Human Resources Policies and Procedures that reflect this corporate-level requirement.

Gender-Based Violence and Harassment (GBVH)

In accordance with ACWA Power’s HSSE Policy, Human Rights Policy, and Code of Conduct and Ethics Policy, GBVH is prohibited through the requirement to maintain an equal, respectful, and dignified workplace. SPVs prepare Human Rights Policies that reflect this corporate-level requirement. ACWA Power’s workers and workers provided by the EPC Contractor are required to sign a Code of Conduct and receive training on its content as part of their initial HSSE induction.

Worker’s Grievance Mechanism

ACWA Power has developed and implemented a worker grievance mechanism which is available to all direct workers and contracted workers provided through EPC Contractors. The mechanism includes an on-line reporting system managed by an independent third party which allows anonymous grievances to be raised. A grievance register is held at a corporate and project level, and all grievances are tracked until they are resolved. This grievance mechanism is available for use at SPV level.

Supply Chain

ACWA Power has developed a corporate Vendor Management Procedure although this does not include the prohibition of child labor or forced labor in the supply chain, or the risk of significant safety issues amongst supply chain workers. In accordance with ESAP #12, ACWA Power will develop a Responsible Sourcing Policy that manages the environmental, social and economic risks associated to procurement practices and raw material sourcing, including labor issues as defined by PS2’s supply chain section associated in particular to components of solar PV and BESS projects. The Policy will describe how the procurement process will be implemented and the roles and responsibilities of those involved in procurement and should be aligned with PS2 requirements. The Policy will also apply to third-party organizations associated with ACWA Power’s projects, such as EPC contractors and suppliers of PV, BESS, and other components.

Through the Responsible Sourcing Policy, ACWA Power will identify, manage and remediate supply chain risks associated with forced labor, as well as any other significant environmental and human rights risks and impacts. This includes due diligence and management procedures for the sourcing of solar PV modules and batteries, in accordance with Good International Practice.

With respect to solar and battery supply chains, the Policy will include management procedures to address the following:

• Mapping and risk assessment of suppliers before onboarding and during life of the business relationship.

• Measures to be implemented in case the mapping reveals potential exposure to forced labor.

• Inclusion of appropriate clauses in procurement notices and contracts with suppliers on labor risks and management thereof.

• Self-declarations and code of conduct for suppliers.

• Labor audits of the PV module manufacturer, as required and to the extent possible sub-suppliers’ manufacturing facility(ies) during the production if risk of forced labor has been identified.

• Requirements for traceability protocols from solar suppliers to conduct as per the provided Bill of Materials (BOM).

• Requirements for solar suppliers to conduct (or provide) traceability audits of their supply chains if requested.

• Document third-party verification of the origin of the BOM materials as listed in the BOM(s).

Occupational health & Safety

ACWA Power has a corporate Occupational Health and Safety Management System (OHS MS) for its operational unit accredited with ISO 45001, based on an OHS Policy that has been approved by the company’s Board, which defines OHS principles and commitments made by senior management and promoted at all organizational levels. At the project level, the SPVs contractually require their contractors/sub-contractors to adhere to ‘OHS Minimum Requirements’ and develop and implement a site-specific OHS MS, including plans and procedures of a scale appropriate to their scope of work. ACWA Power, through each project SPV, assesses the adequacy of their contractors/subcontractors OHS MS and ensures any identified deficiencies are addressed before site mobilization. All workers complete basic OHS training, and supervisory staff and employees undertaking high-risk activities complete specific OHS training.

As per ESAP #8, the SPVs will request, prior to start of construction, that the EPC contractor develops an ESMS and a set of ESMPs that mirror the Company’s ESMS. The Contractor’s ESMS and ESMPs shall be approved by the Company prior to mobilization of the contractor to the site. This shall include a Worker Accommodation Plan that reflects IFC’s Guidance Note on Worker’s Accommodation: Processes and Standards.

PS 3 – Resources Efficiency and Pollution Prevention

Resource Efficiency and Green House Gases (GHG)

ACWA Power is fully engaged in the transition from carbon-emitting energy generation and desalination to renewable and sustainable energy sources. The Company’s strategy is focused on the decarbonization of its portfolio and on the development of renewables and transitional low CO2e emitting assets. ACWA Power has a publicly disclosed target to reduce its emissions intensity by 50% in 2030, compared to its emissions in 2020, and to achieve net zero emissions by 2050.

GHG emissions during the construction phase of the project will be calculated as part of the ESIA and will include all transportation activities and machinery operation associated with the construction phase of the project, as well as any site-based power generation. Scope 2 emissions will be determined on the basis of the temporary power consumption associated with the construction activities, in case that a temporary power supply to the construction sites is established. Scope 3 emissions will be provided by vendors of PV modules, batteries and other equipment. During operation, the Project will play an important role towards the Company’s GHG emissions reduction targets for 2030 and 2050.

Water Use

As per ESAP # 13, water use during the construction and operation phase of the Project will be assessed as part of the detailed design of the Project, supported by the ESIA studies, which will include an assessment of alternative technologies for cleaning the solar modules during operation of the plant, as this activity may require substantial volumes of water that may affect the overall water availability in the region. Risks and impacts related to water use, community water availability and water efficiency will be assessed through the ESIAs and managed through the ESMPs. Water will only be sourced from appropriately permitted sources, in compliance with local regulations and in line with the IFC PS.

Pollution Prevention and Control

Pollution generated during the construction and operation of renewable energy projects is generally minor and readily mitigated through standard pollution prevention and control measures. The Company will require its contractors/subcontractors to comply with all environmental license conditions, with the requirements of the project-specific ESIA, and associated ESMS and ESMPs, covering such aspects as fugitive dust from earth-moving activities, noise and exhaust from construction machinery; sanitary effluents from worker facilities (typically disposed of via septic systems), and non-hazardous and hazardous solid waste. As per ESAP #12, the EPC Contractor will be contractually bound to carry out a due diligence audit of the available waste disposal facilities prior to mobilization to the site and only select those facilities that have adequate environmental safeguards in place to meet IFC PS and WBG EHS Guidelines.

PS 4 – Community Health, Safety, and Security

Risks and impacts of all Project components to host communities and the public will be assessed during the ESIA process. Based on the findings, appropriate mitigation measures will be defined and implemented during the design, construction and operation the Project.

The main road traffic risk associated with the Project is related to transporting general construction materials, PV modules, batteries and equipment required to build the assets from vendor facilities. Additional risks relate to daily transportation of project personnel. Risks associated with all transport will be quantified and managed through a Transport Risk Assessment and Management Plan that will be developed by the Contractor as part of its ESMPs (ESAP #8).

Community risks associated with the temporary presence of a large workforce during the construction phase of the project will be addressed through the development and implementation of a Labor and Working Conditions Management Plan, to be part of the Company’s and Contractors ESMPs, which will include provisions for suitable accommodation as well as a code of conduct for interacting with the local communities.

During operation of the facilities, community risks could include electrocution, fires and explosions. To minimize such risks, all electrical installations will be fenced and secured, and BESS facilities will be sited at a suitable distance from other structures, taking into consideration fire and explosion risks. As per ESAP #11, the SPVs, or the company operating the Project assets, will develop an Emergency Preparedness and Response Plan, based on consultation with regulatory agencies and local communities. The Project’s community grievance mechanism (see ESAP #15) will be available for any concerns raised by members of the community in relation to the above-mentioned risks on community health and safety.

Security Personnel

In accordance with ESAP #1, ACWA Power will update their HSSE Policy to include commitments concerning security and the respect of human rights that will be applied to all its projects. Additionally, as part of ESMSs developed the Project (ESAP #7), the SPV will develop and implement a Security Management Plan aligned with IFC PS4 and the Voluntary Principles of Security & Human Rights. The plan will include a Code of Conduct for site security personnel, a security risk assessment and incident reporting, and an investigation process. The Project’s community grievance mechanism (see ESAP #15) will be available for members of the community or employees in the event of a violation of the code for security personnel or other grievance related to security personnel.

PS 5 – Land Acquisition and Involuntary Resettlement

As per ESAP #2, ACWA Power will prepare a series of framework documents that provide guidance on how to apply PS5 to individual projects.

The land required for Samarkand 1 for project components (apart from the TL towers) is expected to cover some 1,041 hectares, part of which is allocated to smallholder and commercial farmers and the remainder used for livestock grazing. Livestock sheds are present although none are used as residential dwellings. There is a cluster of residential houses along the northern end of a 19 km TL route comprising the loop-in-loop out connections which connect the new substation to the grid.

The land required for Samarkand 2 for the PV plant, underground cable and substations comprises 1,112 hectares and is mostly used for livestock grazing. Whilst some livestock sheds are present, the land is not used for residential purposes. Along the TL route there are several orchards and areas of crop cultivation.

The land required for the project will be expropriated in accordance with the PPA and Presidential Decree, which sets the legal basis for the land acquisition, with the areas required being reclassified for industrial use. A Land Acquisition and Livelihood Restoration Plan (LALRP) is being prepared for each site by the SPVs, according to national legislation and Lender standards, including PS5, in parallel with the ESIA process. As per ESAP #14, the SPVs will implement the LALRP and once completed, a Completion Audit will be undertaken by an independent resettlement specialist to check that the PS5 objectives are met, and resettlement activities were conducted accordingly.

It is necessary to undertake a micro-siting study for the installation of the TL towers. As per ESAP #7, the SPVs will develop and implement a Tower Siting Procedure that will be applied to the Project, to ensure that the physical footprint takes into consideration the avoidance/minimization of impacts on nearby E&S receptors in accordance with the mitigation hierarchy, in line with the IFC PS.

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

The Company has commissioned independent consultants to carry out ESIA Scoping Reports and preliminarily identify biodiversity risks and impacts associated with all assets that will be developed as part of the Project.

The Project, including both Samarkand 1 and Samarkand 2 sub-projects, is situated in the temperate grasslands, savannas and shrublands biome of the Alai-Western Tian Shan steppe ecoregion (as designated by WWF). Samarkand 1 components are mostly located in arid steppe grassland that has been converted to agricultural land in some parts, and in others has been degraded due to ongoing grazing. Along the TL of Samarkand 1 are also orchards. The main habitat type is similar in Samarkand 2, where project components are also mostly located in arid steppe grasslands. Along the TL, there are orchards, as well as hedgerows, xerophytic, dry and wet shrublands, wetlands and riparian habitats. The project does not overlap with any Legally Protected or Internationally Recognized Areas.

As per ESAP#4, the SPVs will carry out ESIAs that will classify and map habitat types as per IFC PS6 definitions and identify priority biodiversity values at the project sites including the TLs through baseline surveys. Biodiversity assessments in the ESIA will also rely on existing data and information from available resources including engagement/consultation with relevant stakeholders. A Critical Habitat Assessment (CHA) will be conducted against PS6 criteria and thresholds to identify Critical Habitat (CH) biodiversity values that overlap with the Project sites and infrastructure. In line with PS6 requirements, project development in Natural and Critical Habitat will be avoided, and where avoidance is not possible the Project will demonstrate No Net Loss (NNL) in areas of Natural Habitat (NH), and Net Gains (NG) in CH through implementation of the mitigation hierarchy. The Company will develop a Biodiversity Framework document to integrate biodiversity conservation and management into its E&S Management Framework (ESAP#2). The Biodiversity Framework will, at the minimum, include Company’s commitment to (i) screen locations of all assets to identify biodiversity values, (ii) conserve and restore Natural Habitat and priority biodiversity values, (iii) mitigate impacts on biodiversity to reach NNL in NH and NG in CH, (iv) maintain ecosystem services, (v) use Good International Industry Practices (GIIP), best available information and scientifically credible data,  (vi) develop/allocate adequate resources and capacity to implement biodiversity management controls and conservation actions, and (vii) engage with key stakeholders to incorporate their input and concerns into biodiversity conservation planning and implementation.

A project-specific Biodiversity Management Plan (BMP) will be developed to set forth measures to avoid and minimize impacts on priority biodiversity values during the construction and operations phases of the Project under the supervision of an appointed biodiversity expert. If the Project is in CH, a fit-for-purpose Biodiversity Action Plan (BAP) and Biodiversity Monitoring and Evaluation Plan (BMEP) will be developed to outline the Project’s mitigation strategy and how NG will be achieved for CH values 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.

Along the TL routes, baseline surveys will identify high risk areas for bird species, and other priority biodiversity values. Impacts on these values will be avoided and minimized at the design phase of the Project through incorporating mitigation measures to address collision and electrocution risk using best available technology. During the operations phase of the Project, the key measure for the TLs will be 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, the SPVs will implement a Post-Construction Fatality Monitoring (PCFM) program 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. The SPVs will contract an internationally recognized and specialized consultancy to collaborate with a local consultancy to conduct baseline surveys, design mitigation measures, and develop and implement a PCFM program. The results of the PCFM will inform the mitigation measures to be developed within the scope of the operations-phase BMP. 

PS8 – Cultural Heritage

Engagement with the Cultural Heritage Agency Regional Office in Uzbekistan has indicated that there are no designated tangible cultural heritage sites within each of the project sites. However, in view of the size of the land plots that will be required for the development of the Project and based on the cultural context of the Project area, there is the potential that Cultural Heritage features may be present that may include isolated artifacts or burial sites.

As part of the change of land use process that the SPVs will have to undertake to obtain a designation for industrial activities, and in accordance with the ESIA TOR included in the ESIA Scoping Reports, a Cultural Heritage survey will be carried out by an archaeologist licensed by the Ministry of Culture of Uzbekistan. Based on the findings of the survey, the SPVs may need to retain an international archaeologist to develop a Cultural Heritage Management Plan (ESAP #7) aligned with PS8. The plan will include avoidance and safeguarding measures for any immovable cultural heritage and a chance find procedure to be implemented during construction of the facilities.                                                   

ACWA Power’s ESMS Implementation Manual does not include guidance on how PS1 requirements associated with stakeholder engagement should be implemented. As per ESAP #2, the Company will develop framework documents that describe how PS1 is to be applied. A Stakeholder Engagement Plan for each project is under preparation as part of the ESIA process and will later become part of the Project ESMS and ESMPs.

Stakeholder engagement has been carried out by the ESIA consultant during preparation of both ESIA Scoping Reports with national and regional Government representatives, men and women from project affected communities, and sedentary and seasonal land users. During the ESIA Scoping stage, Stakeholder Engagement Plans for Samarkand 1 and 2 have been prepared covering the remaining ESIA activities, reflecting the outcome of a detailed stakeholder identification and analysis activity. 

As per ESAP #15, the SPVs will develop and implement project-level Stakeholder Engagement Plans (SEP) to meet PS1 requirements, regarding disclosure of information, consultation, ongoing reporting to affected communities, and a formal community grievance mechanism that includes methods to: a) communicate the grievance mechanism to stakeholders; b) receive and register complaints, including anonymous complaints; c) screen, assess and address issues raised; d) document and track grievances; e) provide feedback to stakeholders on grievance mechanism results; and f) monitor and adjust the management program including defining KPIs, as appropriate.                                                   

Company: ACWA Power Company

Point of Contact: Shariq Rahman

Title: Vice President & Corporate Finance Head

Telephone Number: 00 966 50 530 4320

Email: srahman@acwapower.com

Website: www.acwapower.com