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.

While all E&S Standards are applicable to this investment, WBG’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following E&S Standards.
Bhutan's policy does not officially identify Indigenous People (IP), but the Constitution recognizes the country’s social, cultural and linguistic diversity. The WBG-led assessment, as required by ESS7, did not identify any distinct social and cultural group possessing all four characteristics as defined by ESS7 Paragraph 8 present in the Project-affected area. The assessment concluded that ESS7 is not relevant and applicable to the project. However, there is sufficient evidence to indicate that some local communities, because of remoteness and unique cultural practices may be more likely to be adversely affected by the Project. Therefore, additional attention is required to such groups, particularly when implementing plans related to stakeholder engagement, cultural heritage, SEA/SH, gender and vulnerable groups, and CLD activities.

ESS1: Assessment and Management of Environmental and Social Risks and Impacts

The key risks and impacts to be managed under this Project include the capacity of the client to implement large scale hydro in an ecologically sensitive area, influx of large workforce, SEA/SH, occupational and community health and safety, land acquisition and related economic displacement of households, inefficient use of resources (water, electricity and raw materials), hazardous and non-hazardous waste generation, air, noise and water pollution, especially during the long construction period, generation of Green House Gas (GHG) emissions, erosion and sedimentation, ecological risks and impacts including impairing aquatic and riparian connectivity due to the dam and disturbances to BC #7 due to the reservoir potentially imparing connectivity between the Phrumsengla National Park (PNP) and Bumdeling Wildlife Sanctuary (BWS), and impacts to tangible and intangible cultural heritage. In order to assess, and manage impacts and risks, the Project has prepared a draft ESIA/ESMP (disclosed externally as of Aug 15, 2025). The draft ESIA will be updated and re-disclosed as per the Project’s Environment and Social Commitment Plan (ESCP). Accompanying management plans for key issues are being prepared and will be disclosed during Project implementation as indicated in the ESCP and the Project Environment and Social Management Plan (ESMP). The forthcoming SPV will ensure that relevant aspects of the ESCP, including inter alia, ESIA, ESMP, Biodiversity Management Plan (BMP), OHS Management Framework and Plans (OHSMF and OHSMPs), Labor Management Procedures (LMP), and the worker’s code of conduct are included in the E&S specifications of the procurement documents and contracts with contractors leading different work packages and the Owners Engineer (OE). Additionally, per the ESCP, the SPV will implement Community and Local Development (CLD) activities to ensure local communities experience socioeconomic benefits (direct, temporary jobs in construction, logistics, and through entrepreneurship as well as community-prioritized last-mile infrastructure and services). A draft CLD Plan (CLDP) is under preparation and will detail the potential types of investments, partnerships and timeline. It will include an operational manual – specifying eligibility criteria, exclusion list, screening mechanism, target-setting for vulnerable groups, monitoring and reporting requirements -- to guide the implementation of selected activities.
The PIU has developed an ESMP for the preparatory works covering the construction of access roads and bridges, which will be updated to include the remaining components of the preparatory works, such as additional roads and bridges, adits, and the temporary power line, diversion tunnel required for construction activities. As per the ESMP, each contractor will prepare and implement a Contractor’s Environmental and Social Management Plan (C-ESMP).
The construction of the 35-km power evacuation transmission line (PETL), by Bhutan Power Corporation (BPC), to evacuate power from the Project to the Durungri substation is considered an Associated Facility of the Project. An Environmental and Social Management Framework (ESMF) has been prepared for the PETL and disclosed together with the draft ESIA. As per the ESCP, the SPV will update, finalize, and implement the ESMF for the PETL, consistent with the ESF requirements, and ensure that BPC prepares and implements an ESIA and ESMP and applicable E&S instruments, in accordance with the ESMF.
A Cumulative Impact Assessment (CIA) was conducted in 2018 for the Kuri-Gongri Basin to evaluate the combined E&S impacts of multiple hydropower Projects, including Dorjilung. As part of the current Project, an addendum to the 2018 CIA was prepared to update and supplement its findings, ensuring the assessment reflects current E&S conditions, as well as planned and ongoing developments in the basin. The CIA studies considered various past, present, and future activities in the Kuri-Gongri River Basin, The assessment reviewed 12 key Valued Environmental and Social Components (VECs), including forest cover, slope stability, migratory fish, protected areas, livelihood opportunities, and downstream public safety. The main recommendation for managing cumulative impacts is to develop a program focused on aquatic and fish species, which would complement the Project’s mitigation plans and contribute to broader basin-level and state-wide strategies for aquatic habitat management (see ESS6 for further details). As per the ESCP, the SPV will coordinate with relevant government agencies and stakeholders to disseminate the updated findings and facilitate the integration and implementation of key CIA recommendations into Project planning and basin-level management. As per the ESCP, the SPV will develop and operationalize (prepare documents, assign responsibilities, allocate budget) an ESMS for the construction and operations phases respectively, consistent with the relevant ESSs, and including the following elements: (i) policy; (ii) identification of risks and impacts; (iii) management programs; (iv) organizational capacity and competency; (v) emergency preparedness and response; (vi) stakeholder engagement and grievance mechanism; and (vii) monitoring and review. The construction phase ESMS also requires contractor-specific obligations, mitigation plans and performance indicators.
Organizational Capacity and Training: During the Project preparation phase, DGPC set up an E&S team, which was later transitioned to the Environmental, Safety, Health and Social Division (ESHSD) within the DHPP PIU, to prepare the E&S risk assessments, management plans and contractual documentation. The team consists of an E&S Manager supported by two environmental officers, 1 OHS officer and 2 inspectors, 2 social officers, 1 biodiversity lead specialist, 1 GBV Specialist and a team of international and national consultants. Once the SPV is established, the ESHSD team will be transferred to the SPV and, as per the ESCP, additional qualified staff will be recruited to support the management of environmental, health and safety, and social risks and impacts of the Project during the construction phase, including additional expertise in Environment, OHS, Biodiversity, Labor, Land Acquisition and Livelihood Restoration, Stakeholder Engagement, Sexual Exploitation and Abuse and Sexual Harassment (SEA/SH), Social Inclusion & Gender. For the supervision of the contractors’ ESHS performance, the SPV’s E&S team will also be supported by the Owner’s Engineer (OE), which will include dedicated environmental and health and safety expertise. The division of labor between OE and SPV E&S teams will be further defined as part of the ESMP update, and driven by available local/international expertise, sequencing as well as constitution/structure and operational offices/ teams of the SPV.
Contractor Management and Assurance: Several large contractors for main works (such as dam, headrace tunnel, powerhouse, electro-mechanical) including subcontractors, and smaller contractors (for preparatory work such as access roads, construction transmission line, adits, diversion tunnel) will be involved in the construction of the Project, with the SPV coordinating the works packages. Contractor requirements as defined in various plans (including the ESMP, OHSMF/OHSMP and LMP) include specific construction E&S specifications and monitoring requirements including periodic audits, inspections, and spot checks of Project locations and worksites. As per the ESCP, the SPV will incorporate these E&S requirements and the code of conduct into the E&S specifications of the procurement documents and contracts with contractors. The SPV as part of the ESMP update will have provisions for effective oversight and monitoring of the C-ESMP implementation by contractors. The updated ESMP will also include a detailed E&S monitoring and reporting plan that will cover all EHSS aspects of relevance during construction.
Monitoring & Reporting: The SPV will prepare and submit to the WBG regular monitoring reports on the environmental, social, health and safety (ESHS) performance of the Project as per the ESCP. An Independent E&S Adviser (IESA) will be engaged to carry out an independent review of the Project’s E&S performance. The IESA will undertake quarterly reviews throughout the construction phase and during the first two years of operations. These reviews will include site visits, verification of monitoring data, and assessment of compliance with agreed E&S requirements, as outlined in the ESCP, ESIA/ESMP, CIA, BMP, SEP, GRM, LMP, OHSMPs, C-ESMP, Cultural Heritage Management Plan (CHMP), and SEA/SH Prevention and Response Action Plan. The process will evaluate both documentation and on-the-ground implementation to ensure that commitments are being met. The IESA will prepare and submit detailed quarterly E&S monitoring reports to the WBG, providing independent assurance of the Project’s performance and highlighting any gaps or areas requiring corrective action.

ESS2: Labor and Working Conditions

The Project related workforce will be composed of: i) direct workers including officials working with the SPV, civil servants in government agencies with direct responsibilities for Project operations, as well as individual consultants, who will be engaged by the SPV; ii) workers engaged by the Project contractors and their sub-contractors for construction works; iii) primary supply workers engaged by the suppliers of goods and services to the Project contractors and their sub-contractors. Additionally, the Project may engage community workers for a limited number of activities aligned with the Project development goals under the CLDP aimed at providing last-mile infrastructure and services to be identified through community mobilization, participatory planning and decision-making during Project implementation. As per ESS2, community workers are defined as those providing services to Project activities with no or limited direct benefits, to support activities aligned with the Project development goals, and who extend direct benefits to their own communities.
Project construction period is expected to last 78 months (including 18 months of pre-construction), with a peak workforce of over 6,000 direct workers and contracted workers. The majority of the workforce will be male migrant workers mainly sourced from India due to the shortage of skilled and unskilled labor in Bhutan. Around 300 direct workers expected to be Bhutanese workers will be required during the Operations and Maintenance period.
Human Resources Management: The SPV has developed a Labour Management Procedure (LMP) in line with Bhutanese labor laws and ESS2 requirements, which is applicable to all Project related workforce. The Project labor commitments outlined in the LMP include: i) the principles of non-discrimination, equal opportunity, prevention of all forms of forced and child labor, and support for Freedom of Association and Collective Bargaining; ii) employment terms and conditions (this includes written contracts, working hours, wages and deductions, overtime requirements, leave and rest periods); iii) the principles for recruitment and termination; iv) the Project Code of Conduct; and v) provisions for a Workers’ Grievance Redress Mechanism (WGRM). Each contractor will be required to prepare their own Labour Management Plans based on this LMP. The LMP will be included in bidding documents and contracts. The SPV has developed a Human Resources Manual applicable to the SPV staff in line with the LMP requirements. The SPV has also developed a SEA/SH Action Plan that outlines mitigation measures (contractor sensitization, worker training, codes of conduct, monitoring, and gender-sensitive facilities). Given the temporary nature of the construction phase, the workforce will be demobilized at the end of the construction period in accordance with national law and the LMP requirements.
Workers’ Grievance Redress Mechanisms (WGRM): In line with the requirements of the ESS2, the LMP also includes provisions for a WGRM through which the Project related workforce will be able to raise work-related grievances. The WGRM outlined in the LMP defines a process to receive and manage all worker related grievances and includes provisions for anonymous grievances, confidentiality, and non-retribution. As per the LMP, the SPV and each contractor will develop and implement their own WGRM, reflecting consistently the principles and process outlined in the LMP. Furthermore, the SPV will extend its WGRM to third party workers in addition to collecting and monitoring the management of grievances through monthly reports by the contractors and periodic checks. As stated above any grievances/cases related to SEA/SH will be managed by a separate mechanism established under the SEA/SH Prevention and Response Action Plan (please see ESS4 for more details).
Workers Accommodation: The Project workforce including migrant workers will be housed at Construction Camp Facilities (CCFs). The SPV staff may also reside in offsite accommodations. Per the ESCP, the CCFs will be constructed and operated based on detailed specifications and camp rules and regulations as specified in the LMP and aligned with Good International Industry Practice (GIIP) as described in the EBRD-IFC Worker Accommodations Practices and Standards (2009). Offsite accommodation, if provided by the SPV, should also meet the same standards as applicable.
Occupational Health and Safety: The SPV has developed an OHSMF, which outlines the requirements of an OHS Management System for the construction phase of the Project, in line with Bhutanese regulations and ESS2 requirements. The OHSMF requirements will be included in the construction contracts, as well as the requirement to monitor and report performance related to OHS. The OHSMF requirements include establishing associated policies; processes for induction; regular training; provision and use of personal protective equipment (PPE); hazard identification and risk assessment; permit to work; prevention, reporting, recording, investigation, analysis of accidents and incidents; follow up on corrective actions; Standard Operating Procedures (SOPs) for a range of construction activities, and emergency response. The OHSMF also includes provisions on the required OHS structure with roles and responsibilities at contractor level. Requirements on the provision of medical care, first aid and provision of medical treatment are included in the ESMP. Guided by the OHSMF, each contractor will formulate, implement, and maintain their own Occupational Health and Safety Management Plan (OHSMP) specific to their scope of work, as per the ESCP. The SPV E&S team, with the support of the OE, will be responsible for checking and approving the contractors’ OHSMP, verifying the contractors’ compliance with OHS requirements and ensuring control measures are in place before start of work.
Contractor Management: Several contractors and sub-contractors will be involved in the civil works program, with the SPV coordinating the works packages. Contractor requirements with regard to Human Resources Management are defined in the LMP, which will be attached to the contracting documentation. The LMP requires that contractors monitor, keep records and report to the SPV on labor and OHS management. As per the ESCP, to manage the labor and working conditions risks associated with a substantial migrant workforce, the SPV will include the following additional requirements in the LMP: i) key principles and processes to assess and manage the risk of exploitation and abuse of migrant workers during recruitment, deployment, and demobilization, and discrimination in terms of conditions of employment such as wages, benefits and accommodations; ii) Accommodation Camp specifications in line with IFC/ EBRD Guidelines (2009); and iii) the Project’s labor monitoring requirements.

ESS3: Resource Efficiency and Pollution Prevention and Management

Resource Efficiency: The Project will require substantial quantities of construction materials, including cement, steel, aggregates, and sand. Most aggregates will come from two quarries, one at the dam site and one near the powerhouse, while sand and minor aggregates will be sourced from Natural Resources Development Corporation Limited (NRDCL) sand mining operations near Gyelpozhing and Authso. Excavated tunnel material will be reused wherever feasible to optimize resource use. Construction power will be supplied through temporary transmission lines, planned in consultation with the Bhutan Power Corporation (BPC). The estimated peak construction power demand is about 15 MW. The estimated peak construction water demand is 476 m³ per day, to be sourced from nearby tributaries. Dedicated pipelines will be installed along road sections to transfer water without affecting other users. Per the ESCP, the C-ESMP will incorporate measures for the efficient use of water and use of energy-efficient equipment.
Greenhouse gas emissions: The Project is expected to result in significant GHG emissions reductions of 113.66 million tons of CO2-equivalent, or 2.67 million tons per year, over the asset’s 40-year life, aligning with Bhutan's climate goals and contributing positively to regional emission reduction targets. DHPP has a high power-density (1,023 W/m²), associated with low reservoir GHG emissions (<1 g CO2/kWh) deemed negligible compared to avoided thermal emissions.
Water Management: The construction of the tunnels may intersect with fault and fracture zones within the geology of the Project area, and seepage from these works could lower the groundwater table, potentially reducing flows from overlying springs that are critical for local water supplies. As per the ESCP, prior to commencement of major infrastructure work and tunneling, the SPV will conduct an assessment and monitoring of all water sources (location, water availability and quality) used by local communities for drinking water, irrigation and as water supply for livestock along the tunnel alignment, roads and Project’s direct footprint. ’s direct footprint. As per the ESCP, the SPV will also require contractors to prepare a Water Management Plan, incorporating the findings of this assessment and subsequent monitoring, to prevent and mitigate impacts to community water resources including: (i) identification and flagging of the location of water sources; (ii) monitoring and documentation of water yield and quality before, during and after construction to detect impacts; (iii) provisions to minimize earth works and any other disturbance in the area around springs and creeks to avoid and minimize sedimentation or chemical contamination; and (iv) provisions for providing water to local villages if the supply source is affected due to Project-related activities. Should any local springs be affected, the SPV will ensure that adequate alternative water supplies to the affected households are provided. Additional requirements to prevent the uncontrolled ingress of groundwater in the tunnel are also included in the Infiltration and Seepage Management Plan below.
Air & Noise Emissions and Vibrations: The main sources of air pollution during construction will include (i) dust emissions from excavation, blasting, operation of construction facilities (e.g. quarries, crushers, and batching plants) and the movement of heavy vehicles on unpaved roads, and (ii) exhaust emissions from construction equipment and transport vehicles. The Project is located in an area with generally good air quality and landscape conditions will tend to limit the dispersion of fugitive dust and emissions. Per the ESCP, contractors will prepare and implement an Air Quality Management Plan, specifying dust suppression, vehicle and equipment emission controls, and monitoring protocols. Noise and vibration levels will increase significantly during construction due to activities such as blasting for tunnels and excavation, operation of heavy machinery, and vehicular traffic, particularly along access roads. Per the ESCP, the SPV will require contractors to prepare and implement a Noise and Vibration Management Plan, specifying control and mitigation measures such as restricting noisy operations to daylight hours, regular equipment maintenance, and conducting noise monitoring at key locations. Vibration impacts may result from blasting operations, potentially affecting nearby structures. Per the ESCP, the SPV will conduct a pre-blast survey documenting the use and conditions of residences, community infrastructure, and sensitive structures such as temples, potentially affected by vibration, along with recording of community concerns and vibration monitoring methodology. In addition, as per the ESCP, the SPV will require contractors to prepare and implement an Explosive and Blasting Management Plan, detailing safe storage, transport, handling, and use of explosives, including blast timing, vibration control, controlled blasting techniques, real-time vibration monitoring, safety protocols, and, where necessary, provisions for compensation and/or structural strengthening or repair of damaged structures.
Effluent Management: During construction, runoff from disturbed areas and tunneling activities, spoil disposal sites, and muck dumping could lead to sediment-laden water entering the Kurichhu River, increasing turbidity and obstructing river flow. The Project will implement erosion control measures and construct sediment retention structures to reduce sediment flow into water bodies. As per the ESCP, the SPV will require the contractors to prepare and implement an Erosion and Sediment Control Plan, to prevent soil erosion and sediment run-off from construction sites, stockpiles, and muck disposal sites. Other liquid waste from the Project will include runoff from work areas (e.g., batching plant drainage with typically high pH), runoff from equipment cleaning and general site maintenance, workers’ facilities and accommodation will also generate black and grey wastewater. As per the ESCP, the SPV will require the contractors to prepare and implement a Wastewater and Drainage Management Plan, covering the treatment and safe discharge of domestic sewage and construction wastewater, as well as stormwater management measures, to ensure that effluent meets statutory standards and WBG EHS Guidelines requirements before discharge.
Process water will be generated also from tunnel drilling (e.g., water used to cool drill bits and intercepted groundwater, often containing high suspended sediment levels). As per the ESCP, the SPV will require the contractors to prepare and implement an Infiltration and Seepage Management Plan to prevent and address water from the tunnel and from muck disposal sites. The Plan shall include: (i) Methods to be employed by contractors to identify tunnel sections requiring pre-excavation grouting to prevent uncontrolled ingress of groundwater. (ii) Procedures for assessing the potential for acid or alkaline rock drainage generation. (iii) Design and operational arrangements for temporary settling lagoons and treatment facilities, as necessary, to clarify and neutralize water prior to discharge to surface water bodies. Provisions for the collection, containment, and treatment of runoff from stockpiles of tunnel-excavated rock spoil if a high ARD potential is identified.
Waste Management: The Project is estimated to generate about 7 million cubic meters of excess earth (muck/spoil) from excavation and tunneling activities which will be disposed in 12 identified muck disposal sites (MDS) distributed along the right bank of the dewatered section of the Kurichhu River. As per ESCP, the SPV will prepare detailed designs of the MDS to prevent muck from entering the Kurichhu River and require contractors to prepare Muck Disposal Planning and Management Plans that include engineering measures such as retaining structures and drainage systems as per the detailed design, erosion control, revegetation, and monitoring, along with an approved implementation budget, to ensure the long-term stability of muck disposal sites.
Peak construction is estimated to generate approximately 3 to 4.2 tons of solid waste per day. The SPV will collaborate with the Dzongkhag Administration and the Ministry of Infrastructure & Transport (MoIT) to identify a suitable site for a dedicated sanitary landfill to be established within the Project area prior to commencement of the main works activities that involve waste transportation, treatment and disposal, as per ESCP. Medical waste generated by the Project’s clinics will be managed through an agreement with the Mongar Regional Referral Hospital, in line with national protocols for medical waste incineration.
As per the ESCP, the SPV will require contractors to develop and implement a comprehensive Waste Management Plan covering all waste streams generated by the Project. The plan will address waste segregation at source, safe collection and on-site storage, transportation, opportunities for reuse and recycling, and final disposal at approved facilities, in compliance with applicable national regulations and WBG EHS Guidelines. As per the ESCP, the SPV will also identify the landfill(s) and third-party service providers for the transportation, treatment, and disposal of project-generated wastes, and require contractors to use only these approved facilities/providers while maintaining a chain of custody for hazardous waste.
Hazardous Chemicals: Construction activities will involve the use of a variety of hazardous materials, including petroleum products, oils and lubricants, paints, solvents, cleaning agents, and explosives. As per the ESCP, the SPV will require contractors to develop and implement a Hazardous Substances Management Plan including procedures for the safe storage, handling, transport, and disposal of hazardous substances.

ESS4: Community Health and Safety

Dam Safety: The Detailed Project report (DPR)/feasibility study includes Dam Safety Plan. The WB dam safety specialists reviewed the dam safety plans required for appraisal, i.e. draft TORs for Owner’s Engineer, Preliminary Operation & Maintenance Plan, and Framework Emergency Preparedness Plan which will be finalized based on their comments. An Independent Technical Panel of Experts (PoE) has reviewed the DPR/feasibility study including aspects regarding seismic hazards, geotechnical studies, tunnel alignment, construction methods and Glacial Lake Outburst Flood (GLOF) and dam safety. As per the ESCP, the SPV will: (a) Maintain an independent panel of experts (Dam Safety Panel), with terms of reference and composition acceptable to the WBG, to, inter alia, review and advise on matters related to safety and other critical aspects of the Dorjilung dam, its appurtenant structures, the catchment area, the area surrounding the reservoir, and downstream areas, as relevant. (b) Inform the WBG in advance of the Dam Safety Panel meetings and share with it a copy of the Panel report of its conclusion and recommendations signed by each participating member after each meeting. Implement the recommendations made by the Dam Safety Panel, unless otherwise agreed to in writing by the WBG. (c) Recruit the Owner’s Engineer including experienced and competent dam engineering professionals in accordance with terms of reference acceptable to the WBG to supervise the design and construction of the Dorjilung dam and associated works. Implement dam safety measures during design, bid tendering, construction, operation, and maintenance in accordance with Good International Industry Practice (GIIP) and ESF Good Practice Note on Dam Safety and the requirements of ESS4, including (d) below. (d) Prepare and implement the following dam safety plans: (i) Construction Supervision and Quality Assurance Plan; (ii) Instrumentation Plan; (iii) Operation and Maintenance (O&M) Plan; (iv) Emergency Preparedness Plan (EPP) including dam break analysis, flooding simulation and mapping, and consequence assessment, as well as the emergency notification protocol with downstream riparian countries; and (v) Reservoir Filling and Commissioning Plan including E&S mitigation measures in form and substance acceptable to the WBG. (e) Carry out safety inspections of the Dorjilung dam at intervals of not less than once every five (5) years during operation, by independent experts with terms of reference acceptable to the WBG.
The SPV has retained the services of Design consultants to provide detailed designs, which the contractors will implement under a standard engineering and construction contract (i.e., not a full EPC model). All design drawings (from Design consultants) will be provided by the SPV and verified by Owner Engineer (OE), with the PoE reviewing main designs for quality and safety.
Emergency Preparedness and Response: Potential emergencies during construction could include floods, wildfires, landslides and man-made incidents such as fires, leaks, or spills. Given the Project’s location in steep terrain and proximity to the river, intense monsoon rains may cause floods that damage infrastructure and equipment, leading to delays, and pose risks to community members and workers. Wildfires during dry seasons threaten access roads and facilities, posing safety risks to workers and potentially halting progress. Frequent landslides and rockfalls in regions like Mongar and Lhuentse endanger vital infrastructure and on-site personnel due to their sudden occurrence. As per the ESCP, the SPV will ensure that contractors prepare and implement a comprehensive Emergency Preparedness and Response Plan to address these risks. The plan will include engineering measures such as slope stabilization, drainage improvements, and creation of firebreaks and clear zones around the construction sites, as well as provision of safety barriers, warning signage, and life-saving equipment near water bodies to prevent drowning incidents. Early warning systems will be established, and a trained Emergency Response Teams will be formed for each contractor with clear communication protocols and coordination mechanisms with the SPV and local authorities. Evacuation routes, assembly points, and response procedures will be defined and communicated to all personnel, with rescue, first-aid and fire protection equipment regularly inspected and maintained. Contractors will conduct regular training sessions and emergency drills for scenarios such as floods, fires, and landslides to ensure preparedness and raise safety awareness among workers. A system for incident reporting, documentation, and root-cause analysis will be implemented, with lessons learned used to improve the plan over time. Records of accidents, diseases, and incidents will be maintained and reviewed as part of compliance monitoring and audits. These measures will strengthen Project resilience, protect workers and communities, and help ensure continuity of construction activities during emergency events. For operations, the SPV will prepare an emergency preparedness and response plan as part of the dam safety plans.
Community Health & Safety: Traffic & Road Safety: Being a land-locked country, the road network is the primary means of transportation across the country. Apart from the main highway that connects the western part of the country to the eastern, there are limited additional roads serving the Project area. In general traffic levels are low, mostly consisting of light vehicles and some heavy vehicles. Traffic levels in the Project area are expected to increase significantly during the construction phase. Routine construction related traffic and non-routine transportation of heavy equipment and materials from port to site, may involve major logistical challenges and can result in an increased risk of accidents, road safety-related issues and conflict with communities along the corridors used for construction-related transport (e.g. disruption of precarious community water or electric connections or private or public property perimetral walls/fences that will need to be temporary removed to allow for passage of large equipment). To manage these risks, as per the ESCP, the SPV will require the contractors to prepare a Logistics and Traffic Management Plan (TMP) as part of their C-ESMP.
Influx Management: At its peak, the workforce is expected to be over 6,000 workers spread over various Project locations; compared to a local population of nearly 19,000 within the 7 directly affected Gewogs, this represents a significant influx of workers from outside the local area and has the risk of generating a number of community health and safety risks, such as the spread of infectious and communicable diseases (including those sexually transmitted), potential increases in crime rates locally, risk of conflict between local communities and newcomers over cultural differences, and pressure on local infrastructure and services (such as health, water and sanitation). All migrant workers will be housed in the CCFs and governed by camp regulations and the workers’ Code of Conduct that regulates interaction with communities. As per the ESCP, the SPV will also require the contractors to prepare a Community Health and Safety Plan as part of their C-ESMP.
SEA/SH risks are recognized as significant due to the large influx of migrant workers and the Project's remote location, with concerns about impacts on local women and girls, especially near worker camps and along transport routes. Based on a detailed baseline and consultations with men and women from local communities, NGOs, CSOs and government agencies in Bhutan, the SPV has assessed such risks and developed a SEA/SH Prevention and Response Action Plan, which will be implemented throughout Project implementation, as per the ESCP. The SEA/SH Action Plan provides management measures at the Project and government levels to prevent and respond to risks and grievances/cases associated with SEA/SH. At the Project level these include provisions against SEA/SH within the Worker Code of Conduct, SEA/SH provisions in the Accommodation Camp specifications, a dedicated survivor centric GRM to receive and manage grievances/cases related to SEA/SH. Other measures include sensitizing SPV staff and all Project actors, capacity building at local government level and community awareness raising. As per the ESCP, the Project has hired a full-time Gender/GBV Specialist and will hire an experienced local NGO/firm to oversee and monitor the Action Plan implementation. As per the ESCP, the Project has also developed and will implement a Gender and Vulnerability Action Plan (GVAP), following consultations with local women and vulnerable groups. The GVAP includes activities aimed at reducing the social vulnerability of women, people with disabilities, and youth, and improving their participation in decision-making processes and access to employment opportunities and income-generating activities.
Security Personnel: Security arrangements will be managed by contractors during construction (in the Project area such as labour camps, Project office, site construction areas) and by the SPV during the operations phases. Security-related risks are low in the Project area, which has low crime rates and no identified risk of violence or use of firearms. Access to construction sites, storage and laydown areas, tunnels, workers’ accommodation and the powerhouses during operation will be controlled by fences, gates and security guards. It is anticipated that the contractors will make use of unarmed private security contractor personnel to safeguard the Project and workforce. The OHSMF provides a brief overview of the security management plan. As per the ESCP, the contractors as part of C-ESMP will develop detailed Security Management Plan which will be guided by the principles of proportionality, consistent with ESS4 and guided by IFC’s Good Practice Handbook on the Use of Security Forces: Assessing and Managing Risks and Impacts and include procedures to: assess risks posed by security arrangements; ensure hiring, rules of conduct, training, equipping, and monitoring of security personnel; provide for background verification on security personnel's individual character with no incidents of past abuses; train security personnel to exhibit appropriate conduct towards Project workers and neighboring communities; train security personnel to manage mock sessions of labor unrest and protests; and to receive and resolve grievances about the security arrangements and acts of security personnel.
Ecosystem Services: Impacts are limited as fishing is not a major provisioning service. There are some uses of non-timber forest products and some impacts on community woodlands that will be addressed under ESS5 mechanisms.

ESS5: Land Acquisition, Restrictions on Land Use and Involuntary Resettlement

The SPV has started to acquire a total of 918.31 acres of land, comprising 900.08 acres of state reserved forest (SRF), 18.23 acres of private land, and 0.66 acres of institutional land. Of the total 18.23 acres of affected private land, 9.07 acres will be permanently acquired, while the remaining 9.16 acres will be temporarily acquired on lease for the construction period. Additionally, 0.66 acres of institutional land will be permanently acquired. The acquisition of private land will impact a total of 53 parties, including 51 Project-affected households with 157 Project-affected people and two Project-affected institutions. Of the 51 Project-affected households, the acquisition of the private land will result in the physical displacement of one household, while the remaining 50 households will experience permanent economic displacement. Of the 18.23 acres of private land being acquired, 3.88 acres are currently under agricultural use owned by six households. Furthermore, 12 households will be impacted by the loss of 342 fruit trees.
To support and manage the Land Acquisition and Resettlement (LAR) process, the PIU has developed a Land Acquisition and Livelihood Restoration Plan (LALRP) in line with ESS5 requirements. The LALRP includes the findings of the census and socio-economic surveys, an assessment of LAR impacts, and defines the eligibility criteria and entitlement matrix. The LALRP makes provisions for in-kind and cash compensation for impacted assets at full replacement cost, with no deduction for depreciation, and recovery of salvageable materials. The plan also outlines high-level livelihood restoration measures such as job opportunities and skill training, allocates the responsibility for the LAR process between the SPV and the Government, defines implementation schedules and appropriate monitoring and auditing requirements. The SPV has established a GRM as part of the SEP and this mechanism will cover all grievances of the people living in the Project area, including complaints regarding the implementation of the LALRP. Should additionally land, beyond what is covered in the LALRP, be required by the Project, the SPV will require for the land acquisition to be undertaken using the existing Project LALRP principles and in compliance with ESS5. As part of the LALRP, the SPV will retain an independent consultant to undertake a completion audit.
As per the LALRP, the SPV will prepare and implement a Livelihoods Restoration Manual in line with ESS5 requirements to plan, operationalize and implement the livelihood restoration measures under the LALRP.

ESS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

The Project lies in eastern Bhutan in a landscape dominated by natural habitats consisting of forests and riverine habitats of the Kurichhu River. Protected areas and internationally recognized areas are located to the east and west of the Project and include the Phrumsengla National Park (IUCN category II) and Important Bird Area (IBA); and the Bumdeling Wildlife Sanctuary (IUCN Category IV) which is also an IBA.  These two protected areas are linked by Biological Corridor #7 (BC#7), the southern arm of which is crossed by the Project’s reservoir.  

Critical habitat features have been preliminarily identified, which includes BC#7, as well as species including Bengal tiger (Panthera tigris) IUCN Endangered (EN) and Dhole (Cuon alpinus) IUCN EN under ESS Criteria (a) and their prey species under ESS Criteria (e). Several birds have also been identified including Pallas's Fish-eagle (Haliaeetus leucoryphus) IUCN EN under Criteria (a) and (c) and White-bellied Heron (Ardea insignis) IUCN CR Criteria (a).  Additionally, two species of flora Hoya bhutanica IUCN EN and Cycas pectinata IUCN Vulnerable have been identified under ESS6 Criterion (b).  Three species of restricted range torrent catch fish have been identified as candidate critical habitat values, all of which are IUCN Not Evaluated under Criteria (b). 

There are aquatic, riparian and terrestrial biodiversity features that have been identified as natural habitat.  These include the Kurichhu River's aquatic ecosystem, forested areas outside Biological Corridor #7, threatened species not considered critical habitat features, and remaining riparian habitats near the tailrace and powerhouse.   

The Project will impact 605ha of forested natural habitats and critical habitats including the loss of connectivity in the southern portion of BC#7 by the inundated area from the dam of around 145ha. Riverine impacts will result from the dewatering of 16km below the dam and conversion of 5km of the river to lotic habitats along the inundated river.  Changes to the natural flow regime downstream of the powerhouse will result in impacts to fish, including migrants and torrent catfishes. However, these impacts will be incremental to existing Kurichhu HPP impacts which are located immediately downstream of the powerhouse. A 16 km dewatered reach plus the high dam is likely to impact upstream/downstream fish migration, fragment riparian and aquatic habitat. Regulated flow may impair seasonal lateral connectivity into flood plains.   

To compensate for residual impacts, a Biodiversity Management Plan (BMP) has been prepared.  This BMP addresses direct and indirect Project impacts to biodiversity during construction and operation by establishing and maintaining a competent Biodiversity Unit in the SPV to implement measures to manage projects impacts.  These mitigation measures will include measures to reduce mortality from machines and hunting, implementing safe wildlife crossings, animal rescue and ongoing wildlife survey programs, avoiding/relocating critical habitat flora values and conducting awareness programs.  Relevant mitigation measures alongside the ESMP will be incorporated into bidding documents as contractual obligations.  An environmental flow will be released to maintain habitats within the dewatered zone of the river, in addition to other measures included in the Environmental Flow Management Plan (EFMP) to manage potential impacts to the aquatic habitat and associated ecology. The BMP also includes a preliminary biodiversity conservation strategy, aiming to achieve no net loss of natural habitat and net gain of critical habitat as per ESS6 requirements, through implementing compensation/offset programs for the loss of critical and natural habitats designed to manage forested habitats within BC#7, reafforestation programs and fish conservation initiatives, and capacity support to protected areas and conservation initiatives through working with the Department of Forests and Park Services (DoPFS) and their field offices. Action plans relating to recording habitat loss, undertaking and documenting pre-construction surveys for breeding birds and important botanical features so they can be avoided will also be implemented during construction as per ESCP.

Building on the recommendation from the CIA (2018 and 2025 Addendum), in alignment with good international practices, and as part of the approach to maintain biodiversity, the WBG is engaging with the client and the RGoB to  explore all options – including, but not limited to, maintaining, conserving, protecting, and enhancing at least one river, river segment, or tributary within Bhutan as a free-flowing watercourse that can offset the impacts to migratory and resident aquatic biodiversity features from DGPC's portfolio of hydropower projects. This approach could function as an aquatic / riparian offset which would increase the robustness of the proposed measures to achieve no net loss/net gain per ESS6 requirements. 

Further analysis is required, however, to confirm impacts on both natural and critical habitats.  As per the ESCP, the SPV will conduct additional surveys to understand the ecology of torrent catfish to confirm critical habitat designation as well as impacts to the critical habitat values of Biological Corridor #7 to inform residual impacts and adaptive management. Further assessment of migratory fish (natural habitat feature) is also required.  The existing actions in the BMP will be reviewed, and conservation metrics will be established to quantify and make recommendations on compensation/offset measures. An assessment of the technical, financial, and political feasibility of these measures to achieve no-net-loss and net gain will be completed, to assess the long-term viability of the biodiversity offset strategy for the Project.  The findings of the analysis will be used to update the BMP and will be implemented when completed.  

ESS8: Cultural Heritage

The Project area has a number of tangible (e.g. monasteries/ stupas, sacred sites, stone baths and traditional houses) and intangible (including festivals/ ceremonies, belief systems, traditions, etc.) cultural heritage. The ESIA identified such tangible heritage sites and intangible cultural elements located, practiced or present in the Project area, assessed impacts and risks, and this information was used to prepare a Cultural Heritage Management Plan (CHMP) in line with ESS8 requirements. This plan includes mitigation measures such as relocating tangible heritage sites with community consent, ensuring signage to delineate cultural sites boundaries for protection, and raise awareness for preserving and promoting intangible cultural heritage, including ceremonies and rituals to appease nature-linked deities as advised by local communities. The CHMP has been informed by consultations in local languages and findings from the ESS7 assessment to screen for the presence of Indigenous Peoples. The CHMP also includes a Chance Finds Procedure which, together with the Workers’ Code of Conduct, will be implemented by the construction contractors. Supervisors and construction workers will be trained in their responsibilities in line with the CHMP.