Tricon Boston Consulting Corporation Pvt. Limited
IFC is considering providing loan(s) of up to US$75 million to Triconboston Consulting Corporation Private Limited (TBCCPL or the Company). The loan(s) would support the construction, operation and maintenance of three adjacent 50 MW (TBCCPL A, B & C total 150 MW) greenfield wind farms. The project site is in the Jhimpir Wind Corridor, Thatta District of Sindh Province in Pakistan, between Karachi and Hyderabad, approximately 50 km from Karachi and 100 km inland from the coast.The project will install a total of 87 wind turbine generators (WTG) (29 at each sub-project). Each turbine will have a generating capacity of 1.7 MW and will require about 2.5 acres of land. Government of Sindh leased 1284acres (500 ha) of land to each TBCCPL 50 MW wind power plant. For all the three sub-projects (150 MW combined), the total land utilization will be 2025 acres (820 ha) out of total land area of 3852 acre. Depending on the final micrositing, WTGs may be spaced around 200m apart from one another in a series of rows and will have 103m rotor diameter, 80m hub height and 131m tip height. WTGs are manufactured by US based General Electric (GE). The landscape is semi-arid and sparsely populated. Isolated hamlets exist within the buffer area between TBCCPL A, B & C wind power plants, within the broader project site leased to the Company by Government of Sindh. The Company has designed the wind farm layout in such a way as to avoid physical and economic displacement and minimize the effect of shadow flicker and operational noise on the nearest hamlets. The closest sensitive receptor/residence is located 0.8 - 1 km from a WTG. The total footprint of the project is estimated to be less than 350 acres (i.e. wind turbine generators 2.5 acres/WTG x 87 WTGs, access road of about 60 acres, and a switchyard of about 10-15 acres) compared with the total 3,852 acres of the site. No physical or economic displacement of people is expected. Only the WTG land parcels and the project's substation land parcel will get fenced by the Company for safety and security reasons. The majority of the project site of 3,714 acres will remain free for access to villagers for their routine activities including grazing of their cattle and seasonal cultivation.TBCCPL is a special purpose vehicle majority-owned by Sapphire Group (the Sponsor). Sapphire Group is one of the oldest business groups in Pakistan with dominant presence in textile sector and now diversifying into power generation including renewable energy. The group has already established Sapphire Wind Power Company Limited (SWPCL), a 52.8 MW operating wind power plant in the same (Jhimpir) area.This project will be an independent power producer and will sell electricity to the Central Power Purchasing Agency Guarantee Limited (CPPA-G) under a separate 20-year Energy Purchase Agreement (EPA) for each 50 MW sub-project. CPPA-G's payment obligations under the EPAs will be guaranteed by the Government of Pakistan.The construction work will be carried out by Chinese Engineering, Procurement and Construction (EPC) companies HydroChina Corporation and HydroChina International Engineering Company Limited (HydroChina), which are Chinese State owned companies fully owned by Power China International. HydroChina worked with Sapphire group for their 52.8 MW Sapphire Wind Power Co Ltd.The Company will also develop internal access roads to service the WTGs within each sub-project and access road from the existing public road. Between the three power plants there will be internal connecting road. A main construction camp will be developed at TBCCPL power plant B while two satellite facilities will be developed at TBCCPL power plants A & C.The WTGs will be connected to a 132 kV high voltage switchyard in the power plant via a 33 kV underground or over ground electrical collection system based on land topography. Electricity from the project will be transmitted from this 132 kV switchyard to the National Transmission and Dispatch Company Limited (NTDC) / Hyderabad Electric Supply Company (HESCO) 132 kV substation. NTDC will develop the connecting transmission line (about 20 km) from the 132 kV switchyard to their 132 kV substation. Sindh Environmental Protection Agency (SEPA) examined the Company's Initial Environmental Examination (IEE) for TBCCPL power plants A, B & C and accorded environmental approval in 2014.It is expected that the parallel construction work will start during the last quarter of 2016 at TBCCPL power plant A, B & C and will be completed in 13-15 months. According to the Company's initial examination, no major environmental and social (E&S) risks are anticipated in relation to the NTDC transmission line or the access road; however, the final social and environmental impacts associated with transmission line will be subject to review under the SEPA's EIA process as well as additional review by IFC. The transmission line is considered as associated facility which is needed for the successful implementation of the project. The implementation of the Environmental Impact Assessment (EIA) is the responsibility of NTDC. Nevertheless, as per the agreed the Environmental and Social Action Plan (ESAP), the Company will monitor the progress of the EIA for the identified associated facility by keeping close contact with NTDC (ESAP Action No. 1(c)).
OVERVIEW OF IFC'S SCOPE OF REVIEW
IFC's review of the project included (i) a site visit from June 6-9 2016 to: the project site, transmission line routes, and access road, including inspection of the operating SWPCL 52.8 MW Wind power plant in Jhimpir, the existing substation facility and the double 132 kV transmission line interconnected to the national grid shared by SWPCL and, and internal roads within the concession area; (ii) meetings with technical, environmental, and social members of the SWPCL team; (iii) discussions with the environmental and social monitoring consultants (Arch Associates) and the EPC contractor (HydroChina); (iv) meeting with one existing family in the new project site; and (v) desktop reviews of TBCCPL power plants A, B & C's IEEs, the Environmental and Social Management Plan (ESMP), bird monitoring study, and other operational policies and procedures including technical, environmental, health and safety and social documents, and assessments submitted by the Company, and prepared against applicable IFC Performance Standards (PS).In addition, IFC used relevant information contained in the following three ESRSs that IFC disclosed for wind farm projects that are located in the same Jhimpir wind corridor: Zorlu Pakistan (56.4 MW), disclosed on April 11, 2011: Metro Power Company Limited (or "MPCL", 50 MW), disclosed on August 22, 2013, and Gul Ahmed Wind Power Limited (50 MW) disclosed on November 13, 2014. IFC also reviewed Jhimpir Wind Farm Region Cumulative Impact Assessment document commissioned by OPIC (ERM, October 2015).
IDENTIFIED APPLICABLE PERFORMANCE STANDARDS**
While all Performance Standards are applicable to this investment, IFC's environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards.PS 1 - Assessment and Management of Environmental and Social Risks and ImpactsPS 2 - Labor and working conditionsPS 3 - Resource Efficiency and Pollution PreventionPS 4 - Community Health, Safety and SecurityPS 6 - Biodiversity Conservation and Sustainable Management of Living Natural ResourcesIf IFC's investment proceeds, IFC will periodically review the the project's ongoing compliance with the Performance Standards
No physical or economic displacement of people will be required. No acquisition of land will be triggered, as 1,284 acres for each of 50 MW windfarm has been provided by the Government of Sindh and lease agreements have already been executed with the provincial government. Finally, there are no indigenous people or areas of high archeological value in the project area of influence. As a result, Performance Standards (PS) 5, 7 and 8 are not considered applicable to this project.
ENVIRONMENTAL AND SOCIAL CATEGORIZATION AND RATIONALE
In accordance to IFC's Environmental and Social Review Procedure (ESRP) and Policy on Social and Environmental Sustainability (PSES) the project is categorized as a Category B project because a limited number of specific environmental and social impacts may result, which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. The most critical environmental, social, and health and safety (ESHS) risks and impacts of the project include: (i) earth movements, vegetation cover removal, and soil erosion associated with excavation and the operation of construction equipment, (ii) occupational health and safety (OHS) risks to construction workers, and (iii) OHS risks to maintenance workers, (iv) potential health and safety risks to the nearby communities associated with dust emissions, high noise levels and blade throw, and (v) permanent landscape modifications.The project site is located in a semi desert area and mostly barren land with sparse vegetation. There are no formal villages and communities within the project site. However, there are some scattered settlements within the larger land parcel awarded to the project and a few hamlets exist mainly in the buffer area between TBCPPL power plants A, B & C. Project micro-siting is being undertaken to minimize impacts (dust emissions, noise, shadow flicker, etc.) on those isolated settlements.
**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability
ENVIRONMENTAL AND SOCIAL MITIGATION MEASURES
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 the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.The Company has presented the information about how the E&S issues and impacts are being addressed, to ensure that the operations at TBCCPL comply with the environmental and social requirements including: the host country laws and regulations; IFC's Performance Standards; and the relevant WBG EHS guidelines. This information is summarized in the paragraphs that follow. Further information is provided in the attached ESAP, which is agreed upon by IFC and other lenders, and will address compliance gaps with IFC's requirements.The main E&S risks/impacts of this project include the following: Company's capacity to manage its social, environmental, health and safety performance in accordance with local requirements and IFC Performance Standards and applicable World Bank Group (WBG) Environmental Health and Safety (EHS) Guideline; inadequate practices and non-compliance with PS2 requirements by the contractors being engaged during construction and operational phases; inefficient raw water management during construction; inappropriate evaluation of noise and visual impacts on sensitive recipient during operation phase; non-compliance of security measures at site with PS4 requirements; inadequate stakeholders process; and Emergency Response Plan lacking response to site specific risks.
PS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS
Policy-Social & Environmental Assessment and Management System: The Company does not have a certified E& S Management System at present. However, the Company has identified E&S risks in its operations and possesses an internal system with structured Social and Environment, Health and Safety (EHS) organization and responsibilities, an E&S policy, procedures, and supporting monitoring and reporting systems and training programs. As per TBCCPL's Code of Conduct and E&S policy, the Company is committed to conducting its business in compliance with all applicable environmental and workplace health and safety laws and regulations and TBCCPL's Social, Environmental, Health & Safety Policies (April 2016). These policies state that the Company will conduct operations in compliance to the applicable laws, regulations and international guidelines and best practices in order to meet social and environmental contractual obligations to investors, lenders, customers and other relevant stakeholders. The policies related to Environment, Occupational Health & Safety and Corporate Social Responsibility will be signed by the CEO of the Company and will be displayed at the corporate office, the project operation sites, and at the website of the Company.Identification of E&S Risks and Impacts: In 2014, the previous owner conducted an Initial Environmental Examination (2014 IEE) for its windfarm power plants TBCCPL A, B & C and obtained an environmental approval from the Sindh Environmental Protection Agency for all three wind power plants. After the acquisition of TBCCPL and its three sub-projects by Sapphire Group, the Sponsor retained a local environmental consulting firm - Arch Associates, which have worked on other wind farms in Pakistan financed by IFC and OPIC - to perform a Cumulative Environmental and Social Impact Assessment and to prepare an ESMP in line with IFC Performance Standards and IFC's Wind Energy EHS Guidelines.The 2014 IEE studies assessed the individual wind power plant (TBCCPL A, B & C) impacts in various relevant areas including land use change, landscape and visual impacts, soil environment, water environment, air quality, noise, loss of natural vegetation, loss and disturbance of habitat, settlement and community access, land-based livelihoods, social and demographic structure impacts by influx of workers, local economy and employment, cultural environment, community health and safety including shadow flicker, blade glint, and blade throw. As captured in the ESAP attached to this review summary, a Cumulative Environmental and Social Impact Assessment is in preparation to take into account the total impact of the 150 MW project (3 x 50 MW) as well the impact of the neighboring windfarm projects. There are around 16 windfarm projects planned for the area, of which eight are under construction and the remainder of which have been issued Letters of Intent (LOI) and land leases as of January 2016. The cumulative assessment under preparationwill build on the 2015 Jhimpir Wind Farm Region Cumulative Impact Assessment report commissioned by OPIC. The Cumulative Environmental and Social Impact Assessment is taking into consideration key potential EHS aspects and impacts such as those related to birds, resettlement, economic impact, noise, visual impact, shadow flicker, transportation, biodiversity and natural resources.A separate baseline Bird Study was conducted for seven months using the Scottish Natural Heritage Guideline for Birds Monitoring in order to determine current bird's flight pattern, flight height, birds count, bird's species identification, birds activity so that project impact on birds and bird's collision risk can be determined. As noted above, no cultural heritage was identified within the project site.Management Programs: For each of the E&S impacts assessed for individual wind power plants (TBCCPL A, B & C) and those in the Cumulative ESIA, a consolidated list of mitigation measures and commitments was compiled as an ESMP with specific management plans e.g. Waste Water Management Plan, Transportation Management Plan, Air Emissions Management Plan, Noise Management Plan, Waste Management Plan, Emergency Preparedness and Response Plan, Spillage Prevention and Counter Control Measures Management Plan, etc. as annexure to the ESMP. The ESMP sets out the arrangements that will be put in place by the Company to manage the E&S performance of the project, its EPC and O&M contractors and their sub-contractors, to outline further studies and surveys to redefine predicted impacts and design appropriate mitigation strategies, to describe the monitoring programs to assess actual impacts and adequacy of mitigation strategies, and to provide framework for compliance auditing and inspection of the project by the Company. In addition, the project has also performed micro /task level Environmental Aspects and Impacts and Occupational Health & Safety Risk Assessment for Construction and Operational phase and developed an Environmental Management Plan and Occupational Health & Safety Management Plan.Organizational Capacity and Competency: The E&S performance of the Company will be managed by the Company's EHS Manager, a Human Resources (HR) Manager and a Community relations Officer, with supplementary technical and managerial support to be provided by Arch Associates, the project ESIA consultants. During the construction phase, the EHS Manager will manage all EHS issues and coordinate with the EHS team of EPC Contractor for management of impacts and implementation of the ESMP and related plans and procedures. Social issues will be handled by the HR Manager and the Community Relations Officer, who will report to the Site Manager. During the operational phase, the EHS Manager will be part of the Company's Engineering Department and will work in close coordination with O&M Contractor and site employees for management of impacts and implementation of the ESMP.Training: Construction workers will receive training on EHS matters, and in particular OHS (safety) awareness and use of appropriate personal protective equipment. This training will be delivered by Arch Consulting and supplemented as necessary by TBCCPL's construction manager.Emergency Preparedness and Response: The 2016 ESMP includes an Emergency Response and Preparedness Plan setting out procedures and measures to be taken to deal with emergency situations including emergency escape, shutdown during emergency evacuation, accounting for all personnel after an evacuation, rescue and medical duties for employees, and other emergency reporting (e.g. fires, medical emergencies). The Company will familiarize all employees and contractors with the plan. The plan will be reviewed and amended when needed to ensure that all parties concerned are furnished with up-to-date information particularly related to snake bite risks.Monitoring, Review and Reporting: The Company's EHS Manager, together with the E&S team of EPC and O&M contractors, will monitor the E&S performance of the project, including the implementation status of the ESMP. The EHS Manager will handle regular reporting requirements to regulatory bodies such as SEPA, and to lenders including IFC. The Company has also appointed an Independent Monitoring Consultant (IMC) as per SEPA requirement.
PS 2: LABOR AND WORKING CONDITIONS
The construction activities will be parallel in three wind power plants (TBCCPL A, B & C) and it is estimated that direct manpower required during the construction phase of the project will be about 600 workers during the peak construction period. In addition, about 150 support staff will be present on site including technical, administrative and security staff. During operation, the Operation & Maintenance (O&M) contract estimates about 50 employees in operations and about 20-30 people in security (as contract workers).Working Conditions and Management of Worker Relationship: The Company has established Employee Relation Procedures and has a HR Manual in line with Pakistan Labor laws and IFC Performance Standard 2 requirements. TBCCPL will ensure that project workers engaged by the Company, EPC contractors and sub-contractors are given understandable documentation concerning their rights under Pakistan labor regulations and any applicable labor agreements, including working hours, compensation & benefits, harassment, freedom of association, workers accommodation, child and forced labor, etc.Human Resource Policy and Management: TBCCPL has instituted and is implementing several formal and documented HR policies and practices that will be applied to both direct and indirect employee, which are in adherence with the Pakistan labor laws, and have incorporated the requirements for labor transparency and equitable treatment as described and detailed in Performance Standard 2. As captured in the ESAP attached to this review summary, TBCCPL will reinforce its HR capacity by appointing a well-qualified HR manager in charge of the implementation of its HR related policy and procedures.Worker's Accommodation: A worker's accommodation camp will be built to house a portion of the peak construction workforce of around 600 persons, though the exact location and size of this camp have yet to be finalized. The Operation and Maintenance (O&M) of the plants will be carried out by GE together with local contractor Al Bario Engineering Pvt. The planned accommodation facilities will be located within the project site and far from any settlements. The size of the accommodation facilities will be designed based on the final EPC and O&M arrangements, as mentioned in the project description section above. A Workers Accommodation Management Plan has been prepared to assist the Company in managing any adverse impacts on employees during the construction phase. The framework provides key elements for the Company to manage construction labor including resource requirements, workers accommodation facilities, recommended mitigation measures, and monitoring and inspection of the workers accommodation facilities.Non-Discrimination and Equal Opportunity: TBCCPL will make employment decisions on the basis of equal opportunity and fair treatment, and in accordance with Pakistan regulations on non-discrimination.Grievance Mechanism: As per the project Stakeholder Engagement Plan, a grievance mechanism for managing both external and internal (worker) grievances has been established. A Community Liaison Officer will be appointed to receive, process and record/respond to comments and/or complaints shared by phone, post or email from external stakeholders and report to Human Resource Manager. The EPC and O&M contractors will also appoint contact persons for receiving, documenting and responding to complaints.Protecting the Work Force: The Company has already documented specific procedures encompassing TBCCPL and its EPC and O&M contractors and their sub-contractors related to prohibition of child labor, forced labor, freedom of association. The Company need to ensure that these procedures are implemented by its contractors.Occupational Health and Safety: The Company has a Health & Safety Management Plan. It has performed an Occupational Health & Safety (OHS) Risk Assessment for Construction and Operation Phase and prepared an OHS Management Plan. The Company with its EPC contractor have carried out a Job Hazard Analysis (JHA) of all construction activities for all hazards associated with work at the WTGs construction site and associated activities (Batching Plant, Excavation, Pouring, Lifting, Electrical Testing etc.). The Company has also developed a procedure for operational controls e.g. Permit to Work, Working at Height, Working at Night, Confined Space, Lifting Plan, Drinking Water Quality Plan. These procedures define TBCCPL and its EPC and O&M contractors' responsibility to manage occupational health and safety performance. It is noteworthy that the same EPC contractor worked with Sapphire Group to achieve physical completion at the Sponsor's existing wind power plant with no lost time incidents recorded.Key potential hazards addressed in the framework include chemical hazards, physical hazards, noise, vibration, biological hazards, malaria, pest and insect control, ergonomic hazards, working hours and working cycles, fitness to work, and work at height. An ambulance will be provided on site 24/7 for emergency needs. Contractor staff will be trained in the nature of the health hazards and specified controls. The Company will build its E&S capacity to monitor implementation of OHS management procedures by EPC contractor and sub-contractors and other service providers.
PS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION
Resource Efficiency:GHG Emissions: The project is estimated to generate 399,000 MWh per year, with greenhouse gas emission reductions of 226,911 tCO2 equivalent per year using a grid emission factor of 0.5687 tCO2e/MWh.Water Management: About 1 to 1.5 m3 per day of water will be required during the operational and around 200,000 tons of raw water will be required during the construction phases of the project. Considering the general scarcity of water in the region, the Company is planning to adopt water conservation measures including using recycled water as much as possible. The batching plant will require a stable good quality of raw water supply for concrete production that is to be obtained from the water supply contractor. Construction camps would also need a considerable amount of water, including potable water, for 600 workers in peak time (but for a limited duration). The Company and the EPC contractor thus need to identify a secure water supply sources for sufficient and consistent supply of water, especially during peak construction period, and develop a procedure to monitor the quality of water being supplied; a Water Management Plan as captured in the ESAP action item 6 will be developed.Resource Efficiency: Since the project involves parallel construction of TBCCPL A, B & C, instead of establishing three separate construction camps, one common facility will be established at TBCCPL wind power plant B and two satellite offices at TBCCPL A & C. Similarly a common sub-station will be used for evacuation of power from TBCCPL A, B & C. This will result in resource efficiency in terms of direct and indirect construction material usage, water consumption during construction and operation phase, and fuel consumption during construction phase. Similarly selection of GE 1.7-100 WTGs results in a lower number of WTGs i.e. 87 for the project compared to Sapphire Group previous practice of using 1.6 MW WTG (reduction in the number of WTG foundations reduces the use of resources).During the operational phase, one 250KVA diesel generator per 50MW wind farm will be installed for emergency power supply, to be operated only as back-up. Fuel will be unloaded in designated areas and stored in above ground storage tank.Pollution Prevention:Construction phase impacts: A 13-15 month construction phase for the project is envisaged comprising the construction of WTG foundations, sub-station, installation of towers and turbine facilities and all accompanying facilities. Access road construction/expansion and construction works associated with the wind turbines foundations and transformer station requires proper drainage and erosion management. All soil and land disturbed and excavated during construction will be re-contoured, replanted, and returned to its original use where possible. A concrete batching plant will be located on each wind farm site as each of the turbine foundations requires about 800 to 1000 m3 of steel reinforced concrete. Theprefabricated concrete batch plants will be provided, operated and decommissioned by the EPC contractor.Noise, Air Emissions and Ambient Air Quality: According to the 2016 ESMP a batching plant emission control plan for air emissions and liquid effluents has been developed within ESMP. Dust emissions from excavations, access roads development, vehicular movements, etc. are potential nuisance risks to the nearby community and will be addressed with adequate mitigations measure. Noise from construction, especially from batching plant operations, being a prime concern to nearby community will be avoided by careful siting of the batching plant.Waste Management: The construction phase will generate a limited amount of waste (packaging, metals, plastic etc.) which will be mostly recyclable and will be sorted and separated in appropriate leak proof containers and disposed of in designated placed by licensed waste management operators. A Waste Management Plan has been developed under the ESMP.Hazardous Materials Management: Contractors will be required to implement specific procedures to reduce waste at source, segregate waste by type, and enhance recycling. During the operational phase, one 250KVA diesel generator per 50 MW will be installed for emergency power supply, to be operated only as back-up. Fuel will be unloaded in designated areas and stored in above ground storage tank. A small quantity of oil/oily water may be generated during the maintenance of pumping stations. Hazardous goods (diesel and oil) will be stored in a covered and controlled storage area with the secondary containment and impermeable floors. Necessary approval from explosive department may need to be acquired for storage of hazardous fuel. Raw Materials and Hazardous Materials Management Plan has been developed under ESMP.Noise, shadow flicker and visual impact: The nearest noise sensitive receptors to any of the 87 turbine locations and substations are approximately 0.8 - 1 km away. As captured in the ESAP action item 7 a baseline noise assessment study before the construction phase and residual noise study during the operational phase will be performed based on the selected turbine specification. The IEE and Noise Management Plan prepared under ESMP concluded that the project will adhere to both relevant national and WBG EHS noise limits in the construction phase. As captured in the E&S Action Plan (ESAP), the project will conduct a shadow flicker study before construction phase based on WTG specification and other parameters and during the first year of operations will monitor the impact of WTG shadow flicker on any habitation identified as being potentially impacted. The project will use the criteria of a maximum of 30 hours per year for the shadow flicker impact (WBG Wind Energy EHS Guidelines) and will implement mitigation measures if this criteria is exceeded anywhere. Potential for cumulative shadow flicker impact will be addressed in the cumulative impact Assessment.Operations Phase: Operations and maintenance activities will be limited, and will include normal periodic maintenance, control/metering and site security management. Key potential operational impacts include WTG noise and visual impacts and positive impacts related to employment opportunities for the local population.
PS 4: COMMUNITY HEALTH, SAFETY AND SECURITY
Community Health and Safety: The Company's Health & Safety Management Framework sets out measures in Community Impact Management Plan to ensure community health and safety. Key measures include cordoning off the construction site from public access, implementing mitigation measures for transporting WTG parts and other materials, transmission line construction to prevent community health and safety (H&S) risks, placing information boards about public safety hazards and emergency contact information in the project area in the local language, ensuring that construction phase workers are housed in labor accommodation facilities built at least 1 km from any communities, providing H&S training to raise awareness about STDs and HIV, and maintaining worker behavior standards.Road Traffic and Safety: To ensure traffic safety in the local communities the Company will require, as defined in the Transportation Management Plan, each contractor to ensure communities are advised in advance of project progress and near term activities where transport issues have the potential to impact local communities. Special attention will be given to any local religious fairs, market days or during movements associated with village processions.Security Personnel: About 100 armed private security personnel and 100 guards will be working during the construction phase. Between 20 - 30 armed security staff will be working during the operational phase of the project mobilized by the O&M contractor. As captured in the ESAP attached to this review summary, the Company will develop a Security Management Plan as per IFC PS 4 requirements. The Company will make reasonable inquiries to ensure that those providing security are not implicated in past abuses; will train them adequately in the use of force (and firearms), and appropriate conduct toward workers and affected communities; and require them to act within applicable law. The Company will not sanction any use of force except when used for preventive and defensive purposes in proportion to the nature and extent of the threat, and will provide a grievance mechanism for affected communities to express concerns about the security arrangements and acts of security personnel (the community grievance mechanism is discussed further under Stakeholder Engagement, below).
PS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES
Protection and Conservation of Habitats: No wildlife reserves are located near the project site. Keenjhar Lake Wildlife Sanctuary, a designated Ramsar wetland and Important Bird Area, is located about 20 km from the project site, which is considered to be sufficient distance to minimize potential negative impacts on migratory birds. A seven month (September 2015-March 2016) bird monitoring study showed that 44 species were observed during the monitoring period covering winter migration and spring migration period. Out of 44 species observed, 11 are migratory birds and the remaining 33 are local residents. Maximum of 100 feet flight height was observed and mainly perching birds were observed in the project area. No endangered or threatened species were observed. The major reason for decline in bird's population and number of species visiting the Keenjhar Lake is less availability of food on land and in the land, hunting pressure, fish catching, etc.The Company established a Bird Monitoring Plan in April 2016 as prescribed by the monitoring study conducted by an ex-WWF ornithologist using the Scottish Natural Heritage Methodology, and will monitor bird movements using the vantage point and point search methodologies during construction and using the point search methodology during operations.The Company will implement the following framework with respect to minimizing operational bird fatalities: (i) all WTGs to be erected at a distance of more than 200 m from each other to reduce the risk of avian collision and to give the birds a wider corridor for the access in the project area; (ii) internal electricity lines from each WTG to the project substation will be underground thus reducing collision chances; (iii) use of flash lamps on the WTGs to prevent bird collision at night; (iv) regular checking of the vacuums or holes in the towers to reduce the risk of birds nesting in the WTGs; (v) bird mortality count by point search in the immediate vicinity to establish any link between the wind turbines and birds mortality for two years starting from the commissioning of the wind farm.As described in the attached ESAP, detailed bird and bat monitoring will be conducted to assess the exact impact of the WTGs on the birds in the project area, and to evaluate the effectiveness of the mitigation measures. The Company has appointed a bird expert to conduct bird monitoring during construction and operations as per the Birds Monitoring Plan.