IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements.
Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an
agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance
Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
The Project received its original Environmental
Impact Assessment (EIA) approval from the Ministry of Environment and Physical Planning (MoEPP) in 2009 for all phases of the Project, and this is valid until February 2028.
A national EIA (Environmental Protection Elaborate report) was completed in November 2024 which covered the full windfarm (Phases 1, 2 and 3) and was approved in December 2024.
An Environmental Protection Elaborate for both the OHL and the substation was submitted to the Ministry in November 2025 and approved in January 2026.
A full ESIA was completed in February 2026, the ESIA will be revised to address gaps identified by the lenders Independent E&S consultant (IESC), related to biodiversity and
social impacts as further described in the respective paragraphs below (as per ESAP NR1)
The disclosures shared with this E&S review summary comprises a
project-focused ESIA and Non-Technical Summary, Stakeholder Engagement Plan, and Biodiversity and Critical Habitat Assessment. The E&S disclosure documents have been conducted
in accordance with IFC PS. Following multiple exchanges and updates during the due diligence phase, IFC considers the E&S disclosure package fit-for-purpose for a project of this
scale and character, i.e., covering all relevant E&S risks and impacts at an appropriate level of detail. 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 Project will be delivered by the Sponsor’s in
country HSSE’s team (E&S, H&S, and Community Liaison), under the regular oversight of the corporate ESG/E&S team. The corporate team are experienced in delivering projects in
compliance with IFC PSs and have appointed a strong local team, which is being supplemented with the recruitment of an HSE Engineer. Sponsor has a corporate ESMS which is
aligned with IFC PSs. The Sponsor’s E&S Management and Monitoring Plan (ESMMP) framework outlines general requirements for E&S performance and assigns roles to the Sponsor
and to the Turbine Supply (TS), Balance of Project (BOP), and Operations and maintenance (O&M) contractors. The BOP contractor will be responsible for delivering all supporting
infrastructure and systems (civil works, electrical works, mechanical works, grid connection, etc.) required for the construction of the wind farm project. The TS will be
responsible for the manufacturing, procuring, transporting, installing and commissioning of the wind turbine generators. The ESMMP details the project’s ESMP framework which
includes required plans for construction and operations (e.g. Biodiversity Management and Action Plan, Emergency Preparedness and Response Plan, and Traffic Management Plan,
Waste and Wastewater Management Plan, Labor and Working Conditions Management Plan, Recruitment Plan, Labor Accommodation Strategy Plan and Grievance Mechanism, etc.).
The ESMMP requires that the contractors prepare the Project/specific respective plans, policies and procedures in line with the Sponsors’ ESMMP framework and national requirements,
IFC PSs, World Bank General Environmental, Health, and Safety (EHS) Guidelines, and other specified Sponsor requirements (the reference framework’).
The Sponsor includes legally binding obligations in its TS, BOP and O&M contracts (and for them to cascade to their subcontractor contracts) for
compliance with project standards including IFC PSs and national legislation, and these requirements are set out in the Sponsor’s Employer QHSSSE Requirements.
This includes the requirement for the contractors to have the adequate resources for managing the associated QHSSSE risks and impacts including but not limited of QHSE manager,
labour and HR manager, security manager and ESHS officers. The sponsor will review the team and may identify and specify additional key roles to be appointed by the contractors,
based on its understanding of the Project’s scope, risks, and needs. The TS/BOP contractors, once appointed, will be required to develop a construction-phase ESMMP (CESMMP) in
alignment with the requirements of the Sponsor’s ESMMP. The Sponsor will review and approve the CESMMP, and then monitor and assess the contractor’s implementation of relevant ESMMP
elements, confirming that corrective actions are being taken when necessary to maintain environmental, social, health and safety (ESHS) performance in line with the PSs and the
Project’s reference framework.
The development of the CESMMP, reviewed and approved by the Sponsor, is a requirement before construction (ESAP #2)
including a specification of which entity (sponsor, specific contractor, or multiple contractors) is responsible for implementing each mitigation measure or other action.
The Sponsor’s project-based E&S officers will be part of the Sponsor’s construction team, with the Sponsor’s construction manager having overall
responsibility for the execution of the Project. The Sponsor’s team includes the Head of Environmental, Social and Governance (ESG), based in the UAE, a Senior E&S specialist,
based in the UAE, and within North Macedonia an E&S specialist, a community liaison officer (CLO), and an HSE Engineer who is in the process of being recruited. Appointment of
the Sponsor’s project specific E&S team will be completed before the start of construction, and will be required to be present on site throughout the construction phase (ESAP #3).
Additionally, an independent E&S monitoring consultant will be engaged during the construction and early operations phases to monitor the implementation of the ESMS and E&S Action
Plans and make recommendations to the IFC on any corrective measures needed.
In preparation for operational activities, the Sponsor will review and approve the
O&M contractor’s Operations Environment and Social Management and Monitoring Plan (OESMMP) verifying that it is consistent with IFC PSs, relevant WBG EHS Guidelines, national requirements, and ESIA commitments (ESAP #4). The Sponsor will oversee and monitor the implementation of the OESMMP.
PS2: Labor and Working Conditions
During construction the number of workers will fluctuate and is estimated at this stage to peak at approximately 300 workers. The construction workforce is expected to consist of approximately 20% international (critical expertise) and 80% national workers from within North Macedonia.
The project's accommodation strategy for non-local workers is still being finalized. As most project workers are anticipated to reside locally,
and the Project is situated in relative proximity to the city of Stip, a worker's camp is not anticipated to be required to be established. Non-local workers are expected to be
accommodated in hotel/apartment accommodation in Stip.
The Sponsor’s ESMMP sets its commitment to comply with North Macedonian law and ILO conventions and covers
key topics including terms of employment and recruitment practices, working hours, non-discrimination, and benefits. Further, the ESMMP defines contractor requirements,
relevant KPIs and monitoring measures and commits contractors to developing project-level HR policy and Labor and Working Conditions Management Plans prior to construction.
These define detailed labor management and monitoring requirements, including a worker grievance mechanism, worker code of conduct (CoC), and accommodation standards. The Sponsor’s ESMMP commits all contractors and subcontractors to apply equivalent standards within the labor contracts in line with sponsor’s requirements.
The ESMMP details the requirement for the development of a worker grievance mechanism (including requirement for training for staff administering grievance mechanisms on how to handle grievances relating to GBVH) which is available to contractors and subcontracted workers. The grievance mechanism will be enhanced to make available an accelerated route to report and handle sensitive cases, such as discrimination, bullying, harassment, and sexual harassment, as well as accessible referral pathways to support services for workers who report experiencing sexual harassment. The Sponsor will also provide training for all workers on HR policies, CoC and the grievance mechanism. (ESAP #6).
The Sponsor has a Responsible Investment Policy, Procurement Procedure, and a Management of Procurement Process which defines commitments, standards, risk assessment approach, processes at different stages of the development of renewable energy projects. The Sponsor ensures that suppliers of main equipment are assessed before entering a commercial relationship and that their practices are aligned with PS2 requirements. These procedures include a due diligence procedure including mapping and risk assessment of suppliers, a supplier code of conduct aligned with PS2 requirements, contractual clauses requiring compliance with the code of conduct, an engagement and disengagement procedure when contractual obligations are breached and a monitoring procedure to assess suppliers’ compliance over the life of the project. The Sponsor retains records of the supplier screening process and ongoing monitoring results.
The ESMMP includes key performance indicators (KPIs) that all employees will have a signed contract and code of conduct, and that all workers are trained in the project’s labor commitment and the worker code of conduct. Compliance with Sponsor’s requirement will be verified with regular audits and inspections by the Sponsor’s corporate team. The TS, BOP and O&M contractors will provide Induction and Regular Training to all workers (including subcontracted workers), supervisors, and managers on the Worker Code of Conduct, occupational health and safety (OHS), human rights, and anti-harassment policies. Tracking OHS performance will be carried out through incident reporting and monitoring of training records. The OHS requirements cover all workers on the project, including subcontractors, and to also conduct labor monitoring (including child or forced labour, discrimination, and unionisation rights).
PS3: Resource Efficiency and Pollution Prevention
The project is estimated to generate about 321 GWh per year net energy output, with greenhouse gas emission reductions of 233,835tCO2 equivalent per year. Once in operation the project’s GHGs will be minimal. The development of a resource efficiency management plan for all phases of the project, which sets specific targets, metrics, and monitoring requirements, will be developed as part of the CESMMP.
The water supply to the project in construction and operations will be from offsite licensed sources and managed through a Water and Wastewater Plan which the TS and BOP will develop in their CESMMP. During construction and operations there is not anticipated to be any industrial or process wastewater generation. Wastewater generated by the project will be predominantly sanitary and collected by licensed companies. Water use during operations will be negligible and associated with sanitary usage and turbine blades cleaning primarily. Irregular watering of unsealed roads is expected to be undertaken to minimize dust emissions. The project is not expected to generate pollution to air, water, and soil, and volumes of waste impacts, which are expected to be readily mitigated through the implementation of standard pollution
prevention and control measures defined within the TS and BOP contractors’ CESMMP.
Noise, vibration, and shadow flicker impact assessments were
conducted as part of the project’s ESIA. Shadow flicker modelling for the operational phase indicated that for Stip 1 three residential receptors could be potentially affected with either flicker impacts of over 30 hours per year or 30 minutes per day. The maximum effect on a property was calculated as 113.5 hours per year. The project plans to implement a tailored protocol for shadow flicker curtailment or a shadow flicker module that will mitigate the impacts on sensitive receptors. The requirement for this Shadow Flicker Management Plan to be developed as part of the OESMMP is included in ESAP #4.
Noise from construction activities is not expected to be a significant issue for this project, with no residential receptors close to the turbine location, and construction activities will be limited to daylight hours. There is no piling or blasting anticipated to be required. Noise modelling shows that two residential receptors in the Stip 1 area closer to the WTGs could have operational night-time noise levels above national and WBG noise thresholds of 45 dBA (+3.7 and +0.6 dBA). Through proposed mitigation measures comprising replacing the standard blade configuration of the WTG with serrated blades, and operating at the standard rated power or where needed curtailed to operate at a lower rated power, impacts can be reduced to minor and negligible. A noise management plan will be developed detailing the monitoring to be undertaken during project construction and operations as part of the CESMMP and OESMMP (ESAP #2 and #4) and the community grievance mechanism can be used by stakeholders to report on noise impacts.
Limited volumes of hazardous materials will be used during the project’s construction (e.g., fuels, lubricants, transformer oils, paints) and less will be required for operations. Detailed waste and materials management and handling plans (WMMHP) are required to be developed by the TS and BOP contactor as part of the CESMMP, and a spill prevention and response plan is also required to be developed for the project. Construction and operational waste are expected to be segregated on site, stored in secure containers, and removed by licensed contractors in line with national legislation, IFC PS3, and WBG EHS general guidelines as laid out in the WMMHP. The WMMHP should assess potential waste disposal and treatment facilities. The assessment will determine whether the facilities are adequate and legitimate enterprises licensed by the relevant government regulatory agencies and whether they are operated to acceptable standards. The Sponsor 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 (ESAP #7).
Landscape and visual effects were assessed within the ESIA this concluded that landscape effects are driven primarily by turbine prominence on ridgelines, while visual effects vary according to settlement proximity, screening, and orientation. The Stip Uplands experience moderate adverse effects due to openness and intervisibility, whereas the valleys experience minor adverse effects because of strong valley enclosure and vegetation screening. No sensitive or designated viewpoints experience high significance effects, and no cumulative visual effects are anticipated given the distance to other wind farms.
The ESIA considers climate variability, including wind strength, temperature, and extreme weather events, climate related risks identified included changes to increases in wind speeds, increases in mean and extreme temperatures, intense rainfall events, and wildfires. Adaptation measures are practical and include actions such as use of heat-resistant materials and SCADA systems integration, improved drainage and soil retention, vegetation management for wildfire defence, and flexible and adapted infrastructure design.
PS4: Community Health, Safety and Security
Community health, safety and security risks associated with the Stip Wind Farm arise primarily from increased construction traffic, heavy machinery movements, and the proximity of works to settlements. The project will involve the upgrade of existing access roads where necessary and use of public roads to transport materials and workers to the site.
The Sponsor’s ESMMP includes a framework Traffic Management Plan (TMP), and the Project will develop and implement a TMP that governs the movement of construction vehicles and machinery (ESAP #8). The TMP will include designated haul routes to avoid sensitive community areas such as schools, or narrow residential streets. It will also introduce speed limits, enforce safe-driving protocols, and require the installation of clear signage and warnings at high-risk sections of the road network. The project will also conduct a road conditions survey to establish the existing state of any public roads as part of the TMP, before the start of construction. The OESMMP will also include a Traffic Management Plan for operations phase.
The ESMMP includes a Code of Conduct, and a project-specific worker's code of conduct (including worker conduct within project worker accommodation facilities) will be established by the TS and BOP contractors (ESAP #2), clearly defining project commitments and individual work responsibilities, including specific measures to address GBVH risks. Additionally, Emergency Preparedness and Response Plans (EPRP) will be developed as part of the CESMMP and OESMMP, 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 where applicable.
Workers are expected to be housed in Stip, and there is not expected to be any influx into local villages. The potential for negative impacts arising from the presence of the workforce on the local communities is limited and will be managed through the worker code of conduct and measured under the ESMP through the community grievance mechanism. Risks for community exposure to hazardous materials during the construction phase are considered negligible due to limited community interaction with the construction sites and project’s commitment to safety measures such as fencing, and warning signs will safeguard the community.
No residential households are within the safety buffer zone for blade throw risk around each turbine (defined as 1.5 times the length of the WTG blade (approximately 300 m) or the overhead line. Appropriate mitigation measures will be defined within the OESMMP (ESAP #6), in line with the relevant EHS Guidelines, including installing warning signs and active engagement to inform local people of the risks posed by the project.
Security Management Plans (SMPs) (for construction and operations phases) will be developed by the TS and BOP, and O&M contractors as part of the CESMMP and OESMMP in accordance with IFC good practice handbook. The SMPs will include measures to address GBVH risks, ensuring that all security personnel receive appropriate training and adhere to a Code of Conduct that prohibits any form of GBVH.
PS5: Land Acquisition and Involuntary Resettlement
The project area expands across approximately 335 ha of land necessary for wind turbines, internal roads, underground cables, the substation, and 7 km overhead transmission line, affecting a total of 1,232 land plots and associated buffers considering the urban plan for the Project. Most land (about 90%) is government owned, with the remaining privately held. Government-held plots are a mix of forested areas and fields used to some extent for grazing, and informal agricultural use. Private plots consist of either abandoned agricultural land or land used for agricultural cultivation. No impacts of physical displacement have been identified, impacts related to economic displacement include permanent loss of land where project infrastructure is located, temporary loss of access during construction, and restrictions under easements for buried cables and overhead lines. Government-held plots are being secured through lease agreements, and securing of the private plots is ongoing with around 70% completed for Phase 1.
The project prioritized avoidance and minimization of land impacts during design. Wind turbine locations, internal roads, and cable routes were modified to reduce disturbance to agricultural plots, avoid structures, and align with existing access routes. For example, several wind turbine locations and road alignments were shifted to reduce land take and avoid impacts on privately owned cultivated parcels and community assets.
Census and socio-economic baseline studies were conducted in 2024-2025 with private landowners and additional land users. 182 affected households were identified on privately owned land, comprising 139 formal landowners, 17 tenants with recognized rights, and 26 informal land users. For government-owned land, PAPs include concession holders and informal land users. Out of these, 98 households will be affected by permanent land loss.
The Project’s Livelihood Restoration Plan (LRP) includes cash compensation for land, crops, and trees at replacement cost, transitional support for PAPs experiencing income loss, continued access to land where surface activities can resume after construction, and targeted livelihood programs (agriculture, livestock, beekeeping, small business development, skills training). Severity of impacts is assessed in the LRP based on the proportion of land lost and whether agricultural livelihoods are fully or partially dependent on affected land. High-severity impact is defined as loss of more than 50% of a PAP’s productive land, or if the remaining land is too small, fragmented or constrained to continue being economically viable for agricultural use. Most PAPs (70%) lose less than 25% of their total handholding. 22 PAPs experience high-severity impacts, including 14 formal landowners, 4 tenants with recognized rights, and 4 informal land users. Households with significant permanent losses receive tailored support to re-establish agricultural production or diversify income, for example provision of agricultural inputs (such as seeds, tools, and soil-improvement materials), technical training on improved farming practices, and assistance for crop diversification or livestock-related activities. Transitional livelihood support will be provided where land access is temporarily restricted during construction.
Vulnerable households were identified and assessed through a multi-criteria method (income, gender, age, disability, ethnicity, health, dependence on natural resources, ability to meet basic needs, etc.). 20 households were identified as vulnerable, including households with elderly heads, serious health conditions or disabilities, and ethnic minority households (Roma or Turkish). Vulnerable households receive additional assistance, including priority enrolment in livelihood restoration programs, enhanced allowances, and counselling. Informal users cultivate or graze livestock on government land. Although they have no legal lease, the Project recognises their use and compensates/assists them through the LRP and aligned with PS5.
The LRP will be updated to address recommendations identified by the IESC (ESAP #9). For Phases 2 and 3, the LRP will be updated to include quantification of permanent and temporary land take for the respective phases, complete identification and baseline data for informal land users, and revised impact severity and entitlements in line with IFC PS5 (ESAP #10).
A Project and LRP grievance mechanism has been promoted during stakeholder meetings undertaken by the Sponsor’s land agents and during LRP census survey, using leaflets available in three languages: Macedonian, Turkish, and English. Grievances can be submitted through phone, email, suggestion boxes, in-person, or through the Sponsor’s multilingual third-party Complaint Management Platform. Anonymous submissions are possible. The Sponsor will commission an LRP close-out audit to confirm implementation and outcomes consistent with PS5 requirements (ESAP #11).
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The Project is located within the Balkan mixed forests ecoregion of the temperate broadleaf and mixed forests biome. The turbines and OHL are situated in a combination of Natural and Modified Habitat, overlapping with three habitats types listed under Annex I of the EU Habitats Directive: Helleno-Balkanic steppes (IUCN Red List - Vulnerable); Eastern Quercus pubescens woods (IUCN Red List - Least Concern); and intermittently flowing Mediterranean rivers of the Paspalo-Agrostidion (IUCN Red List - Data Deficient). The project does not overlap with any Legally Protected or Internationally Recognized Areas. One Key Biodiversity Area/Important Bird and Biodiversity Area (KBA/IBA) is located immediately adjacent to the project, the “Lake Mantovo & River Lakavica KBA”, with no infrastructure proposed within its boundaries. The KBA is designated for the European Red Roller and Masked Shrike (both IUCN Red List – Least Concern). The National Ecological Network of North Macedonia (MAK-NEN) is located to the southeast of the Project area. Developed between 2008-2011, MAK-NEN aims to maintain ecological connectivity and support biodiversity conservation and sustainable land use.
Bird and bat baseline data, including flight activity surveys and both manual and passive acoustic monitoring, were collected over 12 months (2024/25) using GIIP methods. One hundred and fifty-seven (157) bird species were identified. Priority biodiversity values include the Eastern Imperial Eagle, European Turtle Dove (both IUCN RED List – Vulnerable), Redwing, Rock Partridge, Grey Partridge and Woodchat Shrike (all IUCN Red List – Near Threatened). A Collision Risk Model (in line with GIIP methods) estimated the number of priority bird species’ fatalities expected during the operational phase. The predicted fatality rates are not high enough to cause a significant population level impact on any of the priority species. Priority biodiversity values also include the Long-fingered bat, Western Barbastelle and Common bent-wing bat (IUCN Red List – Vulnerable), as well as other bat species, all of which are protected under the EU Habitats Directive. The IFC Natural Habitat No Net Loss requirement will apply to all these priority biodiversity values.
To confirm the habitat determination for any of the identified priority biodiversity values, the Critical Habitat Assessment (CHA) will be revised to (i) refine the Ecologically Appropriate Area of Analysis (EAAA) for priority biodiversity values, (ii) reassess and map Critical Habitat and Natural Habitat values, and (iii) update the residual impact assessment to quantify residual impacts. A Biodiversity Action Plan (BAP) will be developed based on the CHA and will be commensurate with the residual impacts resulting from the project. The BAP will include a loss/gain assessment and define habitat and species-specific actions to address residual impacts on Critical and Natural Habitat, and associated priority biodiversity values to reach No Net Loss and Net Gain objectives. For the priority habitat types, this will include (i) detailed habitat mapping, (ii) identification of impacts (iii) any recommendations on avoidance, minimization and restoration measures (iv) quantification of residual impacts and (v) a clear demonstration of how NNL/NG will be achieved. The BAP will also make provisions for engagement with relevant stakeholders, including local and regional conservation organizations (i.e. Macedonian Ecological Society and European Centre for Nature Conservation) considering potential impacts on the KBA and qualifying bird species. (ESAP#12).
The Sponsor has developed a construction-phase Biodiversity Management Plan (BMP), which will include pre-construction check-ins/walkover surveys, specifically for areas of Natural Habitat and associated priority biodiversity values. The BMP describes avoidance and minimization measures relevant to these values during the construction phase. This will include the installation of bird flight diverters (BFDs) along the entire OHL following good international industry practice (GIIP) in terms of appropriate BFD model and spacing interval. The Sponsor will appoint a Biodiversity Specialist, with suitable experience and expertise, who will be responsible for the overall management and reporting of all Biodiversity activities relating to the project.
In the operations-phase of the Project, per ESAP#13 the Sponsor will implement a Post-Construction Fatality Monitoring (PCFM) program for both the turbines and OHL, based on 2023 IFC-EBRD-KFW Good Practice Handbook and Decision support Tool for Post Construction Bird and Bat Fatality Monitoring for Onshore Wind Energy Facilities in Emerging Market Countries and GIIP to monitor bird and bat activity, which at the minimum, will include (i) systematic carcass searches conducted at weekly intervals year-round under all turbines with transects 6-m in width, (ii) implementation of an adequate number of industry-standard bias correction measures for searcher efficiency (detectability), carcass removal (scavenging), and unsearched and unsearchable areas, (iii) industry standard statistical calculation of total, bias-corrected bird and bat fatality using GenEst software on a semi-annual (2x/year) basis. For bats, in addition to carcass searches, bat monitoring will also include acoustic bat detectors installed at the nacelle to determine bat activity and inform smart curtailment, if needed. The PFCM program will take place for at least a three-year period with semi-annual reporting following a standardized template, but the actual timeframe of the PCFM program will depend on fatality results. The first strategic review of the PCFM program will take place 6 months after the start of the operations phase and then continue on a semi-annual (2x/year) basis. The company will contract an internationally recognized and specialized consultancy to design and develop PCFM, collaborating with a local consultancy for its implementation.
In addition to the PCFM program, the Sponsor will develop an operations-phase BMP (ESAP#14) with an Active Turbine Management Program (ATMP), which will include: (i) blade feathering up to the turbine cut-in speed for all turbines from 1 July to 20 September to minimize collision impacts to bats; (ii) measures for dimming, avoiding light trespass and adapting lamp spectra for all lighting to minimize impacts of light pollution specifically on bat species; (iii) confirmation of priority biodiversity values based on the PCFM results; (iv) threshold setting for priority biodiversity values following the potential biological removal method; and (v) an adaptive management strategy including observer or technology-led shut-down on demand for birds, and smart curtailment for bats, as needed. All technical and financial preparation for the implementation of the operations-phase BMP and ATMP will be finalized prior to the onset of operations phase of the project.
PS8 – Cultural Heritage
Risks and impacts related to cultural heritage were reviewed as part of the ESIA. Archaeological sites within the projects wider area were identified, including the Gramada Iron Age necropolis near Buchim and the Star Bunar early Christian basilica in Baltalija. These sites are located outside of the area of influence and will not be affected by the project. The ESIA also identified locally important cultural use areas, including a gathering site used for local celebrations and an unmarked Muslim graveyard located near an access road. The project has adjusted access road design to avoid physical impacts and will implement archaeological supervision and a Chance Finds Procedure consistent with national requirements and PS8 as part of the CESMMP.
