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
GQ has a corporate-level Health, Safety, Environment, Social and Security (HSESS) integrated management system (IMS), including a policy covering six broad aspects, namely i) health and safety; ii) environment; iii) social and local socio-economic development; iv) security; v) labour and employment; and vi) safeguarding (addressing gender-based violence, sexual exploitation and abuse, sexual harassment, modern slavery and human trafficking). GQ policy and IMS are broadly aligned to IFC PS requirements and ISO 14001 on environmental management and ISO 45001 on Occupational Health and Safety (OHS) management.
GQ IMS sets out HSESS requirements for contractors and Contractor Management Plans (CMPs) are applicable during the construction phase while during operation, all contractors must follow GQ’s asset HSESS policies, plans and procedures. Both the Turbine Supply Agreement (TSA) and Balance of Plant (BOP) Agreements require the contractors to comply with all applicable HSE regulations including the Safety Plan and E&S Requirements Plan (ESRP) in its design, access arrangements, construction and operations. Additionally, each contractor is required to develop and implement an E&S Management System (ESMS) to GQ’s satisfaction and in accordance with, and in support of, the ESRP and GQ’s Construction E&S Management Plans (C-ESMPs). CEN will adopt and incorporate GQs policy and HSESS IMS as their own for the construction and operational phase of WEF and construction phase of the T-Line. This would also include initiatives to enhance positive impacts on gender (ESAP #1).
The operation of the T-Line will be under EDM, for which EDM’s existing Environmental Policy will apply. EDM’s environmental policy commits to compliance with legal requirements, protection of the environment, continuous improvement in environmental performance and the prevention of pollution. EDMs policy will be updated to include commitment to social and occupational health and safety aspects and align their policy to IFC PSs and applicable World Bank Group (WBG) EHS Guidelines (ESAP #2). Sufficient information of EDM’s ESMS was not available at the time of the appraisal to be able assess EDM’s capacity to operate and maintain the T-Line. Hence, an independent audit of EDM’s ESMS and HSE resources will be undertaken of the T-Line and an action plan will be developed and implemented for identified gaps prior to start of operations (ESAP #3).
The Project E&S risks and impacts identification comprise of i) the initial EIA and ESIA Addendum (including an EMP) for the WEF and the T-Line; ii) Resettlement Action Plans (RAPs) for the WEF and T-Line; iii) a draft SEP; iv) bird and bat monitoring reports; v) a CHA in accordance with PS6; and vi) a draft BAP, which includes an offset feasibility assessment. Collectively, these documents are considered the E&S disclosure package. Following multiple exchanges and updates during the project E&S appraisal, IFC consider the E&S disclosure package commensurate to the risks and impacts for a wind project of this scale and nature.
The initial EIA and a public consultation were completed and obtained environmental approval from the Ministry of Land and Environment (MTA) in March 2022 for an initial design of 63 MW. The project was later redesigned to include larger and additional turbines with a total capacity of 120 MW. CEN confirmed with MTA that revision of the EIA will not be required. Approval for the increase in capacity to 120 MW was issued by MTA on 14 December 2023. Subsequent to the EIA, an ESIA and EMP were developed by the project to align the impact assessment to Lender standards.
CEN together with the BoP will undertake a Pre-Construction Survey (PCS), to document the existent conditions of all impacted land prior to construction of the wind turbine platforms, roads (including any upgrades), facilities (offices, sub-station, camps, etc.,), and/or use of batch plants, quarries, borrow pits, waste facilities, etc. The PCS will pay particular attention to any pre-existent infrastructure, any sensitive E&S receptors and any locations where construction will be undertaken. A report will be issued including pictures and any additional avoidance and/or minimization and mitigation control measures required to be implemented where relevant and, in alignment with IFC PSs and the framework and principles of the RAP approved for the project (ESAP #4).
Some E&S management plans have been developed as part of the ESIA Addendum i) Waste Management Plan; ii) Emergency Preparedness Response Plan (EPRP); iii) Community Safety and Security Framework Plan; iv) Grievance Redress Mechanism; among others. GQ will also develop C-ESMPs for the construction of both the WEF and T-Line. The C-ESMP will address gaps identified in the ESIA Addendum (including the EMP) and the ESDD; and will be supplemented by additional management plans as required (such as OHS, a Community Health and Safety, Local Recruitment, Influx management, etc). CEN will incorporate the C-ESMPs as part of its HSESS IMS and include the requirement for similar management implementation plans to be developed by contractors (ESAP #5).
During the operational phase of the WEF, CEN IMS will apply whereby the needs for management plans is defined. An assessment will be undertaken prior to commissioning, to ensure all risks and impacts are covered and the required HSE organization and supporting E&S management plans are in place (ESAP #6). As for the T-Line, the audit of EDM’s ESMS will determine any management plans needed for operation and maintenance of the line, as per ESAP#3.
The Project is currently supported by GQ Senior Environmental and Social Governance (ESG) Manager, GQ Biodiversity Specialist, Source Energia HSE Manager and a CEN appointed Community Liaison Officer (CLO). CEN will appoint a suitably experienced HSE Manager, supported by a qualified Social (with experience in implementing IFC PS5) and Biodiversity Manager (familiar with IFC PS6). A suitable number of health and safety, environmental, community liaison and labor management officers will also be recruited to support the HSE Manager. A similar HSE structure will be put in place by the BOP and TSA contractors, to adequately support the ESMS implementation of the WEF and T-Line. CEN construction phase HSE organizational structure will be in place six months prior to the start of construction and maintained till stable operations is reached (ESAP #7). Similarly, an HSE organization commensurate with the E&S risk posed by the operational phase will be defined prior to commercial operations. The company will also implement a woman working group to empower women in engineering and technical roles for the operational phase and disclose information regarding potential opportunities to the local community ESAP #6.
For the operation of the T-Line, EDM will designate the required qualified EHS resources to implement its ESMS and audit action plan, as per ESAP #3.
GQ requires the contractor to administer training program to the project workforce comprising of health and safety requirements; E&S requirements; basic construction skills and operation of the plant. CEN will develop training plans for construction and operation phase, which will also cover E&S broader aspects such as biodiversity management, resettlement, lively hood restoration, security, gender-based violence, among others.
As per GQ IMS, CEN will develop a site-specific EPRP tailored to the project phase and asset type based on a thorough site-specific risk assessment. Contractors are mandated to collaboratively develop site-specific EPRPs with the local community and existing third-party emergency units which will be required as part of the C-ESMP, ESAP #5.
GQ systematically monitors its HSESS impacts of its projects, to identify trends and address non-compliances effectively. Compliance obligations, such as project permitting, legislative requirements, lender requirements, internal performance monitoring, and incident statistics, guide monitoring efforts. Key Performance Indicators (KPIs) have been established to outline the minimum monitoring and reporting expectations for Contractors from project development to decommissioning. During the construction phase, monitoring requirements will be defined in the CEN HSESS C-ESMP and supporting plans, with standardized reporting forms guiding Contractors in fulfilling statutory and lender obligations. Similar KPIs will be developed as part of operations of the project (refer to ESAP #5-6).
PS2: Labor and Working Conditions
The Project is expected to employ c. 600 workers (400 for the WEF and 200 T-Line) during the construction phase. While the Project will promote job opportunities for local community members, it is expected that a large portion of the workforce employed by the EPC contractor and subcontractors will come from outside the project area. Once in operation, the Project plans to employ approximately 20 people for the WEF while EDM will be responsible of the TCE.
Human Resources (HR) management for the Project is overseen by GEM’s HR Manager while a GQ ESG/Social manager is responsible for HR aspects of contract management. GQ has developed a corporate HR policy addressing aspects related to i) hiring; ii) workers’ rights; iii) working hours; iv) leave; v) remuneration; vi) human relations (including non-discrimination and non-harassment); vii) health and safety; and viii) disciplinary sanctions. Additional policies and procedures include a corporate Code of Business Conduct (CBC) and an Anti-Corruption and Bribery Policy. From 2023, GQ also publishes a Modern Slavery Statement on its corporate website. Prior to start of construction, CEN will adopt GQ CBC and will develop a similar HR and Labor management system in line with the Mozambican Labor Law and IFC PS2 requirements. The relevant HR and Labor management system and/or PS2 labor requirements will apply to all workers of the project including those employed by contractors and sub-contractors (ESAP #8).
GQ CBC does not condone any form of abuse or exploitation, including workplace discrimination, harassment or unfair treatment based on race, color, age, sex, sexual orientation, gender reassignment, disability, religion or belief, natural extraction or social origin. This is applicable during hiring, compensation, promotion and termination of employment. GQ also applies a zero-tolerance approach to any form of retaliation; Gender Based Violence (GBV); and sexual exploitation and abuse or any form of workplace sexual harassment (GVBH). CEN will include similar principles in the Project’s HR and Labor management system. Similarly, CEN shall develop a formal worker grievance mechanism, whereby workplace concerns can be raised and addressed. CEN will ensure that workers are informed on the mechanism at the time of hiring and will make it accessible to all workers. The worker grievance mechanism will be extended to all CEN direct employees and contractors and third-party employees of contractors and will consider confidentiality safeguards for reporting GBVH complaints (ESAP #9).
The Project will provide transportation to the local workforce from their homes in Namaacha town and surroundings to the Project site. For non-local workforce, the Project is assessing if workers will be housed in pre-existent housing facilities in Namaacha or in a fit for purpose accommodation camp for the duration of the construction phase. CEN will undertake a risk assessment of the workers’ accommodation options for the WEF and T-Line in line with the IFC/EBRD Guidance Note on Workers’ Accommodation and will undertake audits prior occupancy and on a quarterly basis thereafter (ESAP #10). The results of the risk assessment and the mitigation measures will be included in the C-ESMP including having appropriate facilities to accommodate female workers to avoid and/or minimize GBVH.
GQ hired a qualified consultant to undertake a supply chain assessment and a labor audit of two shortlisted WTG suppliers for the Project. The assessment did not find any evidence of child and forced labor. However, some non-compliance with PS2 labor, working conditions and OHS requirements were identified (e.g., exceeding limit of working hours and overtime; consecutive working days and some safety issues). A set of recommendations and corrective actions were provided. CEN will ensure that the contract with the selected WTG supplier makes explicit reference to the WTG supplier manufacturing and assembly facilities to be used for the Project. CEN will verify the implementation of the corrective action plan of the selected WTG supplier and will track all non-compliances and recommendations until satisfactorily closed out (ESAP #11).
CEN will also develop a supply chain management plan covering as a minimum i) the adoption of a supplier's code of conduct by the project; and ii) the provision for audits during construction and operations, including the possibility to undertake random checks and/or interviews (ESAP #12).
GQ's HSESS Policy and IMS commits to protecting its workforce and is applicable to all its projects. EPC contractors are required to develop a project H&S Risk Register during construction, meeting minimum national and ISO 45001 standards.
CEN will develop an OHS management system aligned to ISO 45001 that will be inclusive, but not limited to i) an OHS policy; ii) an OHS management plan; iii) permit to work systems; iv) transportation route risk assessments; v) journey management; and vi) procedures for incident management, reporting and investigation. The management system will apply to all direct workers and contractors alike and be aligned to the national requirements, IFC PS’s, WBG EHS Guidelines and GIIP for the sector. The OHS management system will also define the EHS requirements to be included in contractual arrangements with contractors and sub-contractors (ESAP #13).
PS3: Resource Efficiency and Pollution Prevention
The Project is expected to generate 336GWh per year, displacing that amount of grid electricity with an emissions factor of 188 gCO2 / kWh. Therefore, the Project is expected to deliver 63,065 tons CO2e reductions.
The project will generate its own electricity for use during operations and during construction, onsite diesel generators will be used. CEN is exploring the installation of temporary solar panels on the site to generate power during construction. As part of the C-ESMP, CEN will require the BoP and TSA to develop and implement a resource efficiency management plan that will include energy efficiency measures and sustainable energy options to be used during construction.
During the Project’s operation phase, water needs are negligible, while during construction water will be required for construction activities, dust control and sanitation purpose including for worker accommodation if installed on site. CEN will require the contractors to develop a water management plan prior to construction, which will include identification of sources of water supply, confirmation that the water quantities used will not create an impact on existent users, anticipated quantities, procedures for onsite management of water supply and minimization of water consumption. If groundwater will be used as water source, CEN will request contractors to undertake a hydrogeological assessment to ensure the abstraction rates are sustainable prior to any use of groundwater (ESAP #14).
No air emissions are expected from the WEF and the T-Line during operations. During construction, two source of emission will be fugitive dust from site construction and transportation activities and from power generation. Construction activities will result in an increased level of noise from equipment and machinery, which are anticipated to be readily mitigated through the implementation of standard pollution prevention and control measures that will be defined under a C-ESMP.
Impacts related to air and noise emissions, visual intrusion, and to potential shadow flicker will have minor impact, as a buffer of 1km from the nearest household will be maintained (please refer to PS4 for further details).
Volumes of solid, liquid, and hazardous waste generated by the project during the construction and operation phase are expected to be low. Solid wastes for the construction phase are anticipated to comprise inert construction wastes (rock, spoil, etc.), packaging materials (e.g., plastics, wooden pallets), and general municipal waste (food waste, food contaminated waste, etc.). Liquid waste anticipated to be generated during the construction phase is mainly wastewater from toilets and sanitation facilities. Hazardous waste for the construction phase is anticipated to be empty containers of paints/coating material, used oil, etc. Waste generated during the operational phase would be much lower, but similar to those for the construction phase and will mainly be associated with site maintenance activities.
Solid waste (hazardous and non-hazardous) will be securely stored on site and regularly removed by authorized contractors to a licensed treatment, recycling, and/or disposal facilities. Domestic wastewater is anticipated to be managed using sewage treatment plants (if a camp is built) or septic tanks, the contents of which will be emptied regularly and transported to the nearest approved wastewater treatment facility. As informed by the ESDD process, there are no suitable solid waste, wastewater, and hazardous waste treatment and disposal facilities located in Namaacha. The C-ESMP will include a waste management plan identifying adequate waste treatment and disposal facilities for the waste streams generated by the construction and operation phases. As per ESAP #5 CEN will ensure all contractors secure an agreement with authorized waste transportation and disposal facilities after undertaking an EHS due diligence assessment to demonstrate the respective selected facilities are in alignment with PS3, WBG applicable EHS Guidelines, national requirements and implement a chain of custody mechanism, ESAP #4.
Given the topography of the WEF site location and its access, the site will require that management of surface run-off drainage. A detailed drainage design will be undertaken to ensure that any discharge of surface run-off water is undertaken in a way that does not create erosion or silting, particularly onto adjacent land (ESAP #15).
PS4: Community Health, Safety and Security
In the WEF, noise impacts have been assessed in the Environmental Noise Impact Assessment using the WBG EHS Guidelines for Wind Energy. Noise modeling was conducted to determine safe distances for all sensitive receptors. Using this modeling, a buffer zone was defined where noise levels of 35 dB(A) were predicted to be met. Households living in the buffer zone or facing exceedance to the applicable WBG EHS guidelines will be relocated. Based on the receptors modeling of the ESIA, the physical resettlement of the noise receptors within the buffer zone will also mitigate risks linked to shadow flickering and blade throwing. During operations, herding activities will continue between the WTGs. However, appropriate mitigation measures will be included in the Project's operational ESMP and SEP, including installing warning signs and active engagement to inform communities of the risks associated the project poses (ESAP #6).
In the T-Line, a 70m or a 50m safety protection zone (dependent on whether there are two parallel or one high-voltage power line) will be established to prevent any potential health and safety incidents to communities. Encroachment in the Right-of-Way (RoW) can potentially trigger health and safety risks in the event of T-Line or towers being damaged during cyclones; long-term exposure to Electromagnetic Frequency (EMF) and risk of eviction in the portion overcrossing the military base. As the management of the T-Line corridor will be handed over to EDM after construction, CEN together with EDM will ensure that additional measures to monitor encroachment into the buffer zone will be included in relevant RoW Encroachment Procedures (ESAP # 16).
The project area is in a region of international mobility between the Mozambican- Eswatini border, with limited infrastructure and employment opportunities. Risks of unmanaged influx will place additional strain on resources such water, housing, healthcare, and potentially result in an increased communicable diseases and competition for jobs. To mitigate potential impacts of internal and transboundary immigration, CEN will develop an influx management framework for the project (ESAP #17). The Framework will cross reference other relevant plans such as the C-ESMP, SEP, RAP, HR and Labor management plan, grievance management and the GBVH Act and will seek to coordinate the efforts with the Namaacha district authorities.
The EPC contactors will engage unarmed private security personnel during the project's construction and operational phases. The number of security guards required to be engaged is yet to be determined. CEN will ensure that security contractors will be appropriately screened and trained on Voluntary Principles of Security & Human Rights. As part of the C-ESMP, CEN will develop and implement a security management plan aligned with IFC PS4 which will be applicable to the Project and its contractors. The plan will also include provisions for systematic training regarding GBVH and use of force. Security incidents will be recorded and investigated, and corrective actions will be implemented, as per ESAP #5.
The main road traffic risk associated with the project is related to the transport of the turbines, blades, wind tower components (abnormal loads), electrical towers, transport of aggregate, concrete, water, and the daily commute of project personnel. The project will undertake a transportation route risk assessment that will identify aspects requiring immediate improvements such as high-risk road stretches, need for road improvements, signage, etc. This route risk assessment will inform a traffic and transportation management plan in line with GIIPs. The plan will include i) a driver safety procedure, consistent with GIIP; ii) journey management monitoring, supervision, and audits; iii) use of In-Vehicle Monitoring Systems (IVMS); iv) defensive driving; v) incident investigation; and vi) reporting indicators. The plan will require contractors to provide transportation for the workforce on site to reduce risks of accidents with third party vehicles. The plan together with the RAP and stakeholder engagement plan will also define the approach for parking and staging materials along the T-Line corridor (ESAP #18).
As part of the SEP, CEN will inform and disclose information about potential emergency scenarios and impacts on communities and herding activities. EPC contactors will develop site-specific emergency preparedness and response plans that will clearly outline the response procedures for emergency scenarios and resources to execute it.
PS5: Land Acquisition and Involuntary Resettlement
In the WEF, the Project secured a DUAT covering an area of 855.6 ha, this includes the project established buffer zone of at least 1 km around the WEF to mitigate potential noise and H&S impacts to dwellings during operation. Currently, the area of the Project is mainly used for grazing activities of neighbouring communities in the area. For the 33.5km T-Line, the project will acquire a 70 or a 50m wide RoW for resettlement and compensation purposes. The T-Line RoW will run mainly over land used for cultivation of small agricultural plots (machambas), five mining concessions and a military zone.
Access to land for the construction and operation of project facilities will trigger physical and economic displacement. In 2023, the Project prepared two Resettlement Action Plans (RAPs) that identified 164 Project Affected Person(s) (PAPs), 135 for the WEF and 29 for the T-Line to be physically displaced and 640 PAPs (89 for the WEF and 551 in the T-Line, 89 of which are tenants) that will be economically displaced. These numbers also include 13 businesses (1 for the WEF and 12 for the T-Line) that will be displaced.
In the last 300m stretch of the T-Line, before reaching the Boane sub-station, the T-Line will be buried to avoid physical displacement impacts of approximately 20 households located in peri-urban area. For the buried cable section, the Project will require a 2m corridor for construction purposes. In the mining concessions crossed by the line, CEN is negotiating Memorandums of Understanding (MoU) with each of the mining operators.
Measures proposed in the RAPs to manage impacts of the loss of land, assets and livelihoods include i) the relocation of PAPs in a host area located outside the project footprint (for the WEP), within an unimpacted area in the same village (in-fill resettlement) or in another community close to the mining concession (for the T-Line); ii) compensation for the loss of assets, businesses, crops and subsistence trees at replacement value; iii) disturbance and relocation allowances; iv) relocation and other measures for graves and assets of spiritual importance after consultation with the affected households; and, v) registration of the DUATs for the replacement land.
Livelihood activities for affected PAPs included in the RAP comprises of i) agricultural-based activities (cropping); ii) business-based activities, iii) employment and skills development support; and iv) targeted livelihood restoration programs. The RAP includes a timebound plan and resource requirement to implement the resettlement and livelihood programme for affected persons. Before construction, CEN will prepare and roll-out an implementation strategy and detailed schedule based on the approved RAP that will include a robust and resettlement-focused grievance mechanism; (ESAP # 19).
In addition, for the portion of land crossing the military servitude belonging to the Ministry of Defence, the Project was restricted access to assess the numbers of impacted machambas. However, the survey team identified a total of 31 PAPs with machambas outside the military area’s walls but still claimed as part of the military servitude. These PAPs have been included in the list of economically displaced PAPs. The Project will establish a RAP grievance mechanism should some PAPs claim the use of machambas in the military area in the future as per ESAP #19 above.
For the WEF, the RAP identified and selected host areas for the affected communities through a process of engagement with local authorities, traditional leaders and affected households, in line with PS5 requirements. An initial assessment conducted in January 2023 identified i) potential erosion risks, ii) impacts on natural resources (e.g., water) and iii) potential soil fertility concerns. These risks will be evaluated in further detail and addressed. Similarly, CEN will ensure that all regulatory requirements will be obtained before the development of sites and movement of affected persons. (ESAP #20).
To manage resettlement risks, a suitable recognized RAP consultant will be recruited for the implementation of the RAP and the restoration of livelihood for the WEF and the T-Line. In addition, the Lenders E&S Advisor will engage an internationally recognized PS5 specialist based on an agreed ToR to undertake bi-annual Resettlement and Livelihood Restoration monitoring and evaluation visits (during construction) followed by a RAP Completion Audit to all physically and economically displaced PAP’s. This PS5 specialist will also undertake a RAP completion audit to demonstrate compliance with IFC PS5 or, if necessary, identify any remaining gaps and corresponding corrective actions, with and associated budget and timeline for implementation (ESAP #21).
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The project is within Critical Habitat for Martial Eagle (IUCN Red List – Endangered), Bateleur (IUCN Red List – Endangered), White Backed Vulture (IUCN Red List – Critically Endangered), and for two threatened ecosystems (Lebombo Summit Sourveld and the Western Maputaland Clay Bushveld). Baseline bat studies concluded a potentially high risk to bats during spring and summer. For other raptors at highest risk of collisions with turbines or the T-Line and for bats, IFC Natural Habitat requirements will be applied.
The project will implement a comprehensive program to avoid and minimize risks, the project i) selected a transmission line route option considered to have the lowest biodiversity impact; ii) will use a ‘ bird safe’ pylon design for the transmission line, approved by a qualified wind-wildlife expert, to minimize risk of electrocution; iii) is deploying an independently proven and extensively field tested AI based, camera-led automated shutdown on demand system to minimize raptor collision fatalities at all turbines for the life of the project; iv) will implement a raptor food management program to remove livestock carcasses that may attract scavenging raptors close to turbines; and v) will develop and implement turbine curtailment program for bats if project fatality thresholds are exceeded (ESAP #22).
The project will develop and implement a Construction Phase Biodiversity Management Plan (BMP) for the project and the T-Line (ESAP #23). This will include; i) pre-construction surveys to assess construction phase risk to threatened flora, breeding birds and roosting bats at the project site and along the T-Line; ii) breeding raptor surveys within and surrounding the project and along the transmission line; iii) an assessment of the scale of the large Miniopterus bat colony to the south of the project; iv) a plan for managing indigenous vegetation through burning and grazing regimes; v) an invasive species management plan; and vi) an approach for installing appropriate bird flight diverters on high-risk sections of the T-Line and on guyed meteorological masts, based on advice from a qualified wind-wildlife expert.
For the operations phase (ESAP #24). the project will contract an internationally recognized, wind-wildlife consultancy/expert to collaborate with their locally contracted ecological consultancy to design a Post Construction Fatality Monitoring (PCFM) program and develop an Operations Phase BMP. The consultancy will be retained for the first two years to provide ongoing PCFM technical support and the PCFM program will be conducted initially for three years. The operations phase BMP will include i) confirmation of priority biodiversity values; ii) fatality thresholds for priority birds and for bats; iii) an adaptive management plan; iv) protocols for all onsite operational phase monitoring and mitigation activities; and v) a semi-annual reporting template to be used for centralized reporting of all bird and bat monitoring and mitigation. The efficacy of the BMP and associated protocols will be evaluated after 2 and 4 years, respectively.
The project has developed a draft Biodiversity Action Plan (BAP) and associated Biodiversity Monitoring and Evaluation Plan (BMEP). The BAP includes a residual impacts assessment, offset strategy, and offset feasibility study. As per ESAP #25, the project will finalize the BAP and BMEP. The BAP will include viable offsets to achieve net gains for Critical Habitat bird species and threatened ecosystems and additional conservation actions to achieve No-Net-Loss (NNL) for the other priority biodiversity values. The project will contract a qualified expert with international experience on offsets to develop, finalize and assist in managing the offset part of the BAP. The project will select from the list of viable offsets that it agrees to finance, which together will achieve net gain and NNL goals for the operational life of the WEF. IFC will approve the offsets and their associated budgets.
To manage the multiple biodiversity risks and interrelated mitigation measures, the project will contract a dedicated Biodiversity Manager (as per ESAP #7), who will be responsible for the overall management and reporting of all mitigation and monitoring activities relating to the project. (e.g., PCFM, automated shutdown, implementation of the construction and operations phase BMPs, etc.). The manager will be an ecologist with experience managing wind-wildlife programs and reporting results.
PS8: Cultural Heritage
CEN prepared a Cultural Heritage Assessment (CHA) to identify potential impacts on tangible and intangible cultural heritage within the WEF footprint. The assessment identified 2 religious buildings, one monument, a natural landscape feature within the region and ten graves in the project site. To avoid displacement of the graves in the WEF, the Project will establish a fenced 20m buffer zone, which was indicated as the preferred option of the affected households. Should a household prefer to relocate a grave in the future, CEN will use professional services and the relocation will be undertaken in accordance with local customs. One of the affected churches is no longer in use by the community but it will be re-built in the new host village. The monument and the natural features are not directly impacted by the project.
The T-Line will impact one sacred site (a house of worship) and nine graves. It is understood that the Project will take all reasonable efforts to ensure that graves are not relocated, but if the contractor or PAPs requires these to be relocated, this will be undertaken in accordance with local legislation and traditional practices. The T-Line RAP includes these commitments to ensure the exhumation and translocation of the graves are undertaken with the necessary care, ceremonies and local customs.
Given the risk of uncovering additional unknown cultural heritage finds, CEN will include a chance finds procedures as part of their C-ESMP (ESAP #5).
