Intended for Energix, European Bank for Reconstruction and Development Document type Final Date January 2016 PHASE II OF WIND FARM BANIE SUPPLEMENTARY REPORT PHASE II OF WIND FARM BANIE SUPPLEMENTARY REPORT Revision 2 Date January 28, 2016 Made by Agnieszka Rogowiec, Maciej Rozkrut, Krzysztof Kręciproch Checked by Maciej Rozkrut Approved by Maciej Rozkrut Ref PL1260 Ramboll Environ Poland Sp. z o.o. Ul. Bytomska 5a 01-612 Warsaw Poland T +48 22 833 09 36 F +48 22 833 10 87 www.ramboll-environ.com P: \PL1260 Banie Ph. II Support\aaaReport ENG 2016\word files\PL1260 Supplementary Report_PhaseII_final.docx Supplementary report CONTENTS 1. INTRODUCTION 1 2. ALTERNATIVE WIND FARM CONFIGURATIONS 2 3. IMPACT ON ARCHITECTURAL AND CULTURAL HERITAGE 3 3.1 Location 3 3.2 Monument/Object 3 3.3 Monuments Register number 3 3.4 Distance and direction to the nearest WTGs 3 3.5 Visibility assessment 3 3.6 Distance and direction to the nearest WTGs 5 3.7 Visibility assessment 5 4. ICE AND BLADE THROW RISK 7 5. CUMULATIVE EFFECT OF THE BIELICE WIND FARM 9 5.1 Cumulative Noise Impact 9 6. SHADOW FLICKER EFFECT 12 7. IMPACT ON THE NATURA 2000 AREAS 12 8. SUMMARY OF ENVIRONMENTAL IMPACTS 14 APPENDICES Appendix 1 Analysis of Shadow Flicker Effect Appendix 2 Analysis of Noise Emission Appendix 3 Ice and blade throw risk maps Appendix 4 Natura 2000 – Screening matrix PL1260 Supplementary report 1 of 15 1. INTRODUCTION Banie wind farm project of up to 192MW was originally developed as the following subprojects: a group of 13 wind turbine generators (WTGs) in the vicinity of the Sosnowo village (Banie 1A subproject), Banie commune (gmina), Gryfiński county (powiat), Zachodniopomorskie voivodeship; a group of 2 WTGs in the vicinity of the Piaseczno village (Banie 1B subproject), Banie commune, Gryfiński county, Zachodniopomorskie voivodeship; a group of 24 WTGs in the vicinity of the Tywica, Lubanowo, Baniewice and Swobnica villages (Banie 2 subproject), Banie commune, Gryfiński county, Zachodniopomorskie voivodeship; development of a group of 3 WTGs in the vicinity of Żelechowo village (Widuchowa subproject), Widuchowa commune, Gryfiński county, Zachodniopomorskie voivodeship; a group of 21 WTGs in the vicinity of Rokity, Kozielice and Siemczyn villages (Kozielice 1 subproject), Kozielice commune, Pyrzycki county, Zachodniopomorskie voivodeship; a group of 22 WTGs in the vicinity of Mielno Pyrzyckie and Trzebórz villages (Kozielice 2 subproject), Kozielice commune, Pyrzycki county, Zachodniopomorskie voivodeship; a group of 11 WTGs in the vicinity of Linie, Stare Chrapowo and Nowe Chrapowo villages (Bielice subproject), Bielice commune, Pyrzycki county, Zachodniopomorskie voivodeship. Due to the decisions taken by the Company, the Project was divided into 3 separate phases. Construction of the first Phase of 50MW has already been accomplished and this part of the Project is currently tested. Construction of the Phase II of 56 MW has been commenced in mid-January 2016 and is expected to be completed by the end of June 2016. The Phase III of up to 142MW will potentially be constructed in the future, depending on, inter alia, the electricity market conditions, renewable energy support scheme and possibility for project financing. Each of the abovementioned subprojects, apart from the WTGs, consists also of auxiliary infrastructure of access roads, assembly yards and underground steering and power transmission cabling connected to three dedicated electrical substations. The subprojects were subject to environmental impact assessment (EIA) procedures, which were conducted by competent authorities based on the relevant EIA reports prepared by independent environmental consultants and were granted appropriate environmental decisions. The EIA reports were reviewed by Ramboll Environ Poland (previously ENVIRON Poland) and assessed against requirements of the EIA directive, national environmental law and good industry practice as per IFC Environment Health and Safety Guidelines for Wind Energy. The review indicated in general satisfactory quality of the reports, however, some shortcomings were also identified. This report has been prepared in order to address the identified shortcomings of the EIA reports and assess related environmental and social risks as well as to address cumulative issues that had not been fully assessed in the individual EIA processes for each permitted wind farm. PL1260 Supplementary report 2 of 15 2. ALTERNATIVE WIND FARM CONFIGURATIONS The EIA directive1 as well as the Polish environmental legislation2, the EIA report prepared for certain developments should discuss the major reasonable alternatives studied by the developer and indicate the main reasons for selecting the chosen option. As identified by Ramboll Environ within the course of the ESDD, all EIA reports prepared for the Banie and Kozielice 1 subprojects addressed this requirement and were judged as fit for purpose by the Competent Authority. In line with best practice, Ramboll Environ recommended additional issues to be included including the need for more detailed justification of the issue. Therefore, below is provided additional comment on this issue. The EIA report for the Banie and Kozielice 1 subprojects were drawn up in 2008 and 2009 respectively, when the commune master plans and local zoning plans were already approved by the local authorities. While the master plan draws general directions for the commune development, the local zoning plans constitute acts of a local law, which have to be taken into account at the stage of development planning. For the Banie subproject the local zoning plans were approved by the Commune Council in April 2005 and for Kozielice 1 and Kozielice 2 in September 2004. Following the national regulations, namely the Spatial Planning Act of March 23, 2003, both the commune master plan and local zoning plans shall be adopted by the local authorities in line with a procedure, which among others, require public participation and a forecast of environmental impact (strategic environmental impact assessment). In the legal framework in force at the time when the local zoning plans were preceded, consideration of rationale alternative solutions was not required by the act. Therefore, the local zoning plans considered only one variant of wind farm configuration, where the WTGs were located at specific locations. It is understood that these locations were selected taking into account possible impacts on human beings and wild nature and that the process of selection was conducted twice: the first time at during establishment of the communes master plans and the second one during establishment of the local zoning plans. Therefore, although not in such a detailed way as during the EIA procedures, the locations were selected to match environmental, social and potential business needs. As the local zoning plans introduced specific locations for the WTGs the options for rationale development alternatives become limited to consideration of different technical solutions, i.e. WTGs dimensions, model and capacity, or to reduce the number of WTGs. However, in 2008 and 2009 when the EIA reports were worked out, the WTGs available on the market were characterized by a very similar technical characteristics and parameters. Therefore consideration of rational technical alternatives in fact would lead to very similar results as the variant analyzed in the EIA reports, which considered installation of 2.5 MW WTGs, i.e. of the largest capacity available those times. As the noise emission of WTGs in general rises along with an increase of a capacity it can be concluded, that the most “noisy” model of WTG available was considered, i.e. the reports analyze the worst case scenario from the acoustic point of view. Change of WTGs dimensions, i.e. hub high or rotor diameter can be also considered as variant solutions. However, selection of these parameters depends on availability of WTGs and even more on wind characteristics in the project development area. The dimensions of WTGs selected for analysis matched the best the wind conditions at the sites, planned capacity of WTGs and expected 1 Directive of the European Parliament and the Council No. 2011/92/EU on the assessment of the effects of certain public and private projects on the environment with further amendments 2 The Act on the Environmental Information Disclosure and Environment Protection, Public Participation in Environment Protection and on the Environmental Impact Assessment of October 3, 2008 with further amendments and before November 2008 the Environment Protection Act of April 27, 2001 with further amendments PL1260 Supplementary report 3 of 15 productivity of the wind farms. Any other dimensions would likely affect the predicted productivity, hence cannot be considered as rational alternatives. Conclusion Although lack of detailed analysis of rational alternatives in the EIA reports is considered a non- compliance issue, in Ramboll Environ opinion it does not affect accuracy of the completed environmental impact assessments of the Banie and Kozielice wind farms. As described above, the studied variants take into account the analyses of the highest capacity WTGs available these times, which match the wind conditions at the sites. The locations of the WTGs were established during the procedures of communes’ master plans and local zoning plans approvals and could not be changed. Therefore analysis of any other variant different by the type of WTG, its dimensions or number cannot be considered