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
Identification of E&S Risks and Impacts
The Project was subject to local regulatory approval and applies Thai laws to its operations. An Initial Environmental Examination (IEE) was completed in 2018 that considered E&S impacts consistent with wind and transmission line facilities, including noise, set back distances, construction impacts and shadow flicker. Permits have also been issued by the Thai and Provincial governments related to construction, land use, waste management, water use, aviation risks and power generation.
The Project was exempted from compliance with safety set-back distances by the Thai Energy Regulatory Commission for structures within the vicinity of three turbines. Based on an initial review of the exempted wind turbines’ safety buffer area, a small number of structures within the relevant buffer distance (342m recommended by the WBG EHS Guidelines for Wind Energy) were identified. The Company will undertake an assessment of the risks (shadow flicker, noise and blade throw) for the users of the structures within the safety buffer zone (ESAP #1). The results of this assessment will be used for informed consultations with the affected stakeholders regarding managing any identified risks and impacts. Separately and as part of the ongoing stakeholder engagement, the Company will sensitize the community and relevant stakeholders about the need to maintain the safety buffer around the turbines and prevent any future encroachment.
The E&S assessments completed are generally consistent with the requirements of IFC PS1 to PS6 in relation to construction and operational impacts. As outlined below, there are gaps that require rectification to fully comply with IFC PS, mainly related to PS2 and PS6.
Environmental and Social Policies and Management Systems:
As a corporate level, SSP has several policies that are consistent with the requirements of IFC PS, including a Corporate Governance Policy, Human Rights Policy, Corporate Sustainability Development Policy and an Environmental Management and Biodiversity Management Policy. SSP also has prepared and certified ISO 9001:2015 (Quality Management System) for three solar plants, ISO 14001:2015 (Environmental Management System) and ISO 45001:2018 (Occupational Health and Safety (OHS) Management System) for one of their biomass assets. SSP has in place an Environmental and Social Management System (ESMS) that applies to a solar project in their portfolio that is subject to IFC investment, however this does not currently apply to the Winchai project. Currently Winchai operates under the previous owner’s E&S systems and processes with some transition to SSP’s approach. Winchai also employs a contractor to maintain and operate the turbines who is an internationally recognised supplier of wind farm equipment and has E&S policies and procedures equivalent to IFC PS. To comply with IFC PS, the Project will be required to apply corporate level policies and procedures as well as develop and implement a site-specific ESMS consistent with IFC PS and the World Bank Group Environmental, Health, and Safety Guidelines Wind Energy (WB EHS Guidelines). (ESAP #2).
E&S Organization Capacity:
SSP maintains E&S staff at a corporate level to integrate policies, processes and systems across their portfolio, including the Winchai project. A Corporate Governance and Sustainability Committee has also been established at SSP to oversee implementation of the policies and procedures. At the Project level, there are three (3) staff responsible for E&S implementation as part of their broader roles as well as three (3) staff employed by the contractor responsible for turbine supply and maintenance, who are permanently located on site and are also responsible for E&S implementation. Winchai staff undertake E&S functions including community liaison, Occupational Health and Safety (OHS) implementation, waste management, environmental compliance and data collection and reporting. SSP’s Human Resources Department and local staff provide training on E&S and OHS risks and mitigations at induction and regularly to ensure consistent application. The contractor has their own E&S policies and procedures and training schedule and has sufficient capacity at a corporate and local level to manage E&S risks. To ensure consistent roll out of the ESMS to be developed for the Project, Winchai is to assess the capacity of local staff to implement the ESMS and employ additional resources if required (ESAP #3). Training on the implementation of the ESMS is to be conducted with local and contractor staff (ESAP #4).
Emergency Preparedness and Response:
Winchai currently implements an Emergency Response Plan according to the previous owner’s policy. This policy includes evacuation requirements in response to emergency situations from natural disasters (including forest fires, earthquakes and floods), OHS risks (electrocution and fall from height) and equipment malfunction. The community are also aware of these requirements, however there is no systematic training of community members in relation to emergency response procedures. Winchai undertakes regular emergency response drills with personnel and contractors. To ensure that the companies emergency response procedures are compliant with PS1 and 4, the Emergency Response Plan is to be updated, discussed with the local community and incorporated into the ESMS (ESAP #5).
Monitoring and Review:
Data is currently collected by Winchai and their contractor on Project performance, waste management, water consumption and community programs. This data is collated and will be provided to SSP for reporting in the companies Sustainability Report. Regular inspections are undertaken of the engineering aspects of the Project by the contractor related to OHS and environmental risks. There currently is no third party or corporate monitoring and review of the Project’s operations, however this is planned to commence in 2025. To comply with IFC PS, the Company will implement a regular audit program of the Winchai project as part of the ESMS to obtain assurance on compliance with IFC PS (ESAP #6) by SSP.
PS2: Labor and Working Conditions
Human Resource Policies & Procedures:
SSP at a corporate level has a Human Resource Management Policy (HRMP). This policy applies to all affiliates, including the Winchai project. The HRMP includes measures to manage risks associated with labor and human rights practices, non-discrimination and harassment, recruitment, OHS, compensation and benefits as well as employee training and development. The Winchai project currently operates according to SSP’s HR policies and training of staff has occurred to socialise the approach with local staff and contractors. There was no retrenchment of existing employees during the project procurement by SSP. All staff reported that their wages and conditions were improved following the acquisition and are compliant with Thai labor laws. There has been no lost time nor incidents at the Project as recorded in the Projects safety performance data. Winchai currently employs 14 full time staff, and the contractor employs six (6) staff, one of which is an international employee with a valid work permit. The current gender balance of the employees is skewed towards male representation with only one (1) current female employee. The main contractor operates under their own policies and procedures that are compliant with IFC PS. A review of the SSP HRMP found that there is no reference to management of Gender Based Violence and Harassment (GBVH), nor a corporate level approach for retrenchment. To comply with IFC PS, the HRMP is to be updated to include measures to manage risk of GBVH and provisions to guide any retrenchment (ESAP #7).
SSP’s HRMP includes measures to reduce risks of child and forced labor both within the company and with contractors. SSP also has a Human Rights Policy (HRP) that includes measures to respect diversity and reduce risks of discrimination. The HRP also refers to the company’s grievance mechanism to record and respond to any allegations related to non-compliance with the policy. The HRP applies to all SSP’s operations, including the Winchai Project. The Project’s main contractor also has PS2 compliant commitments and conducts regular training. Whilst there is not a unionised workforce, SSP will be required to include a statement in the HRMP enabling staff to form and join unions (ESAP #8).
Grievance Mechanism:
Winchai’s HRMP also includes a grievance and whistleblowing mechanism that is available for all staff and can be anonymously applied with no grievances identified. In order comply with IFC PS2, the whistle blower mechanism is to specifically refer to and include mechanisms related to GBVH (see ESAP #7). The HRMP mechanism is also available for all contractors; however, the main contractor operates its own corporate level grievance mechanism which is consistent with IFC PS.
Occupational Health and Safety and Third-Party Employees:
Both Winchai and its main contractor implement OHS policies and procedures. Both entities have specific requirements related to working at heights, electrical risks, confined spaces, driving, and emergency situations. These requirements are audited, and training applied to all personnel. There is an investigation procedure in place related to incidents. Personal protective equipment applicable to the wind sector is used and applied by the contractor personnel. Other minor contractors employed (such as for grass cutting) comply with SSP’s OHS systems.
Supply Chain:
SSP has in place a Supplier Code of Conduct for Sustainable Business Development (SCoC). The SCoC includes reference to business and E&S risks, including workers treatment and human rights, OHS, emergency preparedness and the environment. The SCoC is provided to suppliers, and relevant measures are included in contractual arrangements. No formal assurance program is undertaken however to determine if suppliers meet SSP’s commitments. To proactively manage supply chain risks, Winchai is to review and update the SCoC as part of the ESMS including an assurance program as part of its procurement process (ESAP #9).
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency:
The Winchai project uses minimal amounts of water (estimated at 7cubic metres per day) for domestic uses and for cleaning. Septic tanks are used at the office facilities of the wind farm. No other resources are used nor are there any emissions or discharges associated with the Project.
Solid waste and hazardous material management:
The Project does generate waste oils and grease, batteries and used hardware from the turbines and transformers. These materials are separated and managed through local waste and hazardous waste companies who transport the materials for disposal, including tracking the disposal of waste.
GHG Emissions:
The Project will lead to a GHG emissions reduction of 195,859 tCO2e/yr by displacing grid generation with renewable energy generation. The Project has several identified climate risks, including increased temperatures affecting outside workers; increases in precipitation and the project site; and an increase in wildfires. In response to these risks, the ESMS is to include specific mitigations related OHS, water management and wildfire management (see ESAP #2).
Noise and Shadow Flicker
Operational noise from turbines and shadow flicker were considered during the Projects IEE. The Project did not identify any exceedances for noise and shadow flicker during survey according to WBG EHS Guidelines. There is no monitoring of noise and shadow flicker during operation. As part of the development and implementation of the ESMS for the Project, Winchai are to monitor for noise and shadow flicker for the wind farm (ESAP #2)
PS4: Community Health, Safety and Security
Infrastructure and Equipment Design, Life and Fire Safety:
The Winchai project finished construction in 2018 and incorporates high quality equipment. Turbines, transformers, interconnecting lines are all procured and managed by an internationally reputable firm.
There is a risk of fire at the Project location due to wildfires due to climate related risks and the surrounding forested environment. Winchai does have an Emergency Response Plan that has measures to manage risks of wildfires. As part of the review of the ESMS, these measures are to be updated considering the WB EHS Guidelines when the ESMS is prepared (See ESAP#2).
Traffic Impacts and Transportation Safety:
Traffic risks during the operation of the Project are low. There are less than 5 vehicles operated by the Project and contractors to inspect the operation of the windfarm.
Community Health and Safety:
There are risks associated with noise from turbines, shadow flicker and potentially blade throw given community access to the wind farm area. To determine if there are any ongoing impacts, monitoring of noise and shadow flicker has been required by ESAP #2. Further analysis of these risks is discussed under PS1.
Security Personnel:
Security personnel are utilised at the Project and are employed as a contractor. To ensure that security personnel comply with relevant IFC PS4 provisions, the HRMP is to be updated to include relevant procedures for the selection, training and conduct of security personnel (ESAP #11) and grievance mechanism to address complaints against security personnel.
PS5: Land Acquisition and Involuntary Resettlement
The Project’s six (6) turbines are located within the land leased from the Department of Social Development and Welfare (“DSDW”) and seven (7) turbines are located within the land leased from the local community. The land is currently used as mixed agriculture, rubber plantations and natural forests. Land was leased in 2017 for the Project by the previous owner of the windfarm who negotiated utilization and lease agreements for the use of land for turbine pads and access roads from the 63 legal owners on a voluntary basis. No resettlement was undertaken at the time of acquisition of the land. The lease agreements covering 248 ha of land were set for 30 years with possible extension with the legal owners of the land, with the owners maintaining ownership and access to the remainder of the land for agricultural purposes. The lease agreements allow for the return the land back to its original condition at the expiry or termination of the lease. Based on interviews, the landowners are satisfied with the level of compensation they receive for the lease of their land and the loss access and economic benefits.
The landowners and community are regularly engaged by the Company. An informal grievance mechanism is in place whereby the landholders and the community can contact the Company through a nominated representative. There have been no grievances recorded by the Company since the commencement of operations. This was confirmed during meetings with landholders and the community during appraisal. To comply with the PS, a formal grievance mechanism is to be established with the community (ESAP #11)
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The Project is in the Central Indochina dry forests Ecoregion which consist of a predominantly cleared landscape with remnant patches of wet and dry deciduous forests. A review of the project’s IEE and other relevant online data did not identify any likely critical habitat values associated with the Project. The habitat types on site are common throughout northern Thailand and no other priority biodiversity values were identified or predicted to occur, however avifauna (birds and bats) are likely present within the airspace. Given the project is located along a ridge, soaring raptors and bats may transit the area. Based on satellite imagery, there has been some clearance of remnant native trees prior to construction for three turbines in the northwest of the Project area in 2017, however this area is estimated to be less than one (1) hectare.
Ongoing risks to birds and bats may exist due to the operation of the turbines and transmission line. All connector lines between turbines are buried. There is currently no Post Construction Fatality Monitoring (PCFM) being conducted for the Project. To determine if there are any ongoing risks to birds and bats from the operation of the windfarm, the Company is to undertake PCFM in accordance with the IFC Toolkit: Post-construction Bird and Bat Fatality Monitoring for Onshore Wind Energy Facilities in Emerging Market Countries. If PCFM identifies significant risks to birds and bats, relevant adaptive management measures are to be used to manage these risks (ESAP #12), including turbine management and deterrents such as blade painting and lights.
Based on IFC’s review and the IEE, no risks and adverse impacts of the project that need to be managed consistent with PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) were identified.
