GEORGIA ELECTRICITY TRANSMISSION NETWORK DEVELOPMENT PROJECTS
Environmental and Social Impact Assessment Non-Technical Summary – Kakheti
Prepared for: GSE
SLR Ref: 901.12.1 Version No: 1 Final – Disclosure Authorised June 2020
Georgian State Electrosystem (GSE) SLR Ref No:901.12.1 Environmental and Social Impact Assessment June 2020 Volume 1 Non-Technical Summary – Kakheti
CONTENTS
INTRODUCTION ...... 1
PROJECT DESCRIPTION ...... 3
ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT ...... 9
BIODIVERSITY ...... 10
SOCIAL ...... 12
LANDSCAPE ...... 16
NOISE ...... 18
HYDROLOGY AND GEOHAZARDS ...... 21
ENVIRONMENTAL AND SOCIAL MANAGEMENT ...... 23
STAKEHOLDER ENGAGEMENT ...... 25
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Introduction
The Georgia Transmission Network Development Project is a Georgian State Electrosystem (GSE) project to develop a number of new overhead transmission lines and substations to be constructed on the Georgian electricity network. The Project comprises five separate projects which are geographically discrete from one another. This Non-Technical Summary describes the results of the Environmental and Social Impact Assessment (ESIA) for new electricity network infrastructure in Kakheti, the details of which are outlined in Table 1.1. Figure 1 and 2 illustrates the location of the Kakheti Project.
TABLE 1.1 DESCRIPTION OF PROJECT COMPONENTS
Project Component D - Reinforcement of the transmission infrastructure in Kakheti Project Name
110/220kV transmission line from Gurjaani to Telavi, on 220kV towers Gurjaani line 110kV transmission line from Telavi to Akhmeta, on 220kV towers Akhmeta line Rehabilitation of the existing 110kV transmission line into Tsinandali Substation Tsinandali line 110kV transmission line into Mukuzani Substation Mukuzani line Rehabilitation and extension of the existing 110kV Akhmeta Substation Akhmeta Substation Rehabilitation and extension of the existing 110/220kV Telavi Substation Telavi Substation Rehabilitation of the existing 110kV Tsinandali Substation Tsinandali Substation Rehabilitation of the existing 110kV Mukuzani Substation Mukuzani Substation Rehabilitation and upgrade of the existing 110/220kV Gurjaani Substation Gurjaani Substation
The Project is being promoted by the Georgian State Electrosystem JSC (GSE) and is being funded by KfW Development Bank (KfW). The Project forms part of the GSE Ten Year Network Development Plan[1], which outlines the need for improvements to the electricity network and for new electricity connections for new energy generation projects. It has been a requirement of KfW that this Project is subject to an Environmental and Social Impact Assessment in accordance with international standards. This Project is being assessed against the EBRD Performance Requirements which are set out in the EBRD Environment and Social Policy[2] and the European Union Environmental Impact Assessment Directive. The Environmental and Social Impact Assessment involves undertaking a number of studies to identify the potential impacts of a development on environmental and social aspects in order to assess the development’s merits, the ability of KfW to support the development and whether mitigation measures can be adopted to avoid, control or minimise any potential impacts. An Environmental and Social Impact Assessment Report has been prepared and is presented in eight volumes, structured as follows: • Volume 1 – Non-Technical Summary;
______1 GSE, Ten Year Network Development Plan of Georgia 2018-2028, 2018 2 EBRD (May 2014) Environmental and Social Policy
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• Volume 2 –Project Definition; • Volume 3 – Biodiversity; • Volume 4 – Social; • Volume 5 – Physical Environment (including Landscape, Noise and Hydrology & Geology); • Volume 6 – Stakeholder Engagement Plan; • Volume 7 – Land Acquisition, Resettlement and Compensation Framework; and • Volume 8 – Environmental and Social Management Plan (ESMP).
An Environmental and Social Action Plan (ESAP) has also been prepared for the Lenders to set out the key actions and measures that GSE will implement during the different phases of the Project: from the current disclosure, through construction, and then during the operation. The ESAP is used by the Lenders to monitor GSE. English and Georgian versions were disclosed on the GSE website (http://www.gse.com.ge/home_ge) and lenders’ website (https://www.ebrd.com/home) on the 9 August 2019. Hard copies of the ESIA for each Components were made available in Georgian at Municipalities crossed by the Project on the 26 August (Component D). Hard copies in Georgian at the EBRD Office in Tbilisi. The documents were disclosed for 120 days.
Feedback forms accompanied all the disclosure documentation to enable the registering of comments and concerns on the Project. These comments have been integrated in the final ESIA report package, out of which this NTS summarised the content.
WHERE CAN I GET MORE INFORMATION?
ONLINE http://www.gse.com.ge/projects/international-projects/ENIP/Environmental-and-Social-Impact-Assessment- Report https://www.ebrd.com/work-with-us/projects/esia/power-grid-enhancement-project.html
ON-SITE GSE Head Office, 2 Baratashvili Street, Tbilisi 0105, Georgia; In the Municipality Offices in Adigeni, Akhaltsikhe, Akhmeta, Ambrolauri, Chokhatauri, Gurjaani, Kutaisi, Lentekhi, Mestia, Oni, Ozurgeti, Telavi, Tkibuli, Tsageri, Tsalenjika, Tskaltubo, Vani CONTACT DETAILS Zezva Khevedelidze Telephone +995 32 2 510 837 (ext. 461)
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Project Description
Need for Project GSE has developed a Ten Year Network Development Plan of Georgia 2018-2028[1] to identify and implement projects that will meet the need for modifications and improvements to the transmission network of Georgia for the next ten years. The specific Ten Year Network Development Plan goals for the Guria Project are to: • improve the reliability of supply in the Kakheti region and the Dusheti region; and • facilitate the connection of future hydropower projects if they come forward. Project Alternatives Alternative transmission line routes and substation locations have been considered. The purpose of considering alternatives is to ensure the selected option is the most appropriate regarding impact on the environment and local communities, whilst also considering the technical challenges and overall cost. The following sections provide a summary of the alternatives considered. Under the no‐action alternative, the Project would not be constructed, and all direct environmental and social impacts associated with the Project would be avoided. However, the Project is an integral and major part of GSE’s Ten Year Network Development Plan. If the Project was not constructed, then the following benefits would not be possible: • Transmission of the electricity from the new hydropower projects in Georgia to where it is needed; and • Improvements to the reliability of the electricity system. Therefore, a number of alternatives have been considered for the Kakheti project. A summary of these is outlined in the following table along with the reasons why they have been discounted or selected.
Transmission Lines Alternatives Considered and Substations
This line is the rehabilitation of an existing transmission line. The existing route and an alternative route were both considered. The selected route comprises the route of the Gurjaani line existing line with diversions to avoid areas of settlement and to avoid the need for resettlement. In order to avoid significant resettlement, some small sections of the alternative pass through the Gombori proposed Emerald Site. This line is the rehabilitation of an existing transmission line. The existing route has Akhmeta line been modified to avoid passing through settled areas, including the centre of Akhmeta.
The Project includes the rehabilitation and upgrade of existing substations. No Kakheti substations alternatives have been considered for any of the substation locations.
Project Component Description Gurjaani Substation The substation is located to the southwest of Gurjaani on the edge of the Tsiv-Gombori Range in a forested area. Nearest housing is approximately 380m away from the substation. While all the proposed new
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Georgian State Electrosystem (GSE) SLR Ref No:901.12.1 Environmental and Social Impact Assessment June 2020 Volume 1 Non-Technical Summary – Kakheti equipment will be located within the existing substation footprint, some land outside of this may be required during the construction phase. Gurjaani Line The existing 110kV transmission line between Gurjaani Substation and Telavi Substation (the Kalauri and Tsinandali lines) would be replaced with a 110kV/220kV transmission line to be constructed on 220kV towers (typically 50m tall). The 33.1km transmission line would also include 3.3km of underground cable to the south of Tsinandali. The Gurjaani line would connect to the Tsinandali Substation and the Mukuzani Substation via short connections referred to as the Tsinandali line and the Mukuzani line. The transmission line heads in a north north-westerly direction from Gurjaani Substation, along the lower slopes of the Tsiv-Gombori mountain range. The existing Kalauri line turns east through the densely populated areas of Zegaani and Chumlaki. The proposed Gurjaani line would continue northwards to avoid these settled areas before re-joining the route of the existing line about 6km to the northwest. The Gurjaani line will be located on the lower slopes of the mountain range to avoid populated areas and, therefore, will pass through agricultural areas, including vineyards, and some forest, although most of the line follows the existing transmission line Right of Way. A section of the Gurjaani route is located within the Gombori proposed Emerald Site. Mukuzani Substation The existing Mukuzani Substation is located to the eastern edge of Mukuzani, near to the disused railway line to Telavi. The substation is 20m x 30m in size located within the GSE landholding (60m x 60m). The nearest property to the existing substation is approximately 30m to the south. To the north and west the substation is surrounded by vineyards. To the east and south the land use is mostly poor quality and derelict land. The Mukuzani Substation would be rehabilitated requiring an extension of approximately 6m x 6m to the existing substation but this would be contained within the existing substation boundary. Tsinandali Substation The existing substation is located to the southeast of Tsinandali, adjacent to the village of Kvemo Khodasheni, on the main road to Telavi, opposite a cemetery which is located to the north. The substation is surrounded by buildings and properties to the south and an old concrete irrigation channel to the east. The existing substation is approximately 24m x 36m in size, within the larger GSE landholding which comprises some trees and vegetation and an operations and maintenance building. The Tsinandali Substation would be rehabilitated, though all new infrastructure would be located within the existing substation boundary. Telavi Substation The existing Telavi Substation is located to the east of the town centre of Telavi, within the city limits, with houses and buildings to the west, north and east. To the south of the substation there is an area of open fields, some of which are cultivated but many of which are not currently used. The existing transmission lines from Akhmeta and Gurjaani enter the substation from this side. The existing substation footprint is approximately 85m x 90m, within a fenced and partly walled enclosure. A larger footprint (180m x 190m) for the GSE regional office and buildings is located to the north and west of the operating substation. The Telavi Substation would be extended to the west to include a new 85m x 90m switchyard for the new 220kV transmission lines. This land is currently owned by GSE.
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Extension area of the Telavi substation Akhmeta Line The existing 110kV transmission line between Telavi Substation to Akhmeta Substation (the existing Ikalto line) would be replaced with a 110kV transmission line to be constructed on new 50m tall 220kV towers. The 35km Akhmeta line broadly follows the route of the existing Ikalto line for the first 18km, with the exception of where it leaves the Telavi Substation where it will be diverted to avoid passing through the city and over residential areas. Through this section, the Akhmeta line will pass through some areas of forest which are part of the Gombori proposed Emerald Site. To the east of Arashenda, the final 17km of the Akhmeta line will divert northwards from the route of the existing transmission line to follow a new route to the Akhmeta Substation. The revised route will avoid the transmission line passing through a number of villages (Sachale and Kistauri) and also the centre of Akhmeta. From Arashenda, the route passes across flat agricultural land, used in part for vineyards. Akhmeta Substation The existing Akhmeta substation is located on the north side of Akhmeta on the Akhmeta to Batsara road. The Akhmeta line will approach the substation from the east, where the land use is agriculture and the landscape is flat and open with few trees. The existing substation footprint is 40m x 70m and this is located within the larger GSE landholding (approximately 180m x 60m) which is used for some operational and maintenance buildings. The substation would be extended into the adjacent agricultural fields to construct a new switchyard for the new transmission line. The extension area would measure approximately 70m x 150m plus another small area of 40m x 70m. Project Construction This section describes how the Project will be constructed. Site Preparation and Establishment Prior to the construction of the overhead line towers and substations the following would be required: • Temporary site compounds: Contractor’s temporary site compounds would provide a location for office and welfare facilities for construction workers, and a base for the storage of construction equipment and materials; • Accommodation camps: Contractor accommodation camps may be established to provide workers not resident in the local area with somewhere to live during the construction period; • Access tracks: Access tracks would be needed so that workers, equipment and materials can reach construction site locations. Existing roads and tracks would be used but some new tracks would be needed in some areas. In some cases modifications to public highways may also be needed to enable the delivery of large items such as transformers for substations;
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• Working areas: Working areas would be established at most construction locations (e.g., working areas for towers and substations). This would include the removal of trees and vegetation and the creation of a level working area. Trees and vegetation would also be removed from the transmission line corridor (the Right of Way) to provide a safe corridor for the transmission line. Transmission Lines Overhead Transmission Lines The overhead transmission lines would be constructed as follows: • Install tower foundations: There are various methods which may be used to install the foundations. Most involve placing concrete and/or steel work into the ground into which the legs of the towers would be fixed;
Typical tower foundations • Assemble the towers: The tower components would be delivered to each location and assembled in sections. They would then be fixed to the foundations and bolted together. Once a tower is complete the insulators would be fixed to the cross arms of the tower;
Indicative 110kV towers
Tower foundations and footprint
• Attach the conductors (wires) to the towers and test the connection: This would be done in sections using ropes (known as pilot wires) threaded through a pulling machine. The new conductor is attached to one end of the pilot wire. The pilot wire is pulled through the section of towers by the pulling
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machines, which then pulls the conductor through. Once fully pulled through, the conductor is connected to fittings and insulators at each tower; and
Conductor wire pulling machine • Land restoration: Upon completion of the works, temporary construction site facilities would be removed. Any remaining working areas would have soils replaced and vegetation planting would be undertaken as necessary. Underground Cables Underground cable sections would be installed as follows: • Underground cables would be laid in trenches excavated using a backacter excavator; • Once installed, the cables are buried and there would be no visible structures above ground other than manhole covers at any cable joint bays. Overhead Line Removal The existing lines in the Kakheti project will be removed and replaced. Fittings from the conductors would be cut into manageable lengths or winched on to drums in a reverse to the process used during installation. The towers would either be dismantled by crane, with sections cut and lowered to the ground, or the towers would be cut and lowered to the ground manually. Tower foundations would generally remain in place to minimise the potential for damage to surrounding vegetation and soils. Substation and substation extensions The substation would be constructed as follows: • Construct concrete foundations: These would be required for a stable base for the construction of the electrical equipment; • Install an ‘earth mat’: To make the surrounding ground at a substation safe from electric shocks an earth mat would be installed below ground level; • Erect structures: The substation support structures, buildings, and electrical equipment would be installed; and • Land restoration: Upon completion of the works, temporary construction site facilities would be removed, soils replaced and vegetation planting would be undertaken as necessary. Project Operation Transmission Lines
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The transmission lines would be operated remotely by GSE and would require very little ongoing maintenance. However, the lines would be subject to annual inspections from either the ground or air using drone or helicopter. The inspection would identify if there are any visible faults or signs of wear. It would also indicate plant or tree growth which might risk infringing safety clearances. Maintenance of the Right of Way corridor would be undertaken using manual cutting to minimise the removal of trees and plants. Small 4-wheel drive vehicles would be used to carry out routine maintenance works. Substation The substation would be securely fenced to prevent unauthorised access. It would be lit where necessary for safety purposes, to allow for maintenance or as a result of security requirements. External lighting would not be directed towards nearby residential receptors. The substations would be permanently or temporarily manned by GSE employees. Akhaltsikhe, Telavi, Akhmeta, Gurjaani, Tsinandali, and Mukazani as existing substations would continue to be staffed by existing staff teams, however, five extra staff would be required at Telavi. Maintenance would be undertaken approximately every three years or as required. If the substations require refurbishment and/or replacement works, small teams of specialist workers would be used. Project Decommissioning The Project Components will become an integral part of the Georgian electricity transmission network. As such the lifespan of the transmission lines are anticipated to be 50 years. The lifespan of equipment within the substation would be approximately 40 years. At the end of their useful life old equipment would be removed and replaced as the Project forms an important part of the Georgian electricity transmission network. Much of the material removed would be suitable for recycling.
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Environmental and Social Impact Assessment
The Kakheti Project has been the subject of an Environmental and Social Impact Assessment which has been carried out in accordance with EBRD requirements set out in the EBRD Environment and Social Policy (2014). The assessment has also been undertaken in accordance with the European Union Directive on Environmental Impact Assessment 2014/52/EU. In addition to this Environmental and Social Impact Assessment, GSE is also undertaking an Environmental Impact Assessment (EIA) in accordance with Georgian legislation. The first part of the Environmental and Social Impact Assessment was to plan and scope the studies and discuss the plans for the project with key stakeholders. A Scoping Report was produced and meetings were held with government agencies and interested stakeholders including local municipalities and non-government organisations, such as Sabuko – society for nature conservation (www.sabuko.org). A meeting with a number of government agencies was held on 2 March 2018 and meetings were held with the municipality of Chockatauri and Ozurgeti on 23 April 2018. Further meetings with government agencies (for example, National Forestry Agency) and non-governmental organisations have been held through 2019. Following the Scoping Study, the Environmental and Social Impact Assessment carried out studies for the following: • Biodiversity effects on habitats, mammals and birds; • Social and economic impacts on people and communities; • Landscape and visual impacts; • Impacts due to noise and air quality; and • Hydrological impacts and geohazards. A key part of the Environmental and Social Impact Assessment is the development of mitigation which follows the principles of the ‘mitigation hierarchy’. The mitigation hierarchy requires that impacts should first be ‘avoided’ and where this is not possible ‘minimised’ and lastly ‘offset’ or ‘compensated.’ For this project, the design of the transmission line routes has tried to avoid environmental and social impacts wherever possible. A number of design principles were used at the start of the Project which were applied to the routing of the transmission lines. The following design principles have been used: • Avoidance of protected areas, especially Emerald sites; • Avoidance of settlements and properties, wherever possible; • Avoidance of key sensitive landscapes; • Avoidance of high value biodiversity features, such as primary forest (forest not touched by human intervention); • Avoidance of tower placement within wetlands, rivers, or areas of biodiversity value; • Keeping transmission lines to landscapes already impacted by transmission lines rather than spoiling untouched landscapes; • Minimising vegetation removal with the right of way corridor; and • Avoiding placing towers on visible prominent ridges. The Environmental and Social Impact Assessment has also considered the combined impact or cumulative impact it may have with other projects being planned but not yet built. However, for the Kakheti Project, there are no cumulative projects which have been identified that would warrant assessment as a cumulative project.
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A summary of the results of Environmental and Social Impact Assessment is outlined in the following sections of this document.
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Biodiversity
Baseline findings A biodiversity study was undertaken to establish the potential level of impact on habitats, mammals and birds. The study comprised survey work of flora, mammals and birds during the spring, summer and autumn of 2017 and 2018. Areas of biodiversity value were found along the route with part of the Gurjaani and Akhmeta lines passing through the proposed Gombori Emerald site.
The biodiversity surveys established the types of habitats present along the length of the transmission line and around the substation. The surveys identify if there is any Priority Biodiversity Features. A Priority Biodiversity Feature is described as a vulnerable feature, threatened habitat or an area defined by stakeholders or the government as being important. A Priority Biodiversity Feature can also be ‘critical’ to the functioning of the habitats, such as in highly threatened ecosystems or habitats of significant importance. Such habitats are called Critical Habitat. No critical habitats were identified within the study area for Kakheti. However, the route passes through the Gombori proposed Emerald Site and, therefore, a separate Appropriate Assessment has been undertaken in respect of this ( see Section 3.5). Priority Biodiversity Features but not associated with Critical Habitat were also identified and included: • Inland surface waters; surface running waters; • Alder Alnus, birch Betula, poplar Populus or willow Salix woodland; • Habitat supporting brown bear, wolf and lynx; • Oak and hornbeam forest; and • Birds in general rather than specific species. Habitat loss By design the transmission lines have where possible avoided forests and also kept to the existing right of way. However, some tree removal will be necessary. During construction, habitat loss will occur as a right of way is cleared for the new transmission line. This will require removal of forest, where present. Some new access tracks will also require tree removal though the route of the line has been selected to follow existing access routes to minimise tree loss. Mitigation for tree loss will comprise soil management plans, biodiversity specialists on site to supervise works and replanting of trees. To retain habitat and potentially to provide additional habitat for birds and bats, dead wood will be retained (1 trunk per 200m) along the right of way. There will be no tree felling during the bird nesting season unless strict measures are put in place to protect the birds and their nests. It is also GSE’s intention, and the requirement of KfW, that through the replanting of trees there will be no net loss of forest due to the Guria Project. GSE will work with the National Forestry Agency, using trees from their nurseries to plant trees to compensate for those trees which are cut down during construction. Once operating, there would be continued natural habitat conversion in the rights of way, which will change the habitats and opportunities for fauna and flora. This is considered to be a neutral impact. Mammals For mammals, impacts could result from construction noise and general disturbance plus the potential for road kill from moving vehicles. Pre-construction surveys will be undertaken and there will be a ban on hunting by the construction work force. Excavations will be also covered overnight and when not being worked on to
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Georgian State Electrosystem (GSE) SLR Ref No:901.12.1 Environmental and Social Impact Assessment June 2020 Volume 1 Non-Technical Summary – Kakheti prevent injury to wild animals. Most of the transmission lines are already close to settlements and disturbed areas and impacts on mammals is not predicted to be significant. Birds The project is not located within a sensitive area for birds and no significant impacts have been predicted. However, there is a potential collision risk for soaring raptors and to mitigate this bird deflectors in the area of the Alazani River on the Akhmeta line will be installed. This is to be undertaken as a conservative measure as birds may use the river to navigate to and from the Alazani Important Bird Area which is located 8km downstream at its closest point. Bird deflectors will also be installed where the transmission lines cross over watercourses greater than 5m wide. Appropriate Assessment of Impacts on Gombori proposed Emerald Site An Appropriate Assessment of the Gombori proposed Emerald Site has been undertaken. An Appropriate Assessment is a study based on a European standard approach for assessing the impact of a project on a protected area which has been defined by the Bern Convention i.e, an Emerald Site. The outcome of the study showed that due to the proximity of the proposed Emerald Site to urban areas and the high levels of disturbance that the habitats have already experienced, the habitats are not considered to be good quality examples of their type. The construction activities and Right of Way clearance will increase temporary disturbance, but in an already disturbed area. The cleared Right of Way would lose some forest but would likely gain of scrub species such as fruit and nut bearing species, which will provide foraging opportunities for birds and brown bear. Where ephemeral/ short perennial species grow, they will provide nectar for insects, and invertebrates as food for birds and bats. GSE will also implement a programme of tree planting to ensure that there is no net loss of biodiversity. The Appropriate Assessment, therefore, concluded that, with mitigation, the Kakheti project would have a likely non-significant effect on the conservation status of the qualifying features of the proposed Emerald Site.
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Social
Baseline findings A social impact assessment has been undertaken. This comprised a comprehensive desk study of available social data, such as demographics, economic activities, community infrastructure, and land tenure and uses. It also comprises a study of cultural heritage interest with data collected from the National Agency for Cultural Heritage Preservation of Georgia (NACHP). Field studies were then undertaken to collect qualitative information and available local statistics. The field studies were undertaken between May to June 2018 and included direct observations during walkovers along accessible sections of study area, semi-structured interviews with residents, and interviews with Municipal authorities. The Kakheti project crosses one region, three Municipalities, one self-governing city and 21 Communities, as listed in the table below: Region Municipality Community Kakheti Gurjaani Gurjaani city, Chumlaqi, Akhasheni, Mukuzani, Vazisubani, Shashiani, Kalauri, Vachnadziani Telavi Municipality Akura, Kvemo Khodasheni, Tsinandali, Kisikhevi, Shalauri, Vardisubani, Ruispiri, Iqalto Telavi self-governing city Akhmeta Zemo Khodasheni, Kistauri, Ozhio, Zemo Alvani, Akhmeta
The following features have been identified during the desk study and field mission: • There are 17 potentially sensitive areas (eg settlements), 11 in rural areas and 6 in urban areas; • The study area crosses 282.8 ha of agricultural land and 2.6ha of residential areas; • Vineyards are a predominant land use and require land areas greater than 1ha; • The land tenure and land rights are quite similar to the rest of the country as land management is still family-based. Generally, agricultural and residential land is privately held by families, either legally registered or considered as private through customary ownership; and • No sites of world or national interest are located in the study area for Component C2, but eighteen sites of local cultural interest have been identified within the corridor. Only one of these is classified as an immovable monument of cultural heritage by the NACHP. Most of these cultural features are cemeteries or churches. Employment and economic opportunities During construction, the main positive impacts would be the temporary employment opportunities, whether skilled, semi-skilled or as unskilled jobs, for the construction of the overhead lines and the substations. Indirectly, the provision of an income source for workers and their families would contribute to their wellbeing and enhance their quality of life. During construction, to maximise positive impacts, a local recruitment strategy and an accommodation plan will be implemented to promote the workers’ wellbeing, maximise the use of local workers, and ensure equal opportunities are provided to men and women in terms of employment. Once operating, the Project will contribute to the strengthening of the electricity transmission network in Kakheti improving the reliability of the existing network. In addition, some limited job opportunities within the new Telavi substation will benefit the local communities.
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Land Acquisition and Involuntary Resettlement During construction, the main significant negative impact identified concerns land acquisition. The Project will require restrictions on land use and also permanent and temporary land acquisitions for siting towers, building substations, and for the construction compounds, access roads and working areas to raise the towers. In total, 5 households could be potentially displaced because of Component D. It has been estimated that the permanent acquisition of land will be 6.6ha: • 0.5ha for the Gurjaani line towers; • 0.6ha for the Akhmeta line towers; • 0.04ha for the Tsinandali loop towers; • 0.07ha for the Mukuzani loop towers; • 1.33ha for the extension of Akhmeta Substation; • 0.7ha for the extension of Telavi Substation; and • 0.08ha for the extension of Mukuzani Substation. The temporary land requirements during construction phase are 9.5ha (excluding the access roads which, whilst mapped by the project, are not yet decided by the contractor). In addition, there is the potential for construction to impact vineyards through which the overhead lines will pass. Some of the displaced households and land are already located in the existing Right of Way. The Gurjaani and Akhmeta lines will follow the routes of existing overhead lines for much of their length. Therefore, most of impacts will occur during construction, with only a few new impacts created during operation, mostly located in sections where new routes will be followed. The land acquisition impacts will be defined in detail during the preparation of the Resettlement Action Plan. This will include the use of forest land for grazing. This will set out and assess individual or collective impacts on the affected communities’ livelihoods and appropriate compensation will be implemented. During operation, the permanent land use restrictions within the Rights of Ways will affect approximatively: • 193ha of land for the Gurjaani line; • 209ha of land for the Akhmeta line; • 8ha of land for the Tsinandali loop; and • 14ha of land for the Mukuzani loop. The majority of the routes of the Gurjaani and Akhmeta lines will follow existing overhead lines where Rights of Way land use restrictions already exist. Therefore, the permanent land use restrictions on new plots of land will be significantly lower than that presented above. Compensation of losses, resettlement assistance and livelihood restoration have been defined in a Land Acquisition, Resettlement and Compensation Framework which is being publicly disclosed with this document. Community Infrastructure Other project impacts will include disruption during construction to local roads from construction vehicles and large loads delivering pieces of equipment, especially for the substation and overhead line tower parts. Two abnormal loads will be required to be delivered to Gurjaani Substation and one to Telavi Substation. The delivery of the abnormal loads has the potential to temporarily disrupt the traffic.
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Construction traffic could result in deterioration of the road surfaces, increased traffic delays or temporary close roads. However, these impacts are not likely to be significant as the Project traffic will be occasional, short-term and low in numbers. It is also possible that some changes to road layout or road junctions will be needed. This will be assessed by the Contractor employed by GSE in accordance with the requirements of the Environmental and Social Management Plan and will need to comply with the EBRD guidelines and any specific requirements imposed by KfW. GSE will also ensure the contractor implements a traffic management plan to control the movement of vehicles. During operation, Project related traffic will be limited to maintenance of the Right of Way and operation of the substations and will not interact with community infrastructures. No negative impact on local traffic is expected during operation. The Mukuzani line will cross the railway, however, there is currently no regular train traffic in this area and no impact is anticipated. Telavi airfield is located 1km north of Akhmeta line. The take-off and landing runways are parallel to the transmission line routes. However, the Akhmeta and Gurjaani lines will follow the route of existing overhead lines and, therefore, these will not create any new risk and impact on aircraft safety is very unlikely. Health and Safety The main health and safety risks to the local population during the construction phase concern noise, dust, and exhaust emissions generated by vehicles or machinery where houses are in close proximity to working areas. However, this impact is not likely to be significant as the proposed works at each site would be small in scale and short-term. Community health and safety could also be impacted by the introduction of the required workforce which could result in: increased demand and competition for goods and services, leading to price rises and crowding out of local consumers; increased demands on the ecosystem and natural resources; social conflicts within and between communities; risk of increased incidence of communicable diseases; and increased rates of illegal behaviour. As with any construction site, there is also the potential for accidents. To avoid risk of accidents, access to worksites will be controlled and restricted to prevent exposure of communities to the health and safety hazards which these areas could present. Construction workers would be issued with a Code of Conduct and communities would have access to a schedule of the works and the access restrictions. Should any impacts or concerns arise the community will have access to a Grievance Mechanism which will be communicated/disclosed to the neighbouring communities. There is also a risk of electrocution from direct contact with high-voltage electricity or from contact with tools, vehicles, ladders, or other devices that can come in contact with high-voltage electricity. As a result, education and public outreach will take place to inform and remind local people about land use restrictions in the Right of Way. Furthermore, signs and barriers will be placed near the towers to prevent access by the public. The overhead transmission lines have also been designed so that the Electric and Magnetic Fields (EMF) exposure of the Project will meet the guideline values used by GSE in Georgia which are based on good international practices. As a consequence no residential property will be exposed to harmful Electric and Magnetic Fields. The number of workers employed by the Project on each construction site would be relatively small. Risks to construction workers and Project operations works could also be introduced by the project. An Occupational Health and Safety Plan will cover both construction and operation activities. During the rehabilitation of the five existing substations (Akhmeta, Telavi, Tsinandali, Mukuzani, and Gurjaani substations), asbestos may potentially be present. This would be an occupational health and safety risk if this presence is confirmed.
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Georgian State Electrosystem (GSE) SLR Ref No:901.12.1 Environmental and Social Impact Assessment June 2020 Volume 1 Non-Technical Summary – Kakheti
Cultural heritage A total of 18 cultural heritage features are located within a 500m corridor of the project, however, only four of these are located along new sections of overhead line. The presence of the transmission lines will not significantly impact these features which currently have transmission lines passing near to them.
Existing line passing over cemetery Furthermore, the Contractor will consult the neighbouring communities to confirm identification of all cultural heritage elements of local value and optimise the design. A Chance Find Procedure will be developed and will be implemented in the event of any unknown cultural heritage elements being found during construction. Wherever feasible, construction works will not prevent access to places of worship, cemeteries or graves.
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Georgian State Electrosystem (GSE) SLR Ref No:901.12.1 Environmental and Social Impact Assessment June 2020 Volume 1 Non-Technical Summary – Kakheti
Landscape
Baseline findings The Kakheti project is located within the Alazani valley and broadly follows the edge of the valley where it meets the the Tsiv-Gombori mountain range. The landscape comprises a number of urban areas passing the settlements of Gurjaani, Telavi and Akhmeta and a number of smaller settlements that are located along the main road between these main centres. The existing transmission lines that connect these towns run to the south and west of these urban centres and in places are routed through more remote landscapes on the lower slopes of the Tsiv-Gombori mountain range.
View of the existing Tsinandali line and dry river bed View of Tsiv-Gombori mountain range
The Project would replace and/or extend a number of transmission lines and substation that already form an established part of the existing landscape. Most of the substation locations are in urban areas which are less sensitive from a landscape perspective. The landscapes that are more sensitive are those associated with the more elevated and remote areas, where human influences on the landscape are less pronounced and where wide open views of the Alazani valley and the Caucuses beyond can be seen. The key visual receptors that are of high sensitivity to the Project are the residents of local settlements. These are located throughout the route. Visual change and effects are likely to be greatest for local residents that are closest to the new transmission lines where changes are being made to existing infrastructure ie, where there is going to be an increase in the height of transmission towers. Landscape Impacts The Kakheti project would replace and/or extend a number of existing transmission lines and substations that already form an established part of the existing landscape. The main transmission line from Gurjaani to Akhmeta would be increased from the current 110kV to 220kV and this would result in towers which would be approximately 20 to 30m higher that the existing towers. Occasional new tracks and temporary construction compounds will be necessary to build the project. There would also be some clearance of vegetation, but as much of the overhead lines cross an agricultural landscape the extent of vegetation loss would be limited. Since there is already transmission lines in the landscape and the majority of the landscape is subject to human intervention the change in the landscape and associated impact is, therefore, likely to be limited and not significant. There is also a short section of underground cable proposed close to Tsinandali, Kisiskhevi and Kvemo Khodasheni. Following installation, reinstatement of vegetation and soils will be undertaken to ensure that the
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Georgian State Electrosystem (GSE) SLR Ref No:901.12.1 Environmental and Social Impact Assessment June 2020 Volume 1 Non-Technical Summary – Kakheti underground cable corridor is successfully restored and integrated such that landscape (and visual) impacts would be not significant. Cable sealing end compounds at both ends of the underground cable would have the appearance of a small substation. The design of these should consider the types of materials used and the colour they are painted, including the use of non-reflective materials (including fencing). Restoration of vegetation and planting and use of surplus soils to create bunds around the facility will also help to screen the new equipment. Visual Impacts The design of the transmission lines has where possible taken routes away from settled areas. For example, the existing transmission line in Akhetma and Kistauri is being removed and routed through an area of agriculture away from visual receptors. Here the project represents a visual benefit. In other areas the transmission lines run close or on the existing route. The main 220kV line from Gurjaani to Akhmeta will pass near some settlements and the towers will be more prominent in views than the existing line. However, in most cases where there are close views these will be removed as the line is being routed further away from settlements. For the line to Tsinandali the visual impacts will not change as the transmission line follows the same route and will be the same height. The Mukuzani line will be routed away from residential receptors and the visual impacts will be less than currently experienced in the landscape. The project is also introducing a short section of underground cable near to Tsinandali to protect views from a new recreational and tourism centre which is seen as an important economic asset to the area. The changes to the substation will on the whole be confined to limited changes within existing site boundaries or extensions located away from visual receptors. However, given the proximity of changes being proposed at Telavi substation to residential areas, screening will be introduced along the western and southern boundary to reduce impacts on views.
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Georgian State Electrosystem (GSE) SLR Ref No:901.12.1 Environmental and Social Impact Assessment June 2020 Volume 1 Non-Technical Summary – Kakheti
Noise
Construction noise The control of noise during both construction and operation is achieved by implementing good practice methods and by the appropriate design of equipment being installed. Construction activities could generate noise and vibration during: • site preparation, construction of compounds, access tracks, tower and substation foundations; • traffic movements; • installation of equipment; and • restoration works. Activities would take place at locations remote from residential buildings and in areas close to residential buildings in more settled areas. Where properties are close to the construction works, mitigation to meet the guideline limits would be employed. Night-time working will be avoided and there would be no traffic movements through built-up areas during night-time hours. Traffic movements through built-up areas such as the settlements along the route will not be permitted during night-time hours: heavy vehicles would not use public roads at night between 22:00 and 06:00; and no Project vehicles will be allowed in villages between 20:00 and 08:00. For the construction of the overhead lines, construction noise at any one location will be of short duration as the crews move progressively along the route of the overhead line. All construction noise impacts would be controlled by the Contractor who would use good international practice mitigation measures in accordance with a Noise and Vibration Management Plan. As a result, no significant construction noise and vibration impacts are anticipated. Operational Noise There are two main sources of operational noise associated with electricity transmission projects: • High voltage overhead lines (i.e. 220kV and above), which can make noise during certain weather conditions, although this would only be noticeable beneath the overhead line or generally within approximately 5m. The noise from a transmission line can be described as a ‘crackle’ or a ’hum’; and • Substations, in particular transformers, switchgear and standby diesel generators. Most overhead lines are designed to operate quietly in dry weather conditions. However, during rain and just afterwards or during periods of mist or fog, noise can occur. However, when it rains some of the effect of this noise is masked by the sound of the rain itself (either directly due to raindrops falling on hard surfaces or nearby vegetation or increased vehicle noise on local wet roads). Noise can also sometimes occur during dry weather, due to a build-up of dust on the overhead line. This is infrequent and generally quieter than noise in wet conditions such that it is rarely noticed and no significant impacts are predicted. Dry noise was, therefore, not considered further in the assessment. Lower voltage transmission lines (i.e. the 110kV lines of the Project such as the Mukuzani and Tsinandali line) are considered to be ‘practically quiet’ in operation. Under certain conditions, however, there may be some low level noise from an 110kV line which would be noticeable only when standing close to the line. The level, occurrence and duration of this noise are such that it is not considered to be significant. While the proposed Akhmeta line and one of the two circuits of the Gurjaani line are proposed to operate at 110kV, these will be installed on 220kV towers and may, therefore, be operated at 220kV in the future. The operational noise from these lines operating at 220kV was, therefore, considered in the assessment.
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Georgian State Electrosystem (GSE) SLR Ref No:901.12.1 Environmental and Social Impact Assessment June 2020 Volume 1 Non-Technical Summary – Kakheti
A low level of background noise (30dB(A)) has been assumed for all residential receptors. This background level is considered representative of quiet night time levels when people are likely to be sleeping. During the daytime, background noise levels are likely to increase and the audible noise from the overhead lines would be reduced. The overhead line wet noise levels at the edge of the Right of Way (and, therefore, at the shortest distance to where housing may be located) for the Gurjaani and Akhmeta lines are below the fixed night-time noise limits3 which are to be met externally to residential buildings as required by both Georgian and international (IFC/World Bank) guidelines/limits (i.e. 45dB(A)). In addition to the fixed noise guideline, the IFC/World Bank has a more-stringent relative guideline of ‘background noise level plus 3dB(A)’. For the majority of the time, the proposed transmission line would give rise to levels well within the guideline. However, this guideline level would be exceeded by the noise in wet conditions for very short periods of time in very quiet rural areas within 200m of the overhead lines. For the majority of the time, the proposed transmission line would give rise to levels well within the guideline. Therefore, significant impacts are not anticipated. Underground cables Underground cables and cable sealing end platform towers are quiet in operation and, therefore, no significant noise impacts will occur. Substation noise With regard to substation noise, transformer noise is effectively constant and comprises a low frequency hum. Transformers generally run continuously except for occasional maintenance and faults. Transformer coolers generate broadband noise (i.e. without any dominant tones) and their operation depends on temperature and loading. Switchgear noise is generated, in the main, by the operation of circuit breakers whose noise is of short duration and very infrequent. Modern switchgear operates with a dull ‘thud’, similar to the slam of a car door. Standby diesel generators are usually run for one hour per month to prove reliability and four hours every six months for maintenance, usually during daytime periods. Continuous operation would only be expected during a rare emergency scenario, when all external power supplies to the substation had been lost. Generators are usually housed in a building or outdoor acoustic enclosure and noise from such assets, would be seldom discernible beyond the substation perimeter fence. Tsinandali and Mukuzani Substations will have no new noise sources. The detailed layout of the proposed changes to the Gurjaani, Telavi and Akhmeta substations will not be known until the detailed design stage. The Contractor would be required to design the substations to meet the Georgian limits and international guidelines with respect to night-time noise levels. This may mean the selection of low noise equipment, changes to substation layout or acoustic enclosures and screening in order to meet the required limits. As a consequence, no significant impacts will result.
______3 Noise limits can be defined in terms of an absolute fixed limit or can be set in relation to background noise levels. For example the IFC/World Bank have an absolute limit for night time noise of 45dB(A) and also a relative limit of ‘background noise level plus 3dB(A)’. The night –time noise limits are more stringent than those for during the day and are applied where a noise source operates continually.
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Georgian State Electrosystem (GSE) SLR Ref No:901.12.1 Environmental and Social Impact Assessment June 2020 Volume 1 Non-Technical Summary – Kakheti
Hydrology and Geohazards
Baseline findings The Kakheti project involves the rehabilitation of existing electricity transmission infrastructure, such as the rehabilitation of existing substations. These substations comprises mostly old equipment where there is some evidence of pollution from oil leaks. Oils in substations have historically used PCBs which is a harmful chemical in the environment. There is also likely to be asbestos presence at these substations, which will need investigating and managing. The project crosses a number of wide watercourses which whilst being wide have either very small or no regular river flow. In most cases these watercourses will only have substantial flow after long periods of rainfall or melting snowfall in the mountains. Soil Contamination Impacts Of particular note for the Kakheti project is the rehabilitation of the existing substations (Gurjaani, Mukuzani, Telavi, Akhmeta and Tsinandali). The transformers at these existing substations have ineffective bunding and have been leaking transformer oil, resulting in contaminated soils. This transformer oil could also contain PCBs (a toxic chemical that persists in the environment) at a level that could cause health risks to construction workers or the public. As part of the Environmental and Social Management Plan, the contractor will be required to evaluate these risks and examine the presence of pollution. This will include the safe removal of any contaminated soil and disposal at a licensed hazardous waste facility. GSE has confirmed that such a facility does not exist in Georgia and, therefore, the materials must be transported safely to a neighbouring country where there are facilities for PCB treatment and disposal.
Evidence of oil leaks at the Kakheti substations
In addition, asbestos is known to be present at the Kakheti substations which also presents a risk to construction workers and will require a plan for its identification, removal and disposal. Based on the protection measures being put in place, no significant adverse impacts would result. The removal of PCBs, asbestos and other contaminants, if found, would result in a beneficial outcome of the project. Land Degradation, Slope Instability and Soil Erosion impacts The construction of the access tracks, construction compounds, substations, and tower foundations required for the Project and also tree and vegetation clearance can potentially cause land degradation, slope instability, soil erosion and sedimentation impacts. The individual impacts at the sites of access tracks, construction compounds, substations, and tower foundations are expected to be localised. Erosion control and soil stability
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Georgian State Electrosystem (GSE) SLR Ref No:901.12.1 Environmental and Social Impact Assessment June 2020 Volume 1 Non-Technical Summary – Kakheti measures will be implemented in accordance with good international practice. Watercourse crossings which will be needed to provide access for the overhead line works will also be based on best practice in international construction projects. Such measures relating to the control of land degradation, slope instability, soil erosion and sedimentation have been outlined in an Environmental and Social Management Plan, which is being publicly disclosed with this document. No significant impacts are, therefore, predicted. Pollution from Accidental Spills and Leaks of Hazardous Substances Small amounts of various hazardous substances such as fuel, oil, paint or hazardous waste (e.g. used oils) will be present on worksites. If appropriate controls are not in place, accidental spills or leaks could occur and potentially pollute underlying soils and groundwater and/or runoff polluting nearby surface water. Hazardous substance handling and storage management measures would, therefore, be prepared and implemented to avoid this as part of a Site Waste Management Plan. No significant impacts are predicted due to accidental spills or leaks. Risk of damage to Project infrastructure from Geohazard Events Project infrastructure constructed on slopes subject to erosion and instability would be exposed to risk of landslip, landslide and rockfall. The construction works, and physical presence of new structures, may increase the likelihood of these events, and, if they were to occur, the transmission line or access track may be damaged. River crossings would be exposed to risk of floods, debris flow, and mud flow. The likelihood of these events would not be increased by the Project, however, if they were to occur and towers or sections of access tracks are in the affected area, these assets may be damaged. Geohazard studies and specific slope- erosion and slope-stability studies will, therefore, be undertaken to inform the detailed design of the Project. Transboundary Impacts As noted in Section 7.6.1, should any contaminated oils or soils be found to contain PCBs, these would need to be exported to a nearby country to be disposed of at a licensed hazardous waste facility as no such facility exists in Georgia. No significant transboundary impacts are anticipated as the volume of material is expected to be small and its transportation and disposal would be undertaken in accordance with good international practice and the Basel Convention on the Control of Transboundary Movements of Hazardous Waste and their Disposal.
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Georgian State Electrosystem (GSE) SLR Ref No:901.12.1 Environmental and Social Impact Assessment June 2020 Volume 1 Non-Technical Summary – Kakheti
Environmental and Social Management
An Environmental and Social Management Plan has been prepared for the Project. The purpose of the Environmental and Social Management Plan is to set out the environmental and social mitigation measures and monitoring requirements identified in the Environmental and Social Impact Assessment Report. Responsibilities GSE will take full responsibility for the environmental and social management of the construction and operation of the Project. Although GSE will take overall responsibility, GSE will delegate the implementation of the environmental and social measures to the Contractors who will construct the Project. In addition, GSE has appointed an Implementation Consultant to supervise the Contractors during the detailed design and construction phase to ensure compliance with the environmental and social obligations set out in the Environmental and Social Management Plan. The Government of Georgia and local municipalities will play a key role in supporting GSE with regard to the compensation of land and resettlement of people and their properties from within the Rights of Way of the transmission lines. Government agencies will also play a key role, for example the National Forestry Agency of Georgia will be involved with respect to the trees that will be removed to create the Rights of Way. They will be responsible for the sale of timber, working with GSE and the local municipalities for the distribution of approximately 30% of cut timber to local communities and in tree planting compensation programmes. Environmental and Social Management Plan The Environmental and Social Management Plan outlines the mitigation and compensation measures that have been identified to reduce or compensate the predicted adverse environmental and social impacts resulting from the Project. The Environmental and Social Management Plan comprises three documents: • Project-wide Environmental and Social Management Plan sets out the framework within which environmental and social management is to be performed; • Transmission Line Environmental and Social Management Plan sets out the environmental and social management obligations relating specifically to the GSE transmission lines; and • Substation Environmental and Social Management Plan sets out the environmental and social management obligations relating specifically to the GSE substations. A number of management actions are to be implemented by GSE to deliver the obligations set out in the Environmental and Social Management Plan, including: • Resettlement Action Plans will be prepared to guide the land take process and to ensure that all individuals affected by land acquisition by the Project are compensated for their land and assets, which will enable them to attain a standard of living similar to and, if possible, better than the existing one; • A Community Health & Safety Plan will be prepared and implemented to ensure that the local communities are protected during the construction works. It will set out the Contractor’s and sub- contractors’ obligations relating to protecting the health and safety of the community; • An Emergency Preparedness Plan will also be prepared by GSE with respect to the potential hazards that could face the Project; • A Stakeholder Engagement Plan has been prepared to summarise the public consultation process carried out so far and the future engagement initiatives planned during the construction and operation of the Project; and • Detailed environmental and social obligations have been included into the Contractor’s contract to ensure that construction methods meet the requirements of the Environmental and Social
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Georgian State Electrosystem (GSE) SLR Ref No:901.12.1 Environmental and Social Impact Assessment June 2020 Volume 1 Non-Technical Summary – Kakheti
Management Plan. The contract includes obligations to adhere to the performance standards of the Lenders’ environmental and social policies. Environmental Monitoring GSE will monitor the effectiveness of the proposed mitigation and the environmental and social performance of the Contractors. Monitoring will include: • Environmental and social surveillance of the construction works will be undertaken by the Implementation Consultant, who would report regularly to GSE on the environmental and social performance of the Contractors; • Once constructed the transmission lines and substations will be monitored to ensure that they comply with international standards on noise; • Habitat reinstatement and tree planting monitoring is needed to ensure that planting to reinstate areas after the construction of the Project is successful. • Community Health and Safety monitoring will be an ongoing requirement to ensure that local communities are safe where there are activities close to live electrical equipment. This would ensure that fencing and signs warning people of the dangers of electricity are maintained.
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Georgian State Electrosystem (GSE) SLR Ref No:901.12.1 Environmental and Social Impact Assessment June 2020 Volume 1 Non-Technical Summary – Kakheti
Stakeholder Engagement
Overview of Stakeholder Engagement Stakeholder engagement is a key element of the Environmental and Social Impact Assessment process as defined by the requirements of the KfW and Georgian legislation. The purpose of stakeholder engagement is to enable stakeholders, including government agencies, municipalities and locally affected people and communities to engage with the decision making process, express their views and influence mitigation and technical solutions. A Stakeholder Engagement Plan has been developed to describe the stakeholder engagement activities completed to-date and to outline the management and planning responsibilities of activities during the remaining development, construction and operational phases of the Project. It also sets out the proposed information disclosure process, and details the future meetings and consultations with Project Affected People and interested stakeholders. The Stakeholder Engagement Plan includes a grievance mechanism so that stakeholders and the public can raise any concerns, provide feedback and comments about the Project, and are informed how those complaints/comments will be handled. Link to the website grievance mechanism: www.gse.com.ge Grievance mechanism telephone number -+995 32 2 510 837 Stakeholder Engagement undertaken so far Since the early stages of the Project, GSE has consulted people and organisations to ensure balanced decisions are made based on all the information and feedback available. There have been two main stages of consultation/engagement to-date: • Scoping Consultation via: o Scoping Meetings and correspondence with the relevant government agencies; o Scoping Meetings with the municipalities through which the Project will pass; and o Submission of a Scoping Report to the municipalities within which the Project is located, relevant government agencies, the Lenders; and the public via the GSE website. • Baseline Information Consultation: o Environment and social topic specific meetings and one to one meetings with a range of stakeholders across the environmental topics, to inform a more detailed assessment and identification of appropriate measures to mitigate the effects of the proposals. • Disclosure of the draft ESIA report: o English and Georgian versions of the 8 volumes of the draft ESIA report were disclosed on the GSE website (http://www.gse.com.ge/home_ge) on the 9th of August 2019. o Hard copies of the ESIA for the Components to be financed by EBRD were disclosed the 9th of August at the EBRD Office in Tbilisi and in at the local government office for all the Municipalities crossed by Component C1 and part of C2. o Hard copies of the ESIA were disclosed on 26th of August at the local government office of all the Municipalities crossed by Components A, B, part of C2 and D. o At the time of each of the disclosure, the Non-Technical Summary was sent in hard copy to the potentially impacted Communities. o Feedback forms were made available at all disclosure steps to enable the registering of comments and concerns on the Project.
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