PJSC “Ukrhydroenergo” (UHE) Performance improvement Project “Improving Power System Resilience for European Power Grid Integration” ENERGY SECURITY PROJECT (ESP) Environmental and Social Management Plan (ESMP)
ACRONYMS BMS Battery management system BoS Balance of system CAPEX Capital expenditures CH Critical habitat CMU Cabinet Ministers of Ukraine CSR Corporate social responsibility EES Battery energy storage system EHS Environmental, health and safety EMS Energy management system ENTSO-E European Network of Transmission System Operators for Electricity ESA Environmental and Social Assessment EIA Environmental Impact Assessment EPC Engineering, Procurement and Construction ESF Environmental and Social Framework ESIA Environmental and Social Impact Assessment ESMP Environmental and Social Management Plan ESS Environmental and Social Standards EU European Union EVA Ethylene Vinyl Acetate FCR Frequency Containment Reserve (a/m)FRR (automatic/manual) Frequency Restoration Reserve GDP Gross Domestic Product GIIP Good International Industry Practice GRM Grievance Redress Mechanism H&S Health and Safety HDG Hot-dip galvanized HPP Hydropower generation plant HV High Voltage IA Implementing Agency IBA Important Bird Area IFC International Finance Corporation ILO International Labour Organization IEC International electrotechnical commission IPS Integrated Power System of Ukraine IRENA International renewable energy agency IRR Internal rate of return IUCN International Union for Conservation of Nature KBA Key Biodiversity Area LMP Labour Management Procedures MW Megawatt MWh Megawatt hour MWp Megawatt-peak NEURC National Commission for State Regulation of Energy and Public Utility Services PAP Project Affected Person PPE Personal Protective Equipment PSP [Hydropower] Pump Storage Plant PFS Pre-feasibility Study PV Photovoltaic PVC Polyvinyl Chloride O&M Operation and maintenance OHS Occupational Health and Safety OVD Ukraine EIA RE Renewable energy
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SEP Stakeholder Engagement Plan SESA Strategic Environmental and Social Assessment SMS Storage management system TSO Transmission System Operator UHE PJSC “Ukrhydroenergo” UE National Power Company (NPC) UkrEnergo, PrJSC USAID United States Agency for International Development USD United Stated Dollar VDC Voltage direct current VAC Voltage alternating current WB The World Bank WBG World Bank Group Wp Watt-peak
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TABLE OF CONTENTS ACRONYMS 1 EXECUTIVE SUMMARY 5 BACKGROUND 5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN 6 PROJECT LOCATION AND DESCRIPTION 6 POTENTIAL KEY IMPACTS 6 CONCLUSIONS AND RECOMMENDATIONS 7 INTRODUCTION 8 PROJECT DESCRIPTION 8 PROJECT GOALS AND OBJECTIVES 9 THE PROJECT GOALS AND OBJECTIVES INCLUDE THE FOLLOWING: 9 ASSOCIATED FACILITIES 9 ENVIRONMENTAL AND SOCIAL FRAMEWORK 9 ESMP METHODOLOGY 11 PROJECT TECHNOLOGY AND CONFIGURATION 12 PROJECT TECHNOLOGY 12 PROJECT CONFIGURATION 14 LOCATION CONSIDERATIONS 16 PEST CONTROL 18 SITE LOCATION AND LAYOUTS 18 ENVIRONMENTAL AND SOCIAL IMPACTS AND MITIGATION 25 PREAMBLE 25 ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS (ESS1) 25 LABOUR AND WORKING CONDITIONS (ESS2) 26 RESOURCE EFFICIENCE AND POLLUTION PREVENTION AND MANAGEMENT (ESS3) 35 COMMUNITY HEALTH AND SAFETY (ESS4) 46 BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES (ESS6) 53 CULTURAL HERITAGE (ESS8) 62 STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE (ESS10) 65 MONITORING AND REPORTING 66 INCIDENT RESPONSE 74 IMPLEMENTATION, CAPACITY DEVELOPMENT AND TRAINING 76 BID AND CONTRACT DOCUMENTS 76 ESMP IMPLEMENTATION RESPONSIBILITIES 76 IMPLEMENTATION SCHEDULE 79 CAPACITY DEVELOPMENT AND TRAINING 80 GRIEVANCE MECHANISM 82 DEFINITIONS OF THE GRM 82 GRM SCOPE AND USE 82 GRM OVERVIEW AND STRUCTURE, COMMUNICATION AND PROCESS 82 ANONYMOUS COMPLIANTS 83 CONFIDENTIALITY AND CONFLICT OF INTEREST 83 RECEIPT AND RECORDING OF COMPLAINTS 83
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INVESTIGATION 83 RESPONSE TO COMPLAINANT 84 REPORTING 84 FURTHER ACTIONS 84 WORLD BANK GRIEVANCE REDRESS SYSTEM 85 APPENDIX A - IMPACT ASSESSMENT METHODOLOGY 86 APPENDIX B - CORRESPONDANCE 93 APPENDIX C - POLICY, LEGAL AND REGULATORY FRAMEWORK94 APPENDIX D – COVID-19 GUIDELINES FOR EPC CONTRACTOR 109 APPENDIX E – ENVIRONMENTAL AND SOCIAL INCIDENT RESPONSE 117 APPENDIX F – CRITICAL HABITAT ASSESSMENT 125
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EXECUTIVE SUMMARY
BACKGROUND PJSC “Ukrhydroenergo’s (UHE’s) operations are critical for providing balancing power in the Integrated Power System of Ukraine (IPS). UHE has significant hydropower and pumped storage resources that are used to provide load-supply balance at short notice, due to the large reliance on inflexible nuclear power generation. Despite UHE’s balancing role being complemented by less maneuverable thermal power generation, Ukraine’s IPS continues to rely on the Russian power system for needed flexibility, especially for rapid response requirements. Further, due to the penetration of large volumes of renewable energy the need for rapid response is made even more acute.
The Project will support the integration of the IPS to the European Network of Transmission System Operators for Electricity (ENTSO-E), which requires significant increase in the flexibility of the system, both during its isolated operation prior to full synchronization, when Ukraine disconnects from the Russian grid, as well as for post-synchronization operations, when Ukraine is finally connected to and becomes a part of the European grid.
To help address the issues and challenges identified above the project “Improving Power Sector Resilience and Competitiveness in Preparation for Integration with the European Power Grid” (hereinafter – the “Project”) will add utility-scale battery storage facilities (hereinafter – the “batteries”) at three proposed hydropower generation plants (HPPs) and one hydropower pump storage plant (PSP) of UHE. At each of the selected sites, the batteries will be integrated with the HPP/PSP units thus forming hybrid units, the operation of which will be managed by an advanced energy management system (EMS). Limited solar photovoltaic (PV) generation facilities will be added at each site for building resilience. As a result the Project will extend the range of ancillary services - Frequency Containment Reserve (FCR), Frequency Restoration Reserve (FRR), reactive power/voltage regulation, “black start”, etc. - that UHE provides on the Ukrainian wholesale electricity market and improve their quality (including faster response and ramp-up rate). It will also help to extend the lifetime of HPP/PSP turbines and decrease repair and maintenance costs by reducing the stress on power generation equipment in the process of start-up and in the conditions of highly volatile operation.
A significant environmental benefit of the Project is increasing maneuverability of hydropower generation through the compatibility with storage batteries to address system flexibility needs resulting from renewable energy penetration and thereby mitigating the negative effect of “green-coal paradox”, a situation where increasing renewable energy power output needs to be balanced by the outdated and worn-out coal-fired power generation with high minimal loads, leading to higher air emissions which have impacts in terms of climate change and to human health.
Each of the hydropower plants proposed for the installation of battery storage facility and solar PV arrays includes a different storage system composition and different solar arrays , determined by the size and number of the hydropower plant units and the consumption of the plant auxiliaries. The four proposed plants are:
• Kyiv PSP (46 MW storage facility and 10.6 MW Photovoltaic (PV) plant); • Kaniv HPP (3 x 22 MW storage facility and 13.5 MW PV plant); • Kremenchuck HPP (60 MW storage facility and 6.5 MW PV plant); and • Seredniodniprovska HPP (25 MW storage facility and 5.3 MW PV plant).
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Thus, the total capacity of the installed battery storage facilities is 197 MW and the total capacity of the solar PV arrays is 35.9 MW.
A social responsibility sub-project (CSR project) at Dnistrovska HPP includes 15 MW 6six-hour Zinc Air Battery and 28 MW PV plant). The battery storage facility will be partially charged by the PV plant and will be used to provide electricity for electric vehicles (EVs at a special low rate1 thus supporting a decrease in vehicle emissions. The rationale for choosing this site for the CSR component is due to it having adequate interconnection capacity and population close enough for power distribution with minimum losses. The CSR component does not include the construction of charging points and will not result in any increase the volumes of traffic on the streets, its aim is to simply provide low cost renewable electricity for electric vehicles.
ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN As part of the Projects compliance with the World Banks Environmental and Social Framework (ESF, 2018), an Environmental and Social Management Plan (ESMP) has been prepared to detail: a) The measures to be taken during the implementation and operation of a project to eliminate or offset adverse environmental and social impacts, or to reduce them to acceptable levels; and b) The actions needed to implement these measures.
PROJECT LOCATION AND DESCRIPTION All sites are within the boundaries of the lands assigned for UHE use along the dam/reservoirs, and do not encroach on grown forests, main customary walkways, customary recreation areas, waterfront accesses, sidewalks, roads, power lines or other infrastructure.
The Project will make use of fully mature and well-developed technologies, widely available at competitive prices in the world’s markets. It has the potential to attract key suppliers in the energy storage sector, resulting in optimization of both the engineerin design and capital expenditure (capex) costs.
The key components of the Project include:
• Containerized Battery Storage facility (either lithium-ion or zinc-air type) • Solar PV arrays (Crystalline technology sourced from a tier one manufacturer)
The connection of the battery storage facilities and PV generators will be performed at the HPP /PSP sites’ existing substations at generator voltage level or at high voltage level using step up transformers. Construction of new overhead transmission lines is not required.
POTENTIAL KEY IMPACTS Based on the current understanding of the sub-project activities, nearly all identified potential environmental and social risks and impacts are predictable, expected to be temporary and reversible and mitigation and management measures can be readily applied to the Project to ensure that there are no highly significant residual impacts during the Project lifecycle.
1 The discount rate over the standard tariff will be determined at feasibility stage and intended to maximize the social benefits.
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Several impacts and issues were identified that were considered to be ‘significant’ even after application of the proposed mitigation and management measures, they include:
• Occupational Health and Safety • Construction Noise • Local Community Aesthetics
However, the residual impact significance for all three of these items was still rated as ‘low’.
A Critical Habitat Assessment (CHA) for the Project identified 49 rare or sensitive species that could be present in or close to the five project sites. Further research confirmed one species, the Steppe Plump Bush Cricket triggers critical habitat, albeit on a precautionary basis. The species is endangered and restricted to just four small global ranges, one of which includes the Kaniv site. While there is no recent or reliable data to confirm its presence at Kaniv, it’s range is very restricted and the site supports the broad habitat types it requires. It is therefore assumed to be present. There are no other critical habitat triggers.
CONCLUSIONS AND RECOMMENDATIONS Mitigation measures have been prepared and included in this ESMP for all of the identified impacts. Many of the mitigation measures are based on good international industry practice (GIIP). They include for example measures to manage and monitor waste, correct storage of hazardous liquids and controlling access to site.
This ESMP also includes specific requirements for implementation of the mitigation measures through bid documents, contracts documents, UHE PMU, the EPC Contractor and the Supervision Consultant. Monitoring responsibilities are also included in the ESMP along with monitoring indicators with which to measure environmental and social performance against. COVID-19 procedures have been provided for implementation during the Project along with a protocol for management and reporting of environmental incidents.
The CHA did identify one species triggering critical habitat. Recent and reliable data is required to confidently confirm its regular presence in the AoI. Further surveys are therefore recommended, ideally during the design phase. If it is confirmed to regularly occur measures to ensure no net loss and preferably achieve a net gain in its nature conservation status will be required. Such measures could be achieved via a Biodiversity Management Plan (BMP) for this species or by avoiding species habitat alotogether, i.e. by altering the location of the infrastructure at site. However, if confirmed absent no further measures are likely necessary. Recommendations in any BMP would likely require offsets in the form of creating / restoring similar habitat in nearby areas so that the total habitat available for the species is increased (~2x the areas removed/modified) or measurably enhanced. All species within the areas potentially affected can then be safely translocated to the areas of suitable habitat, and suitable monitoring plans should be put in place to establish the success of habitat creation and relocation.
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INTRODUCTION
PROJECT DESCRIPTION The Project will add utility scale battery storage at four of UHE’s hydropower plants. The batteries will be integrated with the hydropower plant units thus forming hybrid units the operation of which will be managed by advanced energy management systems (EMS). Limited solar generation will be added at each site for building resilience. As a result the project will extend the range of ancillary services (frequency containment reserve, frequency restoration reserve, reactive power/voltage regulation, black start, etc.) that UHE provides on the Ukrainian wholesale electricity market and improve their quality (including faster response and ramp-up rate). It will also extend the life of UHE turbines and decrease the maintenance costs by reducing the stress on the equipment in the process of start-up.
The project will support the integration of the Ukrainian grid with the European power system (ENTSO-E), which requires significant increase in the flexibility of the system, both for isolated grid operation prior to full synchronization, as well as for post-synchronization operations when Ukraine disconnects from the Russian grid and becomes a part of the European grid. With the introduction of large volumes of renewables the need for frequency containment and restoration reserves is made even more acute.
Each of the hydropower plants selected for the installation of battery storage and solar arrays includes a different storage system composition and different solar arrays , determined by the size and number of the hydropower plant units and the consumption of the plant auxiliaries,. The four plants are:
• Kyiv PSP (46 MW storage and 10.6 MW Photovoltaic (PV) plant); • Kaniv HPP (3 x 22 MW storage and 13.5 MW PV plant); • Kremenchuck HPP (60 MW storage and 6.5 MW PV plant); and • Seredniodniprovska HPP (25 MW storage and 5.3 MW PV plant).
Thus, the total capacity of the installed battery storage is 197 MW and the total capacity of the solar arrays is 35.9 MW.
The project will also promote the use of electric vehicles for public transportation providing cost effective charging sources by adding long duration battery storage with greater energy storage capacity at a fifth hydropower plant which needs to store some of the energy in generated in normal operating conditions. This social responsibility sub-project (CSR project) at Dnistrovska HPP includes 15 MW 6six-hour Zinc Air Battery and 28 MW PV plant). The battery storage will be partially charged by the PV plant and will be used to provide electricity for electric vehicles (EVs) at a special low rate2 thus supporting a decrease in vehicle emissions. The rationale for choosing this site for the CSR component is due to it having adequate interconnection capacity and population close enough for power distribution with minimum losses. The CSR component does not include the construction of charging points and will not result in any increase the volumes of traffic on the streets, its aim is to simply provide low cost renewable electicity for electric vehicles.
The connection of the battery storage and PV generators will be performed at the HPP /PSP sites’ existing substations at generator voltage level or at high voltage level using step up transformers. Construction of new overhead transmission lines is not required.
2 The discount rate over the standard tariff will be determined at feasibility stage and intended to maximize the social benefits.
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PROJECT GOALS AND OBJECTIVES
The project goals and objectives include the following: • Support ENTSO-E integration – in order to meet the EU's reserve capacity requirements for synchronization with ENTSO-E Ukraine will need around 200 MW of Frequency Containment Reserve (FCR) as indicated in RTE Study. • Support RES integration – the integration of the increased amount of RES being connected to the Ukrainian power grid requires additional power system flexibility (including FCR, aFRR and mFRR) as identified in the UE generation adequacy report approved by NEURC • Increase power system reliability – the Project creates the most reliable source of system flexibility as it is not contingent on the availability of resources (water, coal, gas) and the working status (in/out of operation) of the provider • Facilitate development and proper functioning of Ukraine’s ancillary services market as an integral segment of a newly established wholesale electricity market in compliance with EU energy acquis • Support Ukraine’s National Emission Reduction Plan 2033 - the Project creates an emission-free source of system flexibility • Support Ukraine's 2050 Green Energy Transition Concept (Ukraine's Green Deal) – the Project charts the way for “greening” the IPS of Ukraine as the optimal technological solution using “green” hydropower to mitigate the “green-coal paradox” that results from “green” RE generation
The additional Project benefits include the following: • Extend the range of ancillary services (FCR, FRR, reactive power/voltage regulation, “black start”, etc.) that UHE provides on the Ukrainian wholesale electricity market and improve their quality (including faster response and ramp-up rate). • Extend the lifetime of UHE turbines and decrease the repair and maintenance costs by reducing the stress on the equipment in the process of start-up and in the conditions of highly volatile operation. • Improve the revenue steam of UHE by generating additional revenues from sales on the ancillary services market. • Promote the use of electric vehicles for public transportation providing cost effective charging sources
ASSOCIATED FACILITIES WB ESF notes that “Associated Facilities” means facilities or activities that are not funded as part of the project and, in the judgment of the Bank, are: (a) directly and significantly related to the project; and (b) carried out, or planned to be carried out, contemporaneously with the project; and (c) necessary for the project to be viable and would not have been constructed, expanded or conducted if the project did not exist. For facilities or activities to be Associated Facilities, they must meet all three criteria. The Project meets the first two criteria, but not the last criteria as both the HPPs and the Project components (solar and battery) can operate independently from one another, although not at the optimum efficiency anticipated under this Project.
ENVIRONMENTAL AND SOCIAL FRAMEWORK
ENVIRONMENTAL AND SOCIAL ASSESSMENT According to the World Bank Environmental and Social Framework (2018), “The Borrower will undertake an environmental and social assessment to assess the environmental and social risks and impacts of a project throughout the project life cycle. The term ‘environmental and social assessment’ (ESA) is a generic term that describes the process of analysis and planning used by the Borrower to ensure the environmental
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and social impacts and risks of a project are identified, avoided, minimized, reduced or mitigated.” Various tools can be used during ESA, including Environmental and Social Management Plan (ESMP).
An Environmental and Social Management Plan (ESMP) for the Project has been requested by the World Bank. ESMP consists of a set of mitigation, monitoring, and institutional measures to be taken during implementation and operation of a project to eliminate adverse environmental and social risks and impacts, offset them, or reduce them to acceptable levels. The ESMP also includes the measures and actions needed to implement these measures.
This ESMP therefore will:
• Identify the set of responses to potentially adverse impacts; • Determine requirements for ensuring that those responses are made effectively and in a timely manner; and • Describe the means for meeting those requirements.
WORLD BANKS ENVIRONMENTAL AND SOCIAL FRAMEWORK The ESF includes the Sustainable Development Concept, which reflects the Bank's commitment to achieving environmental and social sustainability, and implies the compliance of investment projects financed by the Bank with the ten World Bank Environmental and Social Standards (WBESSs): ESS1 - ESS10. The WBESSs are designed to help UHE to manage the risks and impacts of a project, and improve their environmental and social performance, through a risk and outcomes-based approach. The desired outcomes for the project are described in the objectives of each ESS, followed by specific requirements to help Borrowers achieve these objectives through means that are appropriate to the nature and scale of the project and proportionate to the level of environmental and social risks and impacts. The Project activities that will be financed by the World Bank are required to meet ESSs of the World Bank ESF. The relevance of each of the standards are summarized below.
Table 1: Summary Table of ESS Applicability
ESS Applicability ESS 1 - Assessment and Management of Environmental and Social Yes Risks and Impacts
ESS 2 – Labor and Working Conditions Yes
ESS 3 – Recourse Efficiency, Pollution Prevention and Yes Management
ESS 4 – Community Health and Safety Yes
ESS 5 – Land Acquisition, Restrictions on Land Use, and No Involuntary Resettlement
ESS 6 – Biodiversity Conservation and Sustainable Management of Yes Living Natural Resources
ESS 7- Indigenous Peoples/Sub-Saharan African Historically No Underserved Traditional Local Communities.
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ESS Applicability ESS 8 – Cultural Heritage Yes
ESS 9 – Financial Intermediaries No
ESS 10 – Stakeholder Engagement and Information Yes Disclosure
ESMP LAYOUT In line with the requirements of the ESF (2018), this ESMP includes the following sections:
• Project Technology and Configuration – A description of the project technology, its layout and locations. • Environmental and Social Impacts and Mitigation – Summary of all of the potential key environmental and social impacts based on the World Banks ESS and an outline of the reqiuired mitigation measures. • Monitoring – Provides the recommended monitoring measures for the Project. • Implementation, Capacity Development and Training - Outlines its specific implementation requirements through all phases of the Project, from bid documentation through to operation. Requirements for any capacity building and training to implement the requirements are also outlined.
ESMP METHODOLOGY During preparation of the ESMP the following research methods were applied: desk review of the available national regulatory and legal documents related for the environmental and social assessment; review of secondary socio-economic statistical data and meetings with UHE staff.
Tetra Tech (the consultant preparing this ESMP) also conducted field visits to all potential sub-project sites and were assisted by UHE, to identify potential environmental and social risks and impacts of the proposed Project in order to draft the ESMP. A Critical Habitat Screening exercise has also been undertaken to determine the presence of critical habitat within the Project area.
The impact assessment methodology is provided as Appendix A. The Project ‘standards’ and relevant laws and regulations are Provided in Appendix C.
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PROJECT TECHNOLOGY AND CONFIGURATION
PROJECT TECHNOLOGY The project will make use of fully mature and well-developed technologies, widely available at competitive prices in the world’s markets. It has the potential to attract key suppliers in the energy storage sector, resulting in optimization of both the engineering design and capital expenditure (capex) costs. The main technology is described below.
BATTERY STORAGE Based on the specific application and the associated business model lithium-ion batteries have been selected for the four sites of hybrid operation of storage and hydropower plant units and zinc-air batteries for the social responsibility sub-project (CSR project) at Dnistrovska HPP. The proposed technologies are widely available in standard 40 feet (12.2m) containers ready-to-operate, with an average capacity of 1 MW.
The containerized solution may be supplied complete and operational from the factory, including all necessary inverters, climate and fire control, EMS (energy management system), BMS (battery management system) and communication interface with remote management systems, greatly reducing costs, complexity of installation and commissioning time, while standardizing the replacement time and procedures once the 10,000 cycles standard warranty has expired.
Lithium-ion batteries
The lithium-ion (Li-ion) batteries have become the most widely used battery technology for grid-scale energy storage used for providing frequency containment and frequency restoration reserve. They offer better efficiency then most of the other technologies. However, it must be noted that the discharge rate and the duty cycle play a significant role in determining actual efficiency. For example, a lithium-based ESS rated for two hours at rated power will have an AC round-trip efficiency of 75 to 85%, while, a system rated for 30 minutes may have an efficiency in the 65 to 75% range. Over time, lithium batteries degrade, and a replenishment, replacement, and disposal strategy is necessary when designing a system for a 20-year operating life. Within the lithium family there are a variety of different chemistries and designs from numerous suppliers, offering competitive cost, and good energy density, as well as cycle life.
Li-ion batteries are highly configurable into a variety of battery racks to create a wide range of power ratings and/or energy increments.
Zinc-air batteries
Zinc-air batteries will be used for the long-duration storage of energy. They are among the most cost competitive technology for this purpose. Moreover, forecasts show that their costs have further to fall compared to other emerging battery technology solutions. However, zinc-air batteries require slightly more costly power-converter systems compared to lithium-ion solutions. Zinc-air batteries have a 20-year design life; however, the design must account for degradation (as capacity may fade). The overall efficiency of zinc-hybrid batteries is typically lower than that of lithium-ion batteries, averaging 65 to 70%.
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Figure 1: Example of ESS Unit Layout
Source: Primus Power
PV ARRAYS Two technologies were considered that are commercially mass/produced, and can be classified into two groups, with two subgroups in each:
• Crystalline.
− Monocrystalline.
− Polycrystalline.
• Thin film.
− CdTe (Cadmium-Telluride).
− Amorphous.
The key differences between them are the result of the manufacturing method which determines the power density per surface (efficiency). CdTe technology has a clear advantage over crystalline when projects are located in hot climates, with average yearly temperature exceeding 250 C. However, it requires more area due to its lower efficiency. Superior output at high temperature usually cannot compensate for low efficiency and increased BoS (Balance of Systems) components (due to low current).
Therefore, for this project crystalline technology is proposed sourced from a tier one manufacturer.
Crystalline technology options
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Monocrystalline is the oldest and most developed technology. Monocrystalline panels are created from a single continuous crystal structure.
Polycrystalline technology cells were previously thought to be inferior to monocrystalline because of the lower efficiency of the panels. However, in 2019 a multi-crystalline cell with efficiency of 20% is not uncommon. As a result, in the current market most large manufacturers offer the same panel capacity with the same power density or efficiency in both technology variations and in both cell configurations with 60 and 72 cells. The size of the panels from both variations have also been standardized, being both widely available in the today’s standard 0.9 by 1.9 meters format, also known as the ‘1x2’.
Power: Measured in watt peak (Wp) and also standardized across configurations and manufacturers, there are many options to choose from in the standard 1x2 form, from the lowest density of 280 Wp to the highest exceeding 500 Wp. Both are widely available.
Assembly: The traditional panel is composed of a front glass, the encapsulated cells, a backing of EVA or PVC foil and an aluminum frame which provides structural integrity to the assembly, which is held together with the glass by special silicon and the frame’s rivets. This traditional assembly has significant disadvantages: for one, the frame protrudes over the glass a few millimeters along the perimeter, creating a “lip” which favors the buildup of dirt along the lower edge of the panel, which, if not properly cleaned, will create a shadow over the lower edge of the lower row of cells, reducing the overall output at first and then creating a hot spot that will accelerate the degradation of the panel. These issues led to the development of a next generation assembly system “glass-glass”, in which the panel has no frame and no backing and the cells are encapsulated directly between two sheets of photovoltaic grade glass.
DC Voltage system: The traditional DC voltage of the systems has been 1,000 Voltage Direct Current (VDC), for which the majority of the cables, terminations, protections and inverters are designed, but in the recent years an increased number of 1,500 VDC components, namely panels and inverters are becoming more available. The key driver is the reduction in BoS costs, by reducing the number of panels, cables, terminations, protections, inverters and labor required for each Wp of installed capacity.
Despite this surge of panels and inverters in 1,500 VDC configuration, the remaining components are not so widely available and may not be considered viable at this moment.
For this project, the use of a 1,000 VDC system, including panels, cables, protections and inverters, is recommended.
PROJECT CONFIGURATION The identified project sites and the estimated capacity of the plants that can be erected on each site are presented in the table below.
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Table 2: Project Sites
SITE SOLAR SOLAR LITHIUM- LITHIUM- ZINC-AIR ZINC-AIR ARRAYS MWH ION ION BATTERIES BATTERIES MWP YEAR BATTERIES BATTERIES MW MWH DAY MW MWH DAY Kyiv PSP 10.6 12,584 46 110.4 - - Kaniv HPP 13.5 16,142 66 158.4 - - Kremenchuk HPP 6.5 7,772 60 144.0 - - Seredniodniprovska 5.3 6,790 25 60.0 - - HPP Total business 35.9 43,288 197 472.8 project Dnistrovska HPP 28.0 35,872 - - 15.0 36.0 Total 63.9 79,160 197 472.8 15.0 36.0
SOLAR PLANT The proposed architecture of the solar plant is presented in the figure below.
Figure 2. PV Plant architecture
Given the particular characteristics and topography of the installation sites, where a combination of soils and installation conditions have to be simultaneously dealt with in order to avoid any interference or damage to the ancillary infrastructures of the HPP facilities, fixed mounting structure options are considered. The option of trackers, inclusive of single axis, are not recommended because the layout of the land available at all sites, which being very narrow and long towards the optimal azimuth, prevents the adequate installation and optimized operation of any kind of tracking system, resulting in a relevant cost and land usage increase not justifiable by the little generation increase due to the non- optimal layout.
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Before any groundworks and final design of the mounting systems a detailed geotechnical and topographic study has to be performed in coordination with UHE to map and mark all underground infrastructures, pipes and other fixtures that are located within the areas assigned to the solar arrays. A detailed load and structural load transfer calculation has to be made before any mounting design is considered final. Given the combination of soil and ground conditions at all sites, where the rows will be cross-sitting in both the dams’ embankment tilted walls and the lower flat soil of the perimeter, a combination of foundation systems has been proposed. For the utilization of the first level of the dams’ tilted embankment walls, the rows will be supported on pre-cast concrete slabs, which will avoid penetrating the ground and distribute the load.
For the utilization of the flat grounds surrounding the embankments, the structures will be founded with 6 mt HDG piles driven an average of 4.5 meters into the ground. The section of the structure on flat land with deep foundations can be used to support the tilt derived downdraft of the sections located on the tilted sections of the embankments. The load transfer and stabilization of the tilted sections will be completed with cross rafters.
The row spacing has been calculated to be 6 meters for adequate shadow reduction for the 21 of December. Given the availability of land at almost all sites inspected, an increased row spacing to nine meters would completely avoid any shadows from one row to the next but would increase the total area occupied by the array, as well as the cabling and ducting costs. The solar fields have been dimensioned with a minimum separation of five meters from the perimeter fence, to avoid any risk of direct or indirect contact from outside the solar field with the generation elements. These distances - six meters between rows and five meters from the perimeter fence - also allow for adequate servicing and maintenance works with both light and heavy machinery, both for construction and during operation.
The panels will be mounted on fixed structures with a tilt angle of 35 degrees towards heading 180 or 185 as per specific site readings. The calculated angles are optimized for the year-round production. A reduction in tilt would deliver a higher output during summer months and reduction during winter months, resulting in a year-round reduction; same as a further increase of the tilt to 40 or 45 degrees will slightly increase the winter production while reducing significantly the summer production and the year-round total generation.
GRID CONNECTION
The connection of the battery storage and PV generators will be performed at the HPP sites’ substations at generator voltage level or at high voltage level using step up transformers.
The proposed interconnection areas and routes for both the solar PV and the ESS, aside from adequate space for primary step-up facilities, take into account access to secondary interconnection facilities without crossing the 110 kV, 150 kV or 330 kV transmission interconnection lines or transformer substation at the HPPs.
The availability of enough suitable space for step-up transformers has also been accounted for in the proposed layouts.
LOCATION CONSIDERATIONS The project sites for the solar PV generator arrays and the ESS units initially identified using satellite information were studied during the visits to UHE. Their suitability, area and terrain limitations were reviewed with UHE engineers. Provisions were made to avoid any groundwork over the embankments
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of the dams and reservoirs. All sites are within the boundaries of UHE’s properties along the dam/reservoirs, and do not encroach on grown forests, main customary walkways, customary recreation areas, waterfront accesses, sidewalks, roads, power lines 3 or other infrastructure. Thus, the project will avoid a lengthy land allocation process, construction and interconnection permits. The next stage of project development must be preceded by a detailed geotechnical study.
Exclusion corridors for overhead power lines, conforming to IEC standards, and paths that avoid crossing new HV interconnection lines and transformers with existing HV lines are also included in the proposed preliminary layouts.
The solar PV arrays and reserve areas have been dimensioned to provide enough drive-through space for heavy machinery operations both in between the rows and along the perimeter to facilitate construction and maintenance works in the future.
The areas proposed for siting of the ESS units (40 feet standard container, 32.50 m2 footprint) have been sized to leave 70% of empty space (1:3 ratio) for safety separation between units and service corridors.
SIZING CONSIDERATIONS The capacity of the energy storage modules installed in the different power plants is determined taking into account the minimum (Pmin) and maximum (Pmax) capacity of the hydropower plant units that will be working together with the batteries as well as the capacity required for pumping at the pumped storage hydropower plant.
The total capacity of the installed battery storage is projected to be 197 MW, Thus as result of the hybrid operation of the power plant units and the battery storage modules UHE will be able to provide up to 197 MW of fast frequency containment reserves and substantially increase the automatic frequency regulation reserves on the ancillary service market.
The capacity of the solar generation has been determined based on the size of the required power supply for the plants auxiliaries and the estimated power supply capacity in cases of water or technological restrictions.
Most sites allow for future expansion of the battery storage modules and PV arrays if UHE decides to do so.
Current and future PV arrays will have a minimum of 5-meter separation for the surrounding fence, which prevents unintentional contact with the plant components, facilitates construction and, once the plant is finished, allows for the movement of heavy machinery as needed.
All arrays have a row separation equal or greater than 6 meters to prevent inter-row shadowing along the maximum generation hours when the sun is at his lowest angle (21 December); to completely avoid interrow shadows, the rows separation can be increased to 9 mt. The final row spacing and block size can be decided at the detailed design stage.
3 Note that the proposed site at Kremenchuck HPP is however very close to power lines.
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SAFETY CONSIDERATIONS Systems in locations close to, or within, residential areas are required to follow applicable fire safety and emission control regulations. Therefore, the systems in such areas shall be fitted with adequate additional protection and risk mitigation systems. Applicable building safety arrangements, e. g. safety of wall structures, emergency exits, fire-proof walls and safety distances, emission control and containment systems, fire trucks access roads, etc. as specified in the local standards, should be taken into consideration. Additional location risks associated with natural disasters, including but not limited to earthquakes, flooding, lightning activity and external fire, and extreme climate conditions should also be considered when designing the protection systems. All technical details of the safety measures for the ESS structure (container) will need to be discussed and agreed with the responsible public authority.
PEST CONTROL Regarding eventual pest control measures, over the years, the use of chemicals (pesticides) has not shown to be effective, with little to none latency of the effects. In these projects, being close to water bodies clearly prevents the eventual application of chemicals, while the most effective measures are already incorporated in the standard design principles, intended to avoid the settlement and nesting of various rodents and birds. These mitigation measures include the positioning of the structural “C” rails with the open face facing downwards, the routing of cables within ducts and away from the rails, in addition to having all ducts and pipes sealed with outdoors expansive polyethylene after testing. To prevent debris from the birds standing on the high edge of the panels, a small wire with spikes, like the one widely used in most public infrastructures, is installed preventing the birds from landing on the panels higher edge. To prevent damage to buried cables by underground rodents, these are driven inside pipes, which are sealed on both ends as mentioned. Finally the space under the rows of panels is high enough not to provide shelter and allowing for easy visual inspection and eventual removal from any nests.
SITE LOCATION AND LAYOUTS The Projects five sites are located across Ukraine as shown in the following figure.
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Figure 3: Site Locations
The below maps illustrate the layout of each of the five sites.
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Figure 4: Kyiv PSP
Coordinates: 50°36’23.01”N 30°28’50.39”E
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Figure 5: Kaniv HPP
Coordinates: 49°46’21.85”N 31°26’17.51”E
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Figure 6: Kremenchuck HPP
Coordinates: 49°04’50.58”N 33°13’52.49”E
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Figure 7: Seredniodniprovska HPP
Coordinates: 48°32’50.23”N 34°31’39.40”
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Figure 8: Dnistrovska HPP
Coordinates: 48°35’30.15”N 27°26’32.18”E
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ENVIRONMENTAL AND SOCIAL IMPACTS AND MITIGATION
PREAMBLE This section of the ESMP:
(i) identifies and summarizes all anticipated adverse environmental and social impacts.
(ii) describes—with technical details—each mitigation measure.
The impact assessment methodology is included for reference in Appendix A.
The identified impacts relate to all proposed sites, unless specifically stated in this section.
ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS (ESS1) ESS1 sets out the Borrower’s responsibilities for assessing, managing and monitoring environmental and social risks and impacts associated with each stage of a project supported by the Bank through Investment Project Financing, in order to achieve environmental and social outcomes consistent with the Environmental and Social Standards (ESSs). The key objectives of ESS1 are:
• To identify, evaluate and manage the environment and social risks and impacts of the project in a manner consistent with the ESSs. • To adopt a mitigation hierarchy approach to: o Anticipate and avoid risks and impacts; o Where avoidance is not possible, minimize or reduce risks and impacts to acceptable levels; o Once risks and impacts have been minimized or reduced, mitigate; and o Where significant residual impacts remain, compensate for or offset them, where technically and financially feasible.
This ESMP has been prepared to meet these objectives of ESS1, along with the other environmental and social standards listed below.
Box 1: Note on Risk Classification
For any project the Bank will classify the project into one of four classifications:
1. High Risk - A Project is likely to generate a wide range of significant adverse risks and impacts on human populations or the environment that are long term, permanent and/or irreversible, high in magnitude and/or in spatial extent and may result in a high probability of serious adverse effects to human health and/or the environment. Other issues that may make a project high risk include impacts to areas of high value and sensitiveity (e.g. legally protected sites) or where there are significant concerns that adverse social impacts of a project may result in social conflict or harm. High Risk sub-projects will be ineligible for financing under this project. 2. Substantial Risk - the Project may not be as complex as High Risk Projects, its ES scale and impact may be smaller (large to medium) and the location may not be in such a highly sensitive area, and some risks and impacts may be significant. Impacts are generally temporary, predictable and/or reversible and are medium in magnitude and/or in spatial extent. The effects of the Project on areas of high value or sensitivity are expected to be lower than High Risk Projects. The potential for cumulative and/or
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transboundary impacts may exist, but they are less severe and more readily avoided or mitigated than for High Risk Projects 3. Moderate Risk - The potential adverse risks and impacts on human populations and/or the environment are not likely to be significant. This is because the Project is not complex and/or large, does not involve activities that have a high potential for harming people or the environment, and is located away from environmentally or socially sensitive areas. The potential risks and impacts and issues are likely to have the following characteristics: (i) predictable and expected to be temporary and/or reversible; (ii) low in magnitude; (iii) site-specific, without likelihood of impacts beyond the actual footprint of the Project; and (iv) low probability of serious adverse effects to human health. 4. Low Risk - A project is classified as Low Risk if its potential adverse risks to and impacts on human populations and/or the environment are likely to be minimal or negligible. These Projects, with few or no adverse risks and impacts and issues, do not require further ES assessment following the initial screening.
Relevant issues, such as the type, location, sensitivity, and scale of the project; the nature and magnitude of the potential environmental and social risks and impacts; and the capacity and commitment of the Borrower (UHE) to manage the environmental and social risks and impacts in a manner consistent with the ESSs are taken into account in determining the appropriate risk classification for the Project. Accordingly, the Project has been classified by the Bank as a ‘substantial risk’ due to potential biodiversity impacts.
The Bank will review the risk classification assigned to the project on a regular basis, including during implementation, and will change the classification where necessary, to ensure that it continues to be appropriate. Any change to the classification will be disclosed on the Bank’s website.
LABOUR AND WORKING CONDITIONS (ESS2)
ESS2 ASPECTS Construction and operation of the Project will require a number of workers. During the construction phase an Engineering, Procurement and Construction (EPC) Contractor will be hired to manage the design, procurement and construction phase of the Project before handover to UHE.
ESS2 RECEPTORS During the construction phase EPC Contractors staff are considered to the affected receptors and during the operational phase UHE staff will be the affected receptors.
ESS2 AREA OF INFLUENCE During both construction and operational phases the area of influence (AoI) for the identified aspects is limited to the site construction and operation zones which are fully within existing UHE site boundaries.
ESS2 POTENTIAL IMPACTS
Worker Conditions and Management of Worker Relationships
The workforce can be exploited if adequate measures are not put in place to protect them such as clearly understandable terms and conditions of employment in contracts, fair compensation, working hours holidays, social security benefits and severance payments. Workers may also be impacted if they are treated differently based on personal characteristics and are prevented from joining workers organizations or prevented from having the right to bargain collectively without interference.
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Construction Phase – Measures have been included within this ESMP and the associated Labour Management Procedures (LMP) to ensure that worker conditions during the construction phase are adequately considered. Note that the construction period is relatively short and that only 20-30 workers are envisaged to be present at various stage of the construction process. Most of the staff will be either local sub-contractors or full-time members of the EPC Contractors staff all of which are likely to have standard contractual agreements which would prevent exploitation. Nonetheless, the Project LMP will have included measures to ensure this. No UHE staff will be involved in site construction. No significant impacts are therefore anticipated.
Operational Phase – UHE will be responsible for operating the facilities. UHE has its own CSR (Corporate Social Responsibility) strategy focusing on enhancing the loyalty, commitment, and engagement of our employees, improving the productivity of work, reducing the staff turnover, optimising costs of employee recruitment and development, therefore no significant impacts to UHE workers in this respect is anticipated.
Protecting the Workforce
Construction Phase – The EPC Contractor will follow all relevant national labour laws relating to the minimum age of workers. Ukraine has also ratified ILO Convention on Minimum Wage and Worst Form of Child Labour. Forced labour is not envisaged.
Operational Phase - No child labour or forced labour is used by UHE. All members of the workforce are employed in line with Ukrainian labour laws, ILO Conventions and its requirements for minimum age of workers.
Grievance Mechanism
Construction Phase – Workers may have complaints about working conditions, salaries, health and safety, etc. A GRM will be therefore be required for EPC Contractor staff during the construction phase.
Operational Phase – Although no written ‘GRM’ currently exists for UHE staff, a structure is in place for workers to raise grievances. UHE employees can raise complaints with their line manager, Director of HPP/PSP, or UHE management. According to UHE staff spoken to during the preparation of the ESMP (at the sub-project sites) there have been no complaints from staff currently employed by UHE (although some complaints were received from retired employees who wished to continue working). In addition, there is a UHE support telephone line where complaints can be made. According to the UHE CSR Strategy, UHE encourages the social dialogue by engaging trade unions of employees and employers to a dialogue to increase productivity, resolve disputes, and build cohesive communities. UHE also approved a Collective Bargaining Agreement 2019-2021.
Occupational Health and Safety
Construction Phase – Potential OHS impacts during the construction phase include; accidents whilst using construction equipment, including vehicles and handheld devices, and electric shocks. The EPC Contractor should be selected based on his experience of similar Projects and should therefore have in place company procedures for occupational health and safety. However, their procedures might not be fully aligned with WBG EHS Guidelines. This will be a prerequisite for any EPC Contractor to demonstrate this as part of pre-qualification for the Project. The EPC Contractor will also be responsible for ensuring that all works are conducted in line with WBG EHS Guidelines.
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In addition, workers could also be affected by communicable disease, specifically COVID-19. Specific World Bank guidance for contractors is included in Appendix D to manage COVID-19 aspects at construction sites.
Gender based violence (GBV) and sexual exploitation, abuse and harassment (SEAH) is also a potential risk during the construction phase.
Operational Phase – The following information has been extracted from the UHE Management Report for 2019.
• Occupational health and safety are monitored by H&S units and heads of production units to prevent occupational accidents, injuries and diseases. • The H&S system has a clear division of duties and responsibilities. Senior managers and relevant professionals at the branches constantly monitor, assess the technical condition of the equipment (initial, periodic, extraordinary technical inspections, expert inspections) and oversee the safe operation of high-risk equipment. • In 2019, the Company spent UAH 9,139,000 (UAH 10,456,000 in 2018 and UAH 8,206,000 in 2017) on H&S measures, which made 1.6% of the payroll. • The main H&S expenses in 2019 were related to: o Provision of overalls, special footwear and other personal protective equipment to workers — UAH 2,338,000 (UAH 2,882,000 in 2018) o Provision of collective protective equipment — UAH 578,000 (UAH 182,000 in 2018) o Assessment of workplaces — UAH 448,000 (UAH 135,000 in 2018) o Obligatory medical check-ups — UAH 448,000 (UAH 416,000 in 2018) o Provision of milk, equivalent food products, and special food — UAH 1,343,000 (UAH 1,034,000 in 2018) o Provision of detergents — UAH 693,000 (UAH 499,000 in 2018) o Bringing the fixed assets in line with the H&S regulatory requirements — UAH 492,000 (UAH 3,635,000 in 2018). • UHE has had a voluntary health insurance programme since 2018. In 2019, over 70% of the Company’s employees received health insurance at UNIQA insurance company. • Workers engaged in heavy works, harmful or dangerous operations, hazardous working conditions or works requiring professional selection were only admitted to work after undergoing medical check-ups, training and knowledge testing. • Monitoring is carried out through inspections of the operation of high-risk facilities, assessment of workplaces, and checks of working conditions. At every level, the Company applies a mechanism to detect and eliminate hazards, control and reduce the risk of fatalities. • In the event of an accident, an investigation commission is to be set up. In 2019, there were no occupational accidents, injuries or diseases at outsider companies operating the Company’s equipment or road accidents with people. • In 2019, the State Labour Service did not conduct any inspections in the Company. At the same time, 248 inspections were conducted by UHE’s H&S Service. In addition, 1,002 checks were conducted during introduction of special conditions for safe works. The Company performed all the measures to eliminate all faults indicated in follow-up recommendations. During the year, the Company held 24 employees liable for violation of the H&S requirements.
Site visits have indicated that there are medical posts at all UHE sub-project sites. A first aid kit is also present and full of proper medicines.
All of the above suggests that health and safety impacts in the operational phase of the Project will be well managed by the existing UHE systems and therefore impacts are not anticipated to be of high
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significance. The main potential OHS risks relate to electrical accidents which UHE staff should be fully trained to avoid and manage. Notwithstanding the above, it is recommended that an audit of UHE OHS procedures is undertaken during the Project design phase to determine any gaps with international best practice. Where gaps are identified OHS training programs should be provided to UHE prior to the handover of the Project to UHE.
Regarding COVID-19, UHE will be responsible for following national protocols and procedures for the safety of their workers during the operational phase of the Project.
Gender based violence and sexual abuse and harassment are potential risks in any workplace including UHE.
Community Workers
None planned as part of the Project.
Primary Supply Workers
The Project involves the installation and operation of solar panels and battery storage. The equipment will be sent directly to the site from the manufacturing plant. The equipment suppliers at this stage of the Project is not known and will be determined during the procurement phase by the EPC Contractor. The EPC Contractor will be responsible for ensuring that any supplier meets the requirements of ESS2 regarding risks relating to child labour, forced labour and serious safety issues and will ensure that clauses are included in all sub-contracts and agreements with sub-contractors and suppliers.
Table 3: Labour and Working Conditions Impacts
Phase
Receptors
Magnitude
Probability
Timeframe
Significance
Spatial Spatial Scale
Consequence
Potential Impact Potential
Sensitivity of Receptors of Sensitivity No. of Receptors Affected Receptors of No.
C Worker Conditions EPC Contractors Staff L M MO ST SMA L UN NS and Management of Worker Relationships
O Worker Conditions UHE Staff L M MO LT SMA L UN NS and Management of Worker Relationships
C Protecting the EPC Contractors Staff L M MO ST SMA L UN NS Workforce
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Phase
Receptors
Magnitude
Probability
Timeframe
Significance
Spatial Spatial Scale
Consequence
Potential Impact Potential
Sensitivity of Receptors of Sensitivity No. of Receptors Affected Receptors of No.
O Protecting the UHE Staff L M MO LT SMA L UN NS Workforce
C Grievances EPC Contractors Staff L M MO ST SMA M UN L
O Grievances UHE Staff L M MO ST SMA M UN L
C OHS EPC Contractors Staff L H MA ST SMA M POS M
O OHS UHE Staff L H MA LT SMA M POS M
Key: H: High / M: Medium / L: Low / MAJ: Major / MOD: Moderate / MIN: Minimum / H/F: High Frequency / M/F: Low Frequency / L/F: Low Frequency / LT: Long term / MT: Medium Term / ST: Short term / MED: Medium / DEF: Definitely / POSS: Possible: / UNLIKE: Unlikely. Cells shaded in blue are positive impacts.
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MITIGATION MEASURES ESS Item Impact Management / Mitigation Responsibility Cost Residual Impact Measure
Worker Conditions No significant Implementation of the measures outlined in EPC Contractor Considered part of general None
and Management of impacts the associated Labour Management Plan construction related costs Worker Relationships identified unless specified in the LMP.
Protecting the No significant Review of EPC Contractors staff contracts Supervision Considered part of SC general None
Workforce impacts to ensure they are within the legal age for Consultant supervision costs. identified work in line with Labour Law and ILO Conventions and World Bank Guidance Notes on Non-Discrimination and Disability and Sexual Orientation and Gender Identity.
Grievances Construction Prepare and implement a GRM for the EPC Contractor Considered part of general None
- Contractor construction phase of the Project. construction related costs staff grievances
Operation - Formalize a GRM for UHE staff UHE Included as part of UHE HR None UHE staff department costs grievances
OHS Construction 1. Develop an OHS plan for the EPC Contractor All considered part of general Low
- Accidents construction phase. construction related costs. and electric 2. The OHS plan will include all of the shocks relevant portions of the WBG EHS Guidelines for OHS including: a. Communication and training
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ESS Item Impact Management / Mitigation Responsibility Cost Residual Impact Measure
b. Physical hazards c. Chemical hazards d. PPE 3. OHS Manager, with training in first aid to be present at site. 4. Provide OHS induction and regular OHS talks to staff prior to the start of the working day. 5. First aid kits (compliant with OSHA standard 1910.266 App. A) will be provided at all work sites. 6. Provide all workers with appropriate PPE for their respective jobs.
Operation - 1. Further analysis of OHS within UHE to OHS Analysis and OHS Analysis and Training – Low Accidents and ensure GIIP. Training – Technical TA costs electric 2. Development of training programs Consultant shocks where gaps are identified. Compliance – UHE costs 3. Continued compliance with national Compliance - UHE regulations.
Construction 1. Implement all necessary national EPC Contractor All considered part of general Low – COVID-19 guidelines relating to COVID-19. construction related costs. 2. Prepare and implement a COVID-19 Management Plan based on the guidelines provided in Appendix D.
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ESS Item Impact Management / Mitigation Responsibility Cost Residual Impact Measure
Operation – 1. Follow national guidelines and UHE Included as part of general Low COVID-19 regulations. UHE operational costs
Construction 1. Deliver specific training on GBV-SEAH EPC Contractor $2,000 for Consultant to Low – GBV / SEAH to all contracted employees and provide training. provide Grievance Redress Mechanism to report GBV-SEAH. 2. Follow the requirements of World Bank Guidance Note: Addressing Sexual Exploitation and Abuse/Sexual Harassment and World Bank Guidance Note on Gender Based Violence.
Operation – 1. Deliver specific training on GBV-SEAH UHE $2,000 for Consultant to Low GBV / SEAH to all UHE staff and provide Grievance provide training. Redress Mechanism to report GBV- SEAH. 2. Follow the requirements of World Bank Guidance Note: Addressing Sexual Exploitation and Abuse/Sexual Harassment and World Bank Guidance Note on Gender Based Violence.
Primary Supply Construction 1. Ensure that any supplier meets the EPC Contractor None None
Workers - Suppliers do requirements of ESS2 regarding risks not meet the
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ESS Item Impact Management / Mitigation Responsibility Cost Residual Impact Measure
standards of relating to child labour, forced labour ESS2. and serious safety issues.
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RESOURCE EFFICIENCE AND POLLUTION PREVENTION AND MANAGEMENT (ESS3)
ESS3 ASPECTS Construction Phase
• Vegetation clearance and site leveling using construction vehicles and construction equipment, e.g. mobile generators, to prepare an area for the solar PV array and battery storage areas. • Water use for construction activities. • Waste material generated from packaging and excess construction materials. • Small volumes of hazardous waste generated during construction, e.g. paint tins, empty oil cans.
Operational Phase
• Generation of waste materials, e.g: panels that need replacing. • Oil leaks from transformers.
Pesticides will not be used during Project construction or operational phases.
ESS3 AREA OF INFLUENCE The Project AoI is considered as follows:
Air Quality – combustion emissions will be localized and should not result in significant impacts at a distance of more than 50m from the source. AoI for this aspect is therefore a 50m buffer around construction zones.
Water Resources – In general the risk of significant impacts occurring is low and any spill or leak will be diluted quickly within the large adjacent surface waters. The AoI for water resources is considered to be a 100m buffer zone from any work area close to surface water. Biodiversity issues are discussed further below.
Soils – The AoI for soils is the immediate construction zones.
Waste and Hazardous Materials – The AoI includes the immediate work sites and waste disposal areas. Some waste materials could be blown off the site into adjacent neighboring areas including surface waters, therefore the AoI is expanded to include a 200m buffer around work sites.
ESS3 RECEPTORS Residential receptors may be impacted by degraded air quality and wind-blown waste, including:
• Kiev HPP: Adjacent to the site. According to UHE, these are illegal dachas, not located on UHE land. • Kremenchuck HPP: Within 50m of the site • Seredniodniprovska HPP: Within 50m of the site • Kaniv HPP: None within 350m. • Dnistrovska HPP: None within 350m.
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Other sensitive receptors include the reservoirs upon which the HPPs are located, most of which are Emerald sites (see below for more information on this subject). Soils on the site are not considered to be a sensitive receptor as they are generally degraded by human activity and are not considered a valued ecosystem component.
ESS3 POTENTIAL IMPACTS
Energy Use
During construction energy will be provided by power from the grid, or via mobile generators at work sites) which will not result in significant energy use. Further, the Project will have significant long-term benefits in terms of energy use and the contribution towards sustainable development.
In addition, research undertaken by the Boeing Corporation on battery storage indicates that the environmental impacts are minimal in the production of lithium and extraction processes are not energy-intensive. 4
Water Use
Water use during the construction phase will not be significant and can be sourced from either existing piped water supplies at the HPP or extracted from the adjacent reservoirs (this activity may require permitting). Studies of water use during the construction phase of solar project in the US indicate that between 1,600 m3 and 7,000 m3 are required during the construction phase (mainly for dust control). 5 This is considered to be a negligible amount given the availability of water in the adjacent reservoirs. As an indicator of this value, use of water at Kaniv HPP in 2019 was 23,768 mm cu.m.
Water use during the operational phase is estimated to be negligible for the washing of the solar panels given the availability in the adjacent reservoirs. Recent studies of solar power projects undertaken by the Asian Development Bank 6 indicate that Wet cleaning requires 4 tonnes of water per MWDC. The average size of the sub-projects is 13MW, assuming 8 cycles of cleaning (6 front panel and 2 back panel) the total water requirements for each sub-project site will be just over 1m3 per day (408 m3 per annum). Wet cleaning will be performed with misted water without any chemicals, performed only in the dry months of the year with 95% evaporation rate. As such no wastewater discharge impacts are anticipated.
Soils
Vegetation clearance could result in some minor soil erosion around the work sites. Such erosion would have a negligible impact on the reservoirs adjacent to sites in terms of sedimentation. No impacts to agriculturally productive soils are envisaged and this ESMP provides measures to ensure that any exposed soils are revegetated with local grasses to prevent erosion on any slopes cleared to house the solar array. Some minor soil pollution could occur if there are leaks or spills of oil, but the volumes stored and used at work sites will be small and will not significantly impact soils of economic
4 Source: https://www.boeing.com/features/innovation-quarterly/aug2018/btj-batteries.page
5 Water Use and Supply Concerns for Utility-Scale Solar Projects in the Southwestern United States. Sandia National Laboratories, 2013.
6 Nur Navoi Solar PV ESIA, Uzbekistan. ADB 2020
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or environmental value. Nonetheless, measures are provided in the mitigation and management section of the ESMP below to manage any spills and leaks.
Raw Material Use
The Project will mainly be supplied with ready made parts to be installed at the sites. There may be some need for aggregates and concrete for foundations and access paths to the site, however, the volumes of material required will not be significant and could be compared with the construction of a small industrial facility. No significant impacts are anticipated
Management of Air Pollution
During construction impacts could include dust generation from the movement of vehicles across work sites and from any excavation works and leveling of land. As noted above, some residential receptors are located within 50m of sub-project work sites and these areas could be impacted by dust. Combustion emissions from fuel combustion engines of construction vehicles and mobile generators are less likely to cause a nuisance to residential receptors at this distance. All works will be undertaken over a relatively short time frame and as such air quality impacts are not anticipated to be of high significance especially if the proposed mitigation and management measures outlines in this ESMP are implemented during the construction phase, e.g. locating sources of emissions away from sensitive receptors, using dust suppression measures, etc.
No air quality impacts are envisaged in the operational phase of the Project.
Greenhouse Gases and Climate Change
Changing climate could potentially result in increased levels and intensity of precipitation in the region. Therefore it is important that the EPC Contractor ensures that this issue is taken into account during the design phase, firstly by ensuring that the sub-project sites are not located in flood prone areas and secondly that there is adequate site drainage to prevent erosion around panel supports (especially on slopes).
Electricity emissions factors in Ukraine are estimated between 550 and 600 g CO2 / kWh. 7 The lifetime emissions factor of solar PV has been estimated at around 6 g CO2 / kWh. 8 Accordingly, the
Project will result in significant CO2 reduction over its lifecycle.
Management of Hazardous and Nonhazardous Waste
Some waste materials were noted at sub-project sites. These materials need to be cleared from the work site by UHE prior to commencement of works. Waste will be disposed of in line with national regulations.
A range of non-hazardous waste will be generated during the construction phase, including cardboard, plastic and wood packaging, scrap metal and paper. Much of this waste can be collected and recycled. Where recycling facilities do not exist, the material will be sent to licensed landfills. Some small volumes of hazardous waste will be generated during the construction phase, including empty paint
7 EIB Project Carbon Footprint Methodologies. Methodologies for the Assessment of Project GHG Emissions and Emission Variations. July 2020
8 Source: https://www.carbonbrief.org/solar-wind-nuclear-amazingly-low-carbon-footprints
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tins and empty oil cans, oily rags, as examples. Hazardous waste will be collected and stored at work sites in suitable containers prior to disposal at licensed hazardous waste facilities. Any broken panels will be repackaged and returned to the supplier.
It is noted that UHE have waste storage and collection systems at the HPP sites and that it is managed according to national regulations and standards (copies of waste management contractors contracts and licenses can be provided, for all generated wastes, including hazardous waste) and as such this system will continue to be followed during the operational phase of the Project.
Any broken panels will be removed and placed in a storage container which aside from his main purpose of storing spares doubles as safe storage and containment for eventually damaged components, until their safe removal, according to national waste disposal regulations, can be acted upon. No significant waste management impacts during the operational phase are therefore anticipated.
Decommissioning of the facility will generate a large amount of hazardous waste, including solar panels. Collection of exhausted of battery modules will be within the OM contracts and fulfilled by the modules manufacturer. The batteries are not disposable elements, they are installed and removed as a containerized unit. The batteries maintain a very high after life value, with nearly 80% of their capacity intact at the end of his commercial lifecyle, and the whole containers will be replaced and shipped back to factory for refurbishment and repurpose. Batteries are also supplied and operated under a performance guarantee, hence if any individual module underperforms it will be replaced and shipped back to factory for analysis and insurance claims.
A plan to manage the decommissioning of the sub-project sites will need to be established by UHE, including procedures for the safe disposal of equipment on site, including any remaining PV panels.
Management of Chemicals and Hazardous Materials
During the construction phase there will be a requirement for use of oil and grease, but only in limited volumes. These materials will be stored according to the requirements of their material safety data sheets (MSDS) away from water sources.
Transformer oil will be stored at the site during the operational phase. It is assumed that the oil will be stored in the same place on site as is currently used at the sub-project sites. A review of these areas during site visits indicated that these areas are stored correctly. As a precautionary measure this ESMP includes specific requirements for the storage of transformer oil used for the Project.
Leaching of Contaminants from Broken Panels
The glass found on PV panels only function is to provide structural integrity to the panels and allow for manipulation and installation. The module itself is a flexible thermal encapsulation of the silicon based cells between two melted layers of ultra-transparent Tedlar film, which is almost unbreakable unless hit by a bullet, cut with a grinder, or melted in factory above 1,000 °C. A broken glass reduces light absorption by the cells, but the panel remains fully operational, eventually for all his life.
Studies from DoE, NREL and BP Solar conclude there is no leaching from crystalline silicon cells, even when directly exposed to highly corrosive environments. Other recent studies also found that no
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elements were, on average, present in concentrations around PV panels that would pose risk to nearby ecosystems.9
Further, the panels that will be required in the procurement will be from Tier 1 rated manufacturers (BNEF bankable rated), all of which are ROHS compliant and EU’s PVCycle associated.
Given the above, no significant impacts associated with this issue are anticipated.
Table 4: Resource Efficiency and Pollution Impacts
Phase
Receptors
Magnitude
Probability
Timeframe
Significance
Spatial Spatial Scale
Consequence
Potential Impact Potential
Sensitivity of Receptors of Sensitivity No. of Receptors Affected Receptors of No.
C Energy Use - L L MI ST IN L DE NS
C Water Use Water resources L L MI ST SM L DE NS
O Water Use Water resources L L MI LT SM L DE NS
C Soils Local environment L L MI ST SM L PO L
O Soils Local environment L L MI LT SM L PO L
C Air Pollution Local Community M M MO ST SM M PO L
C Waste Management Local Community / L M MO ST SM M DE L Local environment
O Waste Management Local Community / L M MO LT SM M DE L Local environment
D Waste Management Local Community / L H MA LT IN M DE M Local environment
C Management of Chemicals Local Community / L M MO ST SM L DE L and Hazardous Materials Local environment
Key: H: High / M: Medium / L: Low / MAJ: Major / MOD: Moderate / MIN: Minimum / IN: Insignificant / H/F: High Frequency / M/F: Low Frequency / L/F: Low Frequency / LT: Long term / MT: Medium Term / ST: Short term / MED: Medium / DEF: Definitely / POSS: Possible: / UNLIKE: Unlikely.
9 Potential for Leaching of Heavy Metals and Metalloids from crystalline silicon photovoltaic systems. Journal of Natural Resources and Development. 2019
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MITIGATION MEASURES ESS Item Impact Management / Mitigation Responsibility Cost Residual Impact Measure
Energy Use No significant None required N/A N/A None
impacts identified
Water Use No significant Although no significant impacts have been EPC Contractor Considered part of general None
impacts identified, it is recommended that waterless construction related costs. identified cleaning methods be investigated by the EPC Contractor to determine if they are feasible at the sites.
Soils Construction 1. Design should account for erosion. EPC Contractor All considered part of general None
- Soil erosion Arrays located on slopes should construction related costs. include adequate drainage, or be graded / stepped to prevent erosion. 2. Salvage and store topsoil and subsoil before areas are excavated, with topsoil stripped and stockpiled separately. 3. Ensure that any exposed soils are revegetated with local grasses to prevent erosion on any slopes cleared to house the solar array.
Construction 1. Ensure that only small volumes of oils EPC Contractor All considered part of general None - Soil are used at construction areas (less construction related costs. contamination than 20 liters)
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ESS Item Impact Management / Mitigation Responsibility Cost Residual Impact Measure
2. Oil cans and other hazardous liquids will be stored on within a secure bunded area in their original containers when they are not being used at construction areas. Spill kits should be provided in these areas 3. Any soils contaminated by spills or leaks in the construction phase will be excavated and disposed of as hazardous waste. 4. Toolbox training on this issue will be provided to EPC Contractors staff.
Raw Material Use No significant None required N/A N/A None
impacts identified
Air Pollution Construction 1. Stationary emission sources (e.g., EPC Contractor All considered part of general None
– Dust and portable diesel generators, construction related costs. engine compressors, etc.) shall be positioned emissions as far as is practical from sensitive receptors. 2. Equipment and vehicles will be regularly maintained in accordance with the manufacturer's recommendations to maximize fuel efficiency and help minimize emissions. 3. Controlled or uncontrolled burning of waste will not be allowed.
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ESS Item Impact Management / Mitigation Responsibility Cost Residual Impact Measure
4. Dust control measures will be implemented on all roads within 250m of residential / sensitive receptors. 5. The EPC Contractor will be required to have an adequate supply of bowsers and carry out watering for dust control at least once a day near residential areas: in dry weather with temperatures of over 25, or in windy weather. Avoid overwatering as this may make the surrounding muddy. 6. Vehicle movements will be restricted to defined access routes and demarcated working areas (unless in the event of an emergency). 7. A strict Project speed limit of 30km/hr will be enforced for Project vehicles using unmade tracks and within Project construction zones. 8. Vehicles carrying fine aggregate materials will be sheeted to help prevent dust blow and spillages. 9. Earthwork operation will be suspended when the wind speed exceeds 20 km/h in areas within 500 m of any community.
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ESS Item Impact Management / Mitigation Responsibility Cost Residual Impact Measure
Greenhouse Gases Operation – 1. Ensure all designs account for any EPC Contractor All considered part of general None
Climate increase in flood events. construction related costs. change, i.e. 2. Provide adequate drainage and flooding, vegetation around the site to reduce increased the likelihood of localized flooding and precipitation soil erosion.
Waste Construction 1. Construction waste will be re-used and EPC Contractor All considered part of general None
– improper recycled where possible. construction related costs. management 2. Any remaining waste materials shall be and disposal of collected and stored in waste waste containers before disposal to landfill by materials licensed contractors. 3. Hazardous waste will be collected and stored at work sites in suitable containers prior to disposal at licensed hazardous waste facilities. 4. Hazardous liquids will not be stored within 50m of any water course. 5. Broken panels and other non- functioning equipment supplied to the site shall be returned to the supplier in their original containers. 6. Portable toilets should be provided at work sites, if UHE facilities are unavailable.
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ESS Item Impact Management / Mitigation Responsibility Cost Residual Impact Measure
Operation – 1. Storage of damaged panels in specific UHE Part of UHE HPP operational None disposal of project storage area. costs. waste, 2. Removal of waste materials according including PV to national regulatory requirements. panels. 3. Collection of exhausted of battery modules will be within the OM contracts and fulfilled by the modules manufacturer.
Decommissio Prepare a decommissioning plan for the safe UHE Part of UHE HPP operational None, if the plan is ning – management and disposal of hazardous costs. adequately Removal of waste. implemented. hazardous waste
Pesticides Operation – No pesticides are planned for use during the use of Project. Procurement and OM contracts pesticides will include clauses
Hazardous materials Construction All hazardous materials will be stored EPC Contractor All considered part of general None
– Pollution according to the requirements of their construction related costs. from Material Safety Data Sheets (MSDS). hazardous materials
Operation – 1. Oil will be stored in UN approved UHE Part of UHE HPP operational None Storage and containers, or other containers costs. use of approved by national regulations or the MSDS. The containers will be stored in
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ESS Item Impact Management / Mitigation Responsibility Cost Residual Impact Measure
transformer secure, impermeable bunded areas oil capable of containing at least 110% of the volume of the largest container in the bund. 2. Hazardous liquids will not be stored within 50m of any water course. 3. Regular inspection of the storage area will be undertaken.
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COMMUNITY HEALTH AND SAFETY (ESS4)
ESS4 ASPECTS • Construction activities, such as site clearance and installation of panel supports will require the use of noisy machinery. • Construction and operation of the site will involve the use of live high voltage equipment. • Security staff are required to ensure that the site is secure at all times.
ESS4 AREA OF INFLUENCE Access to the site is prohibited and all facilities will be constructed according to Good International Industry Practice (GIIP) meaning that community health and safety issues will be largely limited to those relating to noise and road safety. The Project AoI for noise is a 500m buffer from construction zones and for road safety it relates to all haul routes to the site.
ESS4 RECEPTORS Residential receptors can be found as follows:
• Kiev HPP: Adjacent to the site. • Kaniv HPP: More than 350m from the site. • Kremenchuck HPP: Within 50m of the site • Seredniodniprovska HPP: Within 50m of the site • Dnistrovska HPP: Within 800m of the site
ESS4 POTENTIAL IMPACTS
Infrastructure and Equipment Design and Safety
UHE and the EPC Contractor will design, construct and operate, the structural elements of the project in accordance with national legal requirements, the EHSGs and other GIIP, taking into consideration safety risks to third parties and affected communities. Structural elements of a project will be designed and constructed by competent professionals and certified or approved by competent authorities or professionals. Structural design will take into account climate change considerations, as appropriate.
Access to the site will be strictly controlled and no access to members of the public will be permitted. According to the UHE Management Report (2019), UHE takes measures to prevent unauthorised incursions into its territory, buildings, and premises and thus prevent people’s injuries on the Company’s equipment. In particular, they have installed security alarm systems. They also monitor the technical condition of fences, locking devices, warning signs, and posters.
Site inspections undertaken during the preparation of the Projects ESMP indicated that all sites are gated. However, a thorough review the UHE site premiter fencing was not undertaken. It is possible that some portions of the UHE sites may not be secure (notably those areas that are located a long distance from main HPP infrastructure), and that in practice people could access the planned Project sites. This could lead to accidents and potentially theft of equipment.
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None of the sites are located in ‘high-risk’ locations relating to weather conditions with the exception of Kremenchuck HPP where part of the proposed sub-project site is considered potentially prone to flooding. It is assumed that these aspects will be accounted for as part of the Projects feasibility study and detailed design.
Dam failure would impact significantly on all of the Project sites. Accordingly, existing dam safety reports should be reviewed during the design phase to ensure that they are satisfactory to World Bank requirements.
All sub-project sites have Emergency Response Plans in place and emergency warning equipment is in place at the sub-project sites (e.g. sirens). Emergency response training is provided on a biannual basis.
Safety of Services
The Project will provide electricity directly to the existing grid. No specific services to the community are anticipated.
Traffic and Road Safety
Transport of equipment to the site will be required. In general, the amount of truck and car journeys to the site will not be significant and is not anticipated to result in additional safety risks to the local community. No construction vehicles will be operated in public areas. Some of the sub-project sites (e.g. Kyiv) will require some minor upgrading of access roads to make them suitable for the delivery of large loads by heavy goods vehicles.
Ecosystem Services
No impacts to ecosystem services are anticipated as part of the Project.
Community Exposure to Health Issues
The Project will not result in community health issues. All construction activities will be undertaken on site and no significant issues, such as significant water pollution are anticipated.
The Project workforce is likely to comprise no more than 20-30 or so workers at a time on the site, most of which will be locally sourced. The transmission of communicable disease in the local community from these workers is considered to be very low.
Impacts relating to air quality are discussed above, and noise below.
Noise
Several of the Project sites are located close to residential areas. Noise impacts on the local community during construction are possible. However, in general the type and number of equipment used will not generate significant levels of long-term noise. Construction will require the use of standard equipment such as graders, scrapers, backhoes, loaders, cranes, dozers, water trucks, portable generators and air compressors, and miscellaneous trucks. These types of construction equipment will generate noise levels above WBG guidelines limits in areas immediately adjacent to work sites. Inserting support structures will also generate noise which could be considered a nuisance. All of these short-term construction phase noise impacts can be readily managed by incorporating good industry practice measures, such as time and activity restraints, placement of temporary noise barriers at noisy work sites, etc. All of these measures are included in the mitigation section of this ESMP below.
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A small vibratory pile driver will be used to place the supports for the solar panels, similar to that used to install freeway guardrails. Vibration from this equipment is not anticipated to impact upon residential properties around the site (vibration of this type will only affect an area within a few meters of the piling area).
During the operational phase of the Project noise will be generated by new inverters and transformers. Due to the nature of solar facilities, this noise will be generated during daylight hours and not at night. Noise levels from this equipment can be as high as 62 dBA at one meter from the source (inverter) and up to 75 dBA at once meter from the source (transformer). 10 If this equipment is located too close to residential receptors it could cause a nuisance during the daytime period and even exceed Project standards for daytime noise. As such, it is recommended that all inverters and transformers are located at a distance that would not impact upon residential receptors, e.g. more than 50 meters from the identified receptors.
Emergency Preparedness and Response
Emergency response procedures have been prepared for all of the HPPs. The procedures must be updated to include the Project, both during construction and operational phases.
Security Personnel
No additional security staff are envisaged under the Project. All Project components will be sited within the existing HPP site boundaries. No security issues have come to light during site visits undertaken for this ESMP.
Table 5: Community Health and Safety Impacts
Phase
eceptors
R
Magnitude
Probability
Timeframe
Significance
Spatial Spatial Scale
Consequence
Potential Impact Potential
Sensitivity of Receptors of Sensitivity No. of Receptors Affected Receptors of No.
C/O Infrstructure design and safety Local community M M MO LT SMA M POSS L
C Noise Local community M M MO ST SMA L DEF L
10 Acoustical Assessment Report for the Ord Mountain Solar and Energy Storage and Calcite Substation Project San Bernardino County, California. County of San Bernardino, Land Use Services Department. 2018
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Phase
eceptors
R
Magnitude
Probability
Timeframe
Significance
Spatial Spatial Scale
Consequence
Potential Impact Potential
Sensitivity of Receptors of Sensitivity No. of Receptors Affected Receptors of No.
O Noise Local community M M MO LT SMA L POS L
C/O Emergencies Local community M M MO LT SMA L UN L
C/O Security Personnel Local community L L MI LT SMA L UN NS
Key: H: High / M: Medium / L: Low / MAJ: Major / MOD: Moderate / MIN: Minimum / H/F: High Frequency / M/F: Low Frequency / L/F: Low Frequency / LT: Long term / MT: Medium Term / ST: Short term / MED: Medium / DEF: Definitely / POSS: Possible: / UNLIKE: Unlikely. Cells shaded in blue are positive impacts.
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MITIGATION MEASURES ESS Item Impact Management / Mitigation Responsibility Cost Residual Impact Measure
Infrastructure and Construction 1. Design, construction and operation of Design Elements – Design elements included in None at this stage
Equipment Design and – Safety risks the structural elements of the project EPC Contractor general EPC costs Safety to the will be in accordance with national legal community. requirements, the EHSGs and other Perimeter fencing – Dam review part of Tetra GIIP, taking into consideration safety EPC Tech costs. risks to third parties and affected communities. Review of dams safety Site control – no additional 2. Perimeter fencing will be examined reports – Tetra Tech costs during design. If required, fencing will Controlled Site be constructed either around Project Access - UHE infrastructure or the UHE site perimeter to prevent unauthorised access during the operational phase of the Project. 3. Structural elements of a project will be designed and constructed by competent professionals and certified or approved by competent authorities or professionals. 4. Structural design will take into account climate change considerations and potential flood areas as appropriate. 5. Existing dam safety reports should be reviewed during the design phase to ensure that they are satisfactory to World Bank requirements.
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ESS Item Impact Management / Mitigation Responsibility Cost Residual Impact Measure
6. Access to the work sites will be strictly controlled and no access to unauthorized people will be permitted.
Operation - Access to the site will be strictly controlled UHE Site control – no additional None Safety risks to and no access to members of the public will costs the be permitted. community.
Traffic and Road No significant None required N/A N/A None
Safety impacts identified
Community Exposure No significant None required N/A N/A None
to Health Issues impacts identified
Noise Construction 1. Equipment and vehicles will be EPC Contractor Temporary Noise Barriers - Low
– short term regularly maintained in accordance $2,000 construction with the manufacturer's noise recommendations to help minimize noise emissions. 2. During construction, work will be undertaken in daytime hours only – in accordance with WB definitions. 3. Project induction training will include instructions about minimizing noise disturbance.
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ESS Item Impact Management / Mitigation Responsibility Cost Residual Impact Measure
4. Local residents will be forewarned of planned activities that are considered by the Project to be noisy.
Operation – All inverters and transformers must be sited EPC Contractor None None noise from at least 50m from the nearest residential transformers receptors. and inverters
Vibration No significant None required N/A N/A None impacts identified
Emergencies Operation and Existing ERPs must be updated to include EPC Contractor and Part of EPC Contractors and None
Construction the Project, both during construction and UHE UHE general costs – Emergency operational phases. events
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BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES (ESS6)
ESS6 ASPECTS Construction Phase – Vegetation clearance will be required where it is present in the areas of the arrays and battery storage. Construction zones, at some sites, are close to surface water features, although no construction works will occur in, or within 20 meters of any surface waters.
Operational Phase – There are no requirements for new overhead transmission lines, all cables will be below ground, or supported on existing cable infrastructure.
Pesticides will not be used during Project construction or operational phases.
ESS6 AREA OF INFLUENCE The AoI for biodiversity aspects for all sites generally comprises the construction and operational zones of the Project sites, but is increased with a 200m buffer to account for potential noise and air quality impacts to terrestrial fauna.
No construction or operational activities will occur in water bodies. Mitigation measures provided for storage of wastes and hazard liquids preclude impacts to surface water. As such, water bodies are excluded from ESS6 assessment and aquatic species were ruled out of the CHA.
ESS6 RECEPTORS The following potential receptors have been identified:
• Terrestrial habitat and terrestrial species • Avifauna.
ESS6 POTENTIAL IMPACTS
Conservation of Biodiversity and Habitats
Three of the five sub-project construction zones and the areas where equipment will be located are classified as modified habitat, including Kyiv PSP, Kremenchuck HPP and Dnistrovska HPP. Modified habitat is classified as “areas that may contain a large proportion of plant and/or animal species of non-native origin, and/or where human activity has substantially modified an area’s primary ecological functions and species composition.” Project works are not anticipated to have significant impacts to these areas.
Project works are also not anticipated to have significant impacts to freshwater habitat, due to the fact that the construction works are land based and set well back from surface waters. However, as a precautionary measure this ESMP comprises a number of mitigation and management measures to ensure that surface waters are not impacted significantly by the Project.
Potential areas of sensitive habitat have been identified at portions of Kaniv HPP and Seredniodniprovska HPP. In addition, mapping by the United Nations Environment Program has indicated that these sites are both close to ‘likely critical habitat’.
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To investigate the habitat status in more detail a CHA was undertaken to identify the species and habitats with high biodiversity value that both regularly occur in the Project’s Area of Influence (AoI) and trigger Critical Habitat thresholds. The assessment was desk-based and involved a review of data from the Integrated Biodiversity Assessment tool (IBAT) and other reliable data sources such as IUCN, GBIF, eBird and academic literature. This Critical Habitat Assessment has been produced in accordance with the IFC Performance Standard 6 (IFC PS 6) and Guidance note 6 (IFC GN6). The following summarises the key findings of the assessment which can be found in full in Appendix F. This section of the ESMP provides a summary of:
• Project Biodiversity Context for all sites • Critical Habitat Criterion 1 – Critically Endangered and Endangered Species • Critical Habitat Requirement 2 – Restricted Range Species • Critical Habitat Requirements 3 – Migratory or Congregatory species • Critical Habitat Requirement 4 – Highly threatened and/or unique ecosystems • Critical Habitat Requirement 5 – Key evolutionary processes • Conclusions
Biodiversity Context
Kyiv PSP - The AoI for this site is situated within modified dry grassland and scrubland habitat close to residential and industrial areas, with some deciduous and occasionally coniferous trees more than 3 meters in height. Patches of bare ground are frequent. It borders the upper reservoir of the Kyiv PSP engineered concrete banks. There are 4 protected areas or areas of national or international importance for nature conservation within 10km of the Kyiv PSP site, see Table 6.
Table 6: Protected areas within 10km of Kyiv PSP project site
Name Designation Distance Direction (km)
Kyivske Reservoir Emerald site 0.4 East
Kyivske Podesennia Emerald site 5 South East
Staropetrivs'ki sosnovi Unknown national 8 North West nasadzhennya designation
Holosiivskyi National Nature Park Emerald site 9 South West
Source: Project Critical Habitat Assessment
Kaniv HPP - The AoI is within largely modified dry grassland and scrubland, with occasional trees present towards the south west boundary. To the north east the AoI borders semi-natural forest. The AoI is adjacent to the edge of the large Kanivske reservoir to the north, which has engineered concrete banks along the length of the proposed development. To the south east is the Kremenchutske reservoir. There are 6 protected areas or areas of national or international importance for nature conservation within 10km of the Kaniv HPP site, Table 7.
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Table 7: Protected areas within 10km of Kaniv HPP project site
Name Designation Distance Direction (km)
Kanivske Reservoir Emerald site 0.1 North
Kremenchutske Reservoir Emerald site 0.1 South east
Tarasiv obriy State Zakaznik (reserve) 0.7 South east
Kanivs'kyi Nature Reserve IBA 2 South
Kanivs'kyi State Zapovednik (strictly 3 South protected area)
Kanivskyi Nature Reserve Emerald Site 3 South
Source: Project Critical Habitat Assessment
Kremenchuk HPP - The AoI is dominated by modified dry grassland and with scattered small trees and bushes. The AoI is adjacent to the edge of the large Kanivske reservoir to the west, which has engineered concrete banks along the length of the proposed development. To the east it is adjacent to a large residential area, with many rows of dachas. There are 3 protected areas or areas of national or international importance for nature conservation within 10km of the Kremenchuk HPP site. Table 8: Protected areas within 10km of Kremenchuk HPP project site
Name Designation Distance Direction (km)
Kremenchutske Reservoir Emerald site 0.1 West
Kremenchutski Plavni Regional Emerald site 4.5 East Landscape Park
Bilets'kivs'ki plavni State Zazanik 4.5 East
Source: Project Critical Habitat Assessment
Seredniodniprovska HPP - The AoI is within largely modified dry grassland and habitat, with some trees and bushes present. The AoI runs adjacent to the edge of the large Kamianske Reservoir to the West, which has non-natural concrete banks along the whole length of the proposed development. The northern part runs adjacent to a large residential area, with many rows of dachas to the East of the AoI, and the Southern part of the project is in a more industrial area, although there are some areas of more natural habitat present. There are 3 protected areas or areas of national or international importance for nature conservation within 10km of the Seredniodniprovska HPP site. Table 9: Protected areas within 10km of Seredniodniprovska HPP project site
Name Designation Distance (km) Direction
Kamianske Reservoir Emerald site 0.1 East
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Dniprovske Reservoir Emerald site 0.1 West
Dniprovs'ko-Oril's'kyj Nature IBA 8 North Reserve
Source: Project Critical Habitat Assessment
Dnistrovska HPP - The Dnistrovska site is located at the Dnister hydroplower plant on the Dnister river, where it borders a small buffer storage reservoir that has non-natural concrete banks along the whole length of the proposed development. The project site is mainly characterised as modified scrubland, with small trees and bushed although there are also stands of larger trees and some small wooded areas present. There are 5 protected areas or areas of national or international importance for nature conservation within 10km of the Dnistrovska HPP site, see Table 10.
Table 10: Protected areas within 10km of Dnistrovska HPP project site
Designation Distance Direction Name (Km)
Emerald site 0 N/A Khotynskyi National Nature Park Podilskyi Dnister Emerald site 4
Vasylivski i Rozkopynski gullies Emerald site 4
Chotiri topoli Regional Nature 9 South Monument
Platan skhidniy (chinar) Regional Nature 10 North Monument
Source: Project Critical Habitat Assessment
Critical Habitat Criterion 1 – Critically Endangered and Endangered Species
The screening process for Criterion 1 concluded that only 1 species has the potential to meet the IFC CH criteria and is assumed to regularly occur in the Project AoI. This is the globally Endangered Steppe Plump bush-cricket. IUCN data suggests that the Steppe Plump Bush Cricket is present in only four small sites globally, one being grassland in the Kaniv region. The other sites are in Russia.
There is no recent or reliable species abundance or distribution data for the Kaniv area but the species inhabits Mesophytic steppe grassland areas and grassland and shrubland are both present in the Kaniv AoI. With the data available its presence Figure 9: Steppe Plump Bush Cricket cannot be confidently determined. However, due to the site’s overlap (presented in Figure 7 of Appendix E) with the specie’s IUCN range and the presence of potentially suitable habitat it must be assumed to regular occur. Therefore, the AoI for the Kaniv site is within Critical Habitat for the Steppe Plump Bush Cricket.
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Critical Habitat Requirement 2 – Restricted Range Species
Only one restricted range species was identified within 50km of the 5 project sites, Nordmann’s birch mouse Sicista loriger. No other restricted range species were identified. This is not surprising as Ukraine does not have high rates of endemism compared to other geographic locations, with the majority of species widely distributed but rare across their range. Therefore, the project area does not contain Critical Habitat under Criterion 2.
Critical Habitat Requirements 3 – Migratory or Congregatory species
Three species present close to the one site (Kaniv) were identified as potentially meeting Critical Habitat thresholds. These are the Little Crake Zapornia parva, the Spotted Crake Porzana porzana and the Black-throated Diver Gavia arctica.
The Kanivske Reservoirs represents part of the breeding range of the Little Crake and Spotted Crake. Both species are fully migratory and migrate to areas of Africa and Asia to overwinter. The main habitats in the AoI are modified dry grassland and scrubland. Therefore, these species, although they may be present in high numbers in the Kanivske reservoir, are unlikely to occur regularly in the Kaniv AoI, but rather in more suitable natural habitats along other banks of this very large reservoir.
The Black throated diver or Arctic Loon Gavia arctica is an aquatic diving bird that feeds exclusively on aquatic prey, primarily fish. It breeds to the North of Ukraine in Scandinavia, northern Russia and the Arctic circle and migrates to overwinter in coastal sites further South, for example the Black and Mediterranean Seas. This species is found in Ukraine only in Passage, where it stops off on migration. During stop-offs in the Kanivske reservoir this species is very unlikely to leave the water, and therefore will not regularly occur within the AoI for the Kaniv site which is exclusively terrestrial.
The project area does not contain Critical Habitat under Criterion 3.
Critical Habitat Requirement 4 – Highly threatened and/or unique ecosystems
No IUCN red listed ecosystems are present in any of the AOIs for this project. Although the AoIs of 3 of the 5 sites overlap with Emerald sites designated under the Bern Convention, these sites have not been designated due to the presence of highly threatened or unique ecosystems, but rather to facilitate the long-term protection of the entire Dnipro river ecological corridor, which is an important stop-off and flyway for migratory waterbird species. Further, no priority habitat types listed in the Bern convention are known to occur within the AoIs, which represent modified grass and scrubland habitat types common in Ukraine and Eastern Europe. The species present in these Emerald sites have been appropriately assessed under Criteria 1, 2 and 3. Therefore, Critical Habitat is not triggered for Criterion 4.
Critical Habitat Requirement 5 – Key evolutionary processes
The IFC definition of critical habitat includes areas associated with key evolutionary processes. The IFC GN6 gives some guidance on this, stating that areas associated with Key evolutionary processes tend to have high spatial heterogeneity, which can lead to speciation via isolation or divergent evolution, or environmental gradients, also known as ecotones, which produce transitional habitat and are associated with the process of speciation. None of the AoIs for these projects contain habitats fitting these criteria, and indeed in are mainly within areas of modified habitat. The area is also not thought to provide key ecosystem services. The project area does not contain Critical Habitat under Criterion 5.
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Critical Habitat Conclusions
The project meets Critical Habitat Criterion 1 at one site, the Kaniv HPP. This is due to the likely presence of the globally Endangered species the Steppe Plump Bush cricket (Isophya stepposa). Although there is no data available to confirm that this species regularly occurs in the Kaniv AoI, it is assumed that it does under the precautionary approach as the habitat is suitable and the IUCN distribution map for the local population overlaps with the site.
Recent and reliable data is required to confidently confirm its regular presence in the AoI. Further surveys are therefore recommended, ideally during the design phase (The survey will also be expanded to encompass general biodiversity across the site). The preliminary methodology of the survey for Isophya stepposa is as follows (the preliminary methodology will be updated as needed):
1. Site survey by a specialist (Entomologist from I.I.Schmalhausen Institute of Zoology, Kiev) with recording of orthoptera sound communication using specialized recording equipment. 2. Schedule: mid-May 2021 - early July 2021 a. 1st visit – 2-3 days (the second week of May) b. 2nd visit – 3-5 days (the end of May) c. 3rd visit – 5 days (mid-June) 3. If Isophya stepposa is found at the first (or second) stage, the next visit (survey) will not be needed.
If Isophya stepposa is confirmed to regularly occur measures to ensure no net loss and preferably achieve a net gain in its nature conservation status will be required. Such measures could be achieved via a Biodiversity Management Plan (BMP) for this species or by avoiding species habitat alotogether, i.e. by altering the location of the infrastructure at site. However, if confirmed absent no further measures are likely necessary.
Recommendations in any BMP would likely require offsets in the form of creating / restoring similar habitat in nearby areas so that the total habitat available for the species is increased (~2x the areas removed/modified) or measurably enhanced. All species within the areas potentially affected can then be safely translocated to the areas of suitable habitat, and suitable monitoring plans should be put in place to establish the success of habitat creation and relocation.
Criteria for High Risk (which as noted above is ineligible for funding) includes a determination that any subproject could have a significant adverse impact on a Critical Habitat. Therefore WB must agree (based on the finding of the aforementioned biodiversity surveys (and any BMP), which will be disclosed and consulted with stakeholders including local biodiversity experts and environmental NGOs) that the potential impact can be readily and reliably avoided, or mitigated in a way which will lead to a Net Gain in biodiversity value, as set out in ESS6 before the subproject can be approved for funding.
Site Clearance of Vegetation
Regarding site clearance. Any trees with a trunk diameter of more than 10cm shall be replaced on a 1:3 ratio with the same species. Locations for replanting will be determined between UHE and the EPC Contractor. EPC Contractor will plant the trees within 1 month of cutting of the existing trees and maintain the trees for the duration of construction, after which UHE will be responsible for maintetance of the trees. The Supervision Consultant shall undertake routine monitoring of the re- planted areas and any dead trees will be replaced by the EPC Contractor. Tree cutting will be avoided during nesting periods and ideally undertaken during the winter.
Invasive Alien Species
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Sites cleared for installation of the solar arrays will be revegetated, especially those on the slopes of reservoir embankments. Accidental introduction of alien, or non-native, species of flora and fauna into areas where they are not normally found can be a significant threat to biodiversity, since some alien species can become invasive, spreading rapidly and destroying or out-competing native species. It is unlikely that such a scenario would occur as a result of the Project, however, the ESMP contains provisions to ensure that local species are used for revegetation.
Table 11: Biodiversity Impacts
Phase
Receptors
Magnitude
Probability
Timeframe
Significance
Spatial Spatial Scale
Consequence
Potential Impact Potential
Sensitivity of Receptors of Sensitivity No. of Receptors Affected Receptors of No.
C/O Impacts to critical habitat Local habitat L H M LT SMA M POS M
C/O Impacts to designated sites IBA / KBA and L H MA ST SMA M NEG NS nationally designated sites
C Invasive alien species Native species L L MI ST SMA L UN NS
Key: H: High / M: Medium / L: Low / MAJ: Major / MOD: Moderate / MIN: Minimum / H/F: High Frequency / M/F: Low Frequency / L/F: Low Frequency / LT: Long term / MT: Medium Term / ST: Short term / MED: Medium / DEF: Definitely / POSS: Possible: / UNLIKE: Unlikely. Cells shaded in blue are positive impacts.
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MITIGATION MEASURES
ESS Item Impact Management / Mitigation Measure Responsibility Cost Residual Impact
Conservation of Design – Critical 1.Surveys to determine the presence of the Local (Unkrainian) 4,000 USD for Survey Any BMP will be Biodiversity and habitat Steppe Plump Bush Cricket and any other special Zoologist, on designed to ensure at Habitats status species. behalf of UHE. 10,000 USD for BMP least no net loss of species. 2. Preparation of a species specific Biodiversity WB to review and Management Plan (BMP), if Steppe Plump Bush approve the Cricket is identified on site (or any other special survey findings status species). and BMP to ensure the project is not ‘high risk’
Construction – 1. Implementation of GIIP measures including: EPC Contractor Part of EPC Contractors general None land clearing and a. All areas to be cleared should be costs general precisely demarcated and work construction carried out only within those works areas. b. Appropriate training will be provided to workers regarding the identification of wildlife in the instance of chance encounters during site clearance and works. c. The collection or hunting of any birds and fish must be strictly prohibited. d. Project staff require environmental toolbox talks during construction to raise awareness, limit conflict
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ESS Item Impact Management / Mitigation Measure Responsibility Cost Residual Impact
and reduce additional disturbance to fauna and avifauna.
Construction – 1. Any trees with a trunk diameter of more • Tree cutting Saplings (5 USD per unit) None Tree Cutting than 10cm shall be replaced on a 1:3 ratio and with the same species. replanting 2. Plant trees within 1 month of cutting of the and existing trees and maintain the trees for the maitenance – duration of construction. EPC 3. Tree cutting avoiding nesting periods Contractor • Locations for replanting will be determined between UHE and the EPC Contractor.
Invasive Species Operation – Ensure that all revegetation uses only native EPC Contractor Included as part of ESA costs None spread of grasses. invasive species.
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CULTURAL HERITAGE (ESS8)
ESS8 ASPECTS Construction Phase - Construction works will involve the clearing the site and leveling of the land to allow the solar array to be constructed stably across the site. Ground mounting structures will be piled directly into soils. Shallow excavations may be required in areas accommodating battery storage and transformers and also to house below ground cables.
Operational Phase – WB ESF indicates that “Tangible cultural heritage….includes movable or immovable objects, sites, structures groups of structures, and natural features and landscapes that have archaeological, paleontological, historical, architectural, religious, aesthetic, or other cultural significance.” Siting of the Solar arrays could affect landscapes although they cannot specifically be described as being of aesthetic significance.
ESS8 AREA OF INFLUNCE The AoI for cultural heritage is the construction site areas.
ESS8 RECEPTORS All of the proposed sites are located within UHE property boundaries. No known PCR exists at these sites. The location of the work sites within these properties are on man-made structures, e.g. dams or on parts of the site that were previously cleared during the construction of the original HPPs. Therefore, it is unlikely that PCR is present below ground in these areas.
None of the planned sites have been identified as landscapes of specific cultural importance and none of the sites are located in areas that would be deemed important for tourism. At some sites, including Kiev PSP, Kremenchuk HPP and Serednednipro HPP, some homes and dachas are located around the boundary of the UHE sites. Most of the site bounadries comprise vegetation of bushes and trees which screen the UHE owned areas. However, other portions face directly towards the proposed array locations.
ESS8 POTENTIAL IMPACTS Legally Protected Cultural Heritage Areas - None present within the Project site boundaries.
Archeological Sites and Material - None known to exist within the Project site boundaries.
Kaniv archaeological survey is located close to the part of Lysukha Mountain which is planned for future Kaniv PSP (not part of this Project).
Consultation has been undertaken with the Department of Culture and Protection of Cultural Heritage of Cherkasy Regional State Administration to confirm the status of cultural heritage sites around Kaniv site. The department representative confirmed that “…. There are no known cultural heritage objects (according to the state record-keeping) within the land plots indicated. However, moving objects related to cultural heritage can be found during development of the land plots. So, if ancient fragments of utensils, bones, human remains, weapons, military equipment or ammunition, jewelry, coins, etc. are found during the works, these works must be stopped immediately and the report on the findings should be sent to the state body for cultural heritage protection…”. See Appendix B for correspondence letter.
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Given the above statement for Kaniv, and for all other sub-project sites, a chance find procedure will be adopted. The Procedures shall follow the national requirements as outlined below.
“1. If during the conducting of any land job archaeological or historical finds are discovered, the performer of job is obliged to stop their further conducting and during 24 hours to inform about this appropriate cultural heritage protection body and body of local government in the territory of which land job is conducted; 2. Land job may be renewed only according the written permission of appropriate cultural heritage protection body after completing of archeological research of appropriate territory.” 11
Built Heritage - None present within the Project site boundaries.
Natural Features with Cultural Significance - None present within the Project site boundaries.
Moveable Cultural Heritage - None present within the Project site boundaries.
Landscape - Property owners in areas overlooking planned infrastructure may have their existing views (comprising vacant UHE owned dam wall areas and transmission lines) altered by the new solar arrays.
Table 12: Cultural Heritage and Landscape Impacts
ce
Phase
Receptors
Magnitude
Probability
Timeframe
Significance
Spatial Spatial Scale
Consequen
Potential Impact Potential
Sensitivity of Receptors of Sensitivity No. of Receptors Affected Receptors of No.
C Archeological Sites and Unidentified L M M ST SMA M UN NS Material below ground PCR
O Landscape Local residents M M M LT SMA M POS M S
Key: H: High / M: Medium / L: Low / MAJ: Major / MOD: Moderate / MIN: Minimum / H/F: High Frequency / M/F: Low Frequency / L/F: Low Frequency / LT: Long term / MT: Medium Term / ST: Short term / MED: Medium / DEF: Definitely / POSS: Possible: / UNLIKE: Unlikely. Cells shaded in blue are positive impacts.
11 Article 36 “Suspense of land job in case of discovering or finds of archaeological or historical quality” of Law of Ukraine "On the Protection of Cultural Heritage" #1805-III of June 08, 2000: https://zakon.rada.gov.ua/laws/show/1805-14#Text
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MITIGATION MEASURES ESS Item Impact Management / Mitigation Responsibility Cost Residual Impact Measure
Archeological Sites Construction 1. Preparation and implementation of a Chance finds – EPC Chance finds – part of EPC None and Material – impacts to chance find procedure. Contractor general costs archeological 2. During construction, toolbox talks will sites be provided to ensure that workers will be alert to any signs of past cultural activity in the area.
Landscape Operation – 3. Natural screening by vegetation in Tree planting – EPC Lump sum – estimated at Low local locations requested by the local Contractor 10,000 USD for three sites. community community. aesthetics
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STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE (ESS10) A Stakeholder Engagement Plan (SEP) has been prepared for the Project. The SEP has been developed to meet all of the requirements of ESS10 including relevant requirements for information disclosure. Specifically the SEP:
• Provides guidance for stakeholder engagement such that it meets the standards of International Best Practice; • Identifies key stakeholders that are affected, and/or able to influence the Project and its activities; • Identifies the most effective methods, timing and structures through which to share project information, and to ensure regular, accessible, transparent and appropriate consultation; • Developed a stakeholder engagement process that provides stakeholders with an opportunity to influence project planning and design; • Established a formal grievance redress mechanisms (GRM); • Defined roles and responsibilities for the implementation of the SEP; • Defined reporting and monitoring measures to ensure the effectiveness of the SEP and periodical reviews of the SEP based on findings.
To date approximately 60 representatives of Project stakeholders (both from the Government and from civil society organisations) have taken part in the stakeholder engagement process. All comments and suggestions received from the stakeholders will be properly considered in the next steps of project preparation and implementation. Consultations will continue throughout project preparation, construction and operation in line with the requirements of the SEP. A grievance redress mechanism (GRM) has also been prepared and is outlined in full in a separate section below (and also in the SEP).
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MONITORING AND REPORTING The following table provides the monitoring plans for the construction phase of the Project and the required reporting elements.
For the design phase, no monitoring per se is required, rather UHE and WB should ensure that these measures are included in EPC Contractors designs and that activities such as reviewing dam safety reports are completed.
For the operational phase mitigation responsibilities lie with UHE as they generally relate to ensuring compliance with national regulations, existing UHE documentation and training programs.
Table 13: Construction Phase Monitoring Plan
ESS Mitigation Monitoring Monitoring Monitoring Monitoring Reporting Indicator / Schedule Responsibilities of Standard Monitoring Compliance
Ensure EPC Staff All staff above At the start of Supervision First Contractors contracts. legal working construction Consultant quarterly are within the age for phase. report to legal age for hazardous and PMU and WB work in line non hazardous with Labour works Law and ILO Conventions.
Prepare a Completed GRM Prior to the Supervision Quarterly GRM. GRM. approved and start of Consultant report to communicated construction, PMU and WB to all workers. and then for any new Workers workers. signed induction training documents confirming understanding of GRM.
Develop an Completed OHS plan Prior to the Supervision Quarterly OHS plan. OHS Plan. approved. start of Consultant report to construction. PMU and WB Plan in compliance with requirements of WBG EHS Guidelines.
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ESS Mitigation Monitoring Monitoring Monitoring Monitoring Reporting Indicator / Schedule Responsibilities of Standard Monitoring Compliance
Implementation OHS plan Copy of plan Throughout Supervision Quarterly of OHS Plan available at available at all construction Consultant report to site. work sites. PMU and WB
OHS Number of Throughout Supervision Quarterly incidents and incidents and construction Consultant report to accidents accidents and PMU and near misses. WB.
Fatalities and serious accidents reported immediately to PMU and WB
OHS Manager. OHS OHS Manager Throughout Supervision Quarterly Manager on on site during construction Consultant report to site working hours. PMU and WB.
Provide OHS Workers Workers Prior to the Supervision Quarterly induction to induction signed start of Consultant report to workers. completed. induction construction, PMU and WB training and then for documents any new confirming workers. understanding of OHS plan.
Regular OHS OHS talks At least one Throughout Supervision Quarterly talks to completed. OHS session construction Consultant report to workers. per week PMU and completed. WB.
First aid kits Inspection of Kits available Throughout Supervision Quarterly provided at all worksites at all worksites construction Consultant report to work sites. PMU and WB.
Appropriate Inspection of Appropriate Throughout Supervision Quarterly PPE. workers PPE PPE being construction Consultant report to work by all PMU and workers in line WB. with WBG
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ESS Mitigation Monitoring Monitoring Monitoring Monitoring Reporting Indicator / Schedule Responsibilities of Standard Monitoring Compliance
EHS Guidelines and national legislative requirements12
Supplier meets Review No forced Throughout Supervision Quarterly the suppliers /child labour in construction Consultant report to requirements signed the supply PMU and of ESS2. contracts chain. WB. which shall include statements that no child labour or forced labour is employed.
Salvage and Observations Topsoil Weekly Supervision Quarterly store topsoil of soil stripped and inspections Consultant report to and subsoil stockpiles. stockpiled PMU and before areas separately. WB. are excavated.
Exposed soils Observation Re-vegetation Upon Supervision Quarterly are revegetated of completed completed. completion of Consultant report to with local work sites. works. PMU and grasses. No invasive WB. species growth.
Only small Observation No large Weekly Supervision Quarterly volumes of oils at worksites storage inspections Consultant report to are used at containers PMU and construction present at WB. areas. work sites.
Hazardous Observation No spills and Weekly Supervision Quarterly liquids stored at worksites leaks of oils inspections Consultant report to within a secure bunded area.
12 Order of the Ministry of Social Policy of Ukraine “On Approval of the Minimum Health and Safety Requirements for the Use of Personal Protective Equipment by Employees at the Workplace” #1804 of November 29, 2018: https://zakon.rada.gov.ua/laws/show/z1494-18#Text Law of Ukraine “On Labor Protection” # 2694-XII of October 14, 1992: https://zakon.rada.gov.ua/laws/show/2694-12#Text (Article 8 “Providing employees with protective clothes, other personal protective equipment, detergents and disinfectants”).
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ESS Mitigation Monitoring Monitoring Monitoring Monitoring Reporting Indicator / Schedule Responsibilities of Standard Monitoring Compliance
Spill kits should outside of PMU and be provided. bunded areas. WB.
Contaminated Observation Waste transfer Weekly Supervision Quarterly soil disposed of at worksites. note for inspections Consultant report to as hazardous hazardous PMU and waste. waste removal. WB.
Toolbox Training At least one Throughout Supervision Quarterly training on completed. session per construction Consultant report to contaminated month PMU and soil. completed. WB.
Stationary Observations Sensitive Weekly Supervision Quarterly emission at worksites. receptors not inspections Consultant report to sources (e.g. affected by air PMU and mobile diesel emissions (e.g. WB. generators) smoke from positioned as tailpipes) far as practical from sensitive receptors.
Equipment and Review of Certified Six monthly Supervision Quarterly vehicles will be vehicle vehicles Consultant report to regularly inspection PMU and maintained. records WB.
No controlled Observations No burning at Weekly Supervision Quarterly or at worksites. the site. inspections Consultant report to uncontrolled PMU and burning of WB. waste.
Dust control Observations No significant Weekly Supervision Quarterly measures at worksites. dust inspections Consultant report to implemented, generation PMU and including water observed. WB. bowsers No complaints from local community.
Vehicle Observations No significant Weekly Supervision Quarterly movements at worksites. dust inspections Consultant report to restricted to
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ESS Mitigation Monitoring Monitoring Monitoring Monitoring Reporting Indicator / Schedule Responsibilities of Standard Monitoring Compliance
defined access generation PMU and routes and observed. WB. demarcated working areas. No complaints from local community.
Project speed Observations No significant Weekly Supervision Quarterly limit enforced. at worksites. dust inspections Consultant report to generation PMU and observed. WB.
No complaints from local community.
Vehicles Observations No significant Weekly Supervision Quarterly sheeted with at worksites. dust inspections Consultant report to tarpaulin to generation PMU and help prevent observed. WB. dust blow and spillages. No complaints from local community.
Earthworks Observations No significant Weekly Supervision Quarterly suspended at worksites. dust inspections Consultant report to when the wind generation PMU and speed exceeds observed. WB. 20 km/h in areas within No complaints 500 m of any from local community. community.
Adequate Observations No flooding of Weekly Supervision Quarterly drainage at worksites. worksites or inspections Consultant report to around the site. neighbouring PMU and lands. WB.
Construction Review Amount of Monthly Supervision Quarterly waste re-used waste waste review of Consultant report to and recycled manifests. recycled. records PMU and where possible. WB.
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ESS Mitigation Monitoring Monitoring Monitoring Monitoring Reporting Indicator / Schedule Responsibilities of Standard Monitoring Compliance
Waste Observation No Weekly Supervision Quarterly materials of waste construction inspections Consultant report to collected and storage waste around PMU and stored in waste areas. worksites or WB. containers neighbouring before disposal properties. to landfill by licensed contractors.
Hazardous Observation No hazardous Weekly Supervision Quarterly waste will be of waste construction inspections Consultant report to collected and storage waste around PMU and stored at work areas. worksites or WB. sites in suitable neighbouring containers properties. prior to disposal at licensed hazardous waste facilities.
Hazardous Observations No visible Weekly Supervision Quarterly liquids will not at worksites. signs of water inspections Consultant report to be stored pollution (e.g. PMU and within 50m of oily sheens on WB. any water water) close to course. work sites.
Broken panels Observations No waste Weekly Supervision Quarterly and other non- at worksites. panels inspections Consultant report to functioning observed PMU and equipment will around the WB. be returned to site. the supplier. Shipping notes to manufacturer.
Portable Observations At least one Weekly Supervision Quarterly toilets. at worksites. portable toilet inspections Consultant report to provided at PMU and each worksite. WB.
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ESS Mitigation Monitoring Monitoring Monitoring Monitoring Reporting Indicator / Schedule Responsibilities of Standard Monitoring Compliance
Hazardous Observations Per the Weekly Supervision Quarterly materials at worksites. requirement of inspections Consultant report to stored the MSDS. PMU and according to WB. their MSDS.
Access to the Observations No accidents Weekly Supervision Quarterly site strictly at worksites. involving public inspections Consultant report to controlled. at the work PMU and sites. WB.
Work Observations No work Weekly Supervision Quarterly undertaken in at worksites. activities at inspections Consultant report to daytime hours night. PMU and only. WB. No complaints from local community.
Mobile noise Observations Barriers Weekly Supervision Quarterly barriers will be at worksites. erected. inspections Consultant report to provided. PMU and No complaints WB. from local community.
Existing ERPs Review of ERP Approved. Prior to the Supervision Quarterly updated. ERP. start of Consultant report to construction. PMU and WB
Implementation Observations No impacts to Weekly Supervision Quarterly of a BMP (if at worksites. species inspections Consultant report to required) PMU and WB.
All areas to be Observations Work site Prior to the Supervision Quarterly cleared at worksites. demarcated. start of Consultant report to demarcated construction. PMU and WB and work carried out only within those areas.
Training Training At least one Throughout Supervision Quarterly provided completed. session per construction Consultant report to regarding the
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ESS Mitigation Monitoring Monitoring Monitoring Monitoring Reporting Indicator / Schedule Responsibilities of Standard Monitoring Compliance
identification of month PMU and wildlife. completed. WB.
The collection Observations No reports of Weekly Supervision Quarterly or hunting of at worksites. poaching from inspections Consultant report to any birds and local PMU and fish strictly authorities. WB. prohibited.
Ensure that all Observation No invasive Upon Supervision Quarterly revegetation of completed species completion of Consultant report to uses only native work sites. growth. works. PMU and grasses. WB.
Avoid tree Observations All trees cut During land Supervision Quarterly cutting during during before nesting clearance Consultant report to nesting periods nexting periods. PMU and periods WB.
Replanting of Routine Survival rate of Throughout Supervision Quarterly trees inspection of saplings construction Consultant report to replanted PMU and areas WB.
Preparation of Review of Chance Find Prior to the Supervision Quarterly a chance find Chance Find Procedure start of Consultant report to procedure. Procedure. approved. construction. PMU and WB
Implementation Observations Chance finds Throughout Supervision Quarterly of a chance find at worksites. recorded and construction Consultant report to procedure. reported. PMU and WB.
Toolbox talks Talks At least one Throughout Supervision Quarterly to ensure that completed. session per construction Consultant report to workers will be month PMU and alert to any completed. WB. signs of past cultural activity in the area.
Implementation Per the SEP Stakeholder Annually Supervision Quarterly of the SEP activities Consultant report to conducted PMU and according to WB. the SEP and
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ESS Mitigation Monitoring Monitoring Monitoring Monitoring Reporting Indicator / Schedule Responsibilities of Standard Monitoring Compliance
disclosed on UHE website
Implementation Regular Grievances Throughout Quarterly of the GRM review of received, construction report to grievances reported and PMU and received and closed out. WB. monitoring progress
INCIDENT RESPONSE Despite the measures recommended to manage environmental and social risks, incidents may occur. An incident in this context is an accident or negative event resulting from failure on the part of UHE (and their Contractors) to comply with Bank safeguards policies, or conditions that occur because of unexpected or unforeseen events during project implementation. Examples of incidents include: fatalities, serious accidents and injuries; social impacts from labor influx; sexual exploitation and abuse (SEA) or other forms of gender-based violence (GBV); major environmental contamination; loss of biodiversity or critical habitat; loss of physical cultural resources; and loss of access to community resources.
The World Bank has prepared an Environment and Social Incidents Response Toolkit (ESIRT) intended to assist Borrowers such as UHE to address incidents that occur during implementation of Bank’s projects.
ESIRT does not replace regular project supervision and reporting but has been prepared to help UHE respond when they learn of incidents during supervision, or at any other time.
This ESIRT is comprised of the following six steps under the incident management and reporting process:
• Step 1 Initial Communication • Step 2 Classification • Step 3 Notification • Step 4 Investigation • Step 5 Response • Step 6 Follow Up
UHE roles (including those of the EPC Contractor and SC and PMU) and responsibilities in incident response are outlined in each of the six steps provided in detail in Appendix E. ESIRT also contains a Section on Responses and Remedial Actions, where examples of possible responses by the Borrower to incidents are provided.
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IMPLEMENTATION, CAPACITY DEVELOPMENT AND TRAINING
This portion of the ESMP outlines its specific implementation requirements through all phases of the Project, from bid documentation through to operation. Requirements for any capacity building and training to implement the requirements are also outlined.
BID AND CONTRACT DOCUMENTS
BID DOCUMENTS The Bid Documents for the potential EPC Contractors will contain two sections relating to environmental issues, firstly a basic clause indicating that the EPC Contractor will be responsible for following the requirements of the ESMP. Secondly, the ESMP will be repeated in its entirety as an Annex to the Bid Documents so as the bidder is aware of his environmental requirements under the Project and help him put environmental costs to his proposal. Environmental cost items will be included in the Bill of Quantities.
CONTRACT DOCUMENTS The Contract Documents will follow a broadly similar pattern to the Bid Documents. It is not considered necessary to repeat the mitigation measures herewith verbatim in a list of environmental contract provisions, rather the Contract will specify that the EPC Contractor is responsible for implementation of the ESMP. Again, the ESMP will be included as an Annex to the contract so the EPC Contractor will be liable for any non-conformance with the ESMP.
ESMP IMPLEMENTATION RESPONSIBILITIES
PROJECT MANAGEMENT UNIT The Project Management Unit (PMU) of UHE is responsible for supervising the EPC Contractor and ESMP implementation for overall compliance with WB ESF requirements and project environment- related legal covenants. The PMU’s responsibilities include the following, but not limited to:
• Ensure the bidding documents of SC and EPC Contractor include all tasks as described in the this ESMP; • Obtaining all necessary government permits and license, including national EIA, for all civil works; • Preparing and submitting semi-annual environmental monitoring reports to UHE and WB for disclosure on their websites; • Reporting to WB of any non-compliance or breaches with WB ESF requirements in a timely manner and take corrective actions promptly – following ERSIT procedures; • Updating the ESMP in case of technical design changes or unanticipated impacts; • Establishing a Grievance Redress Mechanism (GRM) after the project effectivity and acting as the GRM secretary to make sure that the GRM is operational to effectively handle environmental and social concerns of project affected persons.
EPC CONTRACTOR
The EPC Contractor will be responsible for implementing construction phase mitigation measures. In order to implement the ESMP he will engage an Environmental, Social, Health and Safety Specialist (ES) 76
to implement and update (where required) the ESMP and to oversee and report on works throughout the contract period. The ES will be the EPC Contractors main focal point for all environmental, social, health and safety issues associated with the Project. The ES will be part-time member of staff on the EPC Contractors roster and should be on site at least one day per week. The required qualifications of the ES are as follows:
• Degree in environmental sciences and related expertise. • Fluent in English and Ukrainian. • Experience of at least two construction projects of a similar size and scale.
Specifically, the ES shall be responsible for:
• Identifying any areas of particular ecological sensitivity that may need to be avoided. • Implementation of the Biodiversity Management Plan (if required). • Translate mitigation requirements written in the ESMP into practical measures on the ground. • Advise in a timely manner as to how best to address changeable and less predictable situations on the ground from an ecological perspective (e.g., should new species be encountered). • Ensure that all staff are fully aware of the environmental sensitivities of the site and their responsibilities, as outlined in the management plans (e.g., via practical toolbox talks ahead of the construction). • Take field notes and photographs to demonstrate compliance with the management plans.
In addition, the ES will be responsible for the preparation of weekly environmental and social checklists and an environmental and social section of the EPC Contractor’s monthly progress reports that shall be submitted to the SC and PMU for review.
The monthly reports, which will include the weekly environmental checklists, shall contain sections relating to:
• General Progress of the Project. • Environmental Incidents, e.g., spills of liquids, accidents, etc. • Progress of any environmental initiatives, e.g., energy savings, recycling, etc. • Records of any environmental monitoring. • Conclusions and Recommendations.
The ES will also act as the Focal Person on-site for receiving and recording initial grievances in the GRM Log. The GRM process is described further in a separate section below.
EPC CONTRACTOR CONTROL OF RECORDS The list of records that must be available by the EPC Contractor for review must include:
• Work program and schedule; • Environmental permits and licenses; • List of equipment; • List of mitigation measures; • Route/program of construction material transportation; • Copies of correspondence related to environmental issues; • Waste disposal records; • Written designation of waste disposal sites and instructions for waste transportation from local authorities;
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• Log of material inventories and consumption; • Chance find records (if any); • Complaints register; • Incident register (environmental limits expedience forms, injuries records, etc.); • Records on remedial actions taken; • Equipment control and maintenance log; • Corrective and preventive action request records; • Training records.
These records shall be kept on-site by the Contractors ESHSO and available for inspection at any time.
SUPERVISION CONSULTANT (SC)
The SC will ensure the correct implementation of the ESMP, and all related documents. Prior to the commencement of works the SC shall be responsible for the following:
• Organize a training program for PMU staff (specifically the PMU Environmental and Social Health and Safety (ESHS) Specialist) on how the environmental aspects of the project will be monitored, giving emphasis on ESMP evaluation; compliance monitoring of construction activities and preparation of corresponding reports; supervision responsibilities and interaction with EPC Contractors; and documentation, resolution and reporting of non-compliance issues and complaints; • Provide guidance to the PMU ESHS Specialist on the environmental and social aspects of the project with emphasis on compliance monitoring and reporting; • Assist the PMU with establishing and operating the grievance redress mechanism, including creating a grievance chart which is to be updated on a weekly basis; • Develop the compliance monitoring system to be used during the construction period for monitoring the EPC Contractors' performance relative to environmental requirements, including the preparation of: (a) monitoring and corrective action forms and checklists, (b) inspection procedures, and (c) documentation procedures; • Conduct orientation sessions with the EPC Contractor on the compliance monitoring system to be used, notification of non-compliance, and the process of requiring contractors to implement corrective measures when necessary; and • Provide guidance to the EPC Contractor on how the ESMP will be implemented including: (a) requirements for each mitigation measure, and (b) implementation schedule of each mitigation measure taking into consideration the general requirement that no specific construction activity will be approved to be commenced if the associated mitigation measures for such activity are not ready before work commences.
During implementation of the works, the SC shall be responsible for the following:
• Supervise the implementation of the ESMP; • Evaluate the EPC Contractors' submitted works activities and schedules relative to the requirements of the ESMP; • Undertake monthly inspection, monitoring and reporting of construction sites and all construction- related facilities to assess the EPC Contractors’ compliance with the ESMP. • Monitor the EPC Contractors' compliance with health and safety, and labor requirements of the project as stipulated in the contract documents; • Monitor implementation of the BMP (if required);
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• Record non-conformance cases, inform EPC Contractor of improvements needed, respond to EPC Contractors’ proposals, prepare corrective action plans for EPC Contractor, and monitor their implementation; • Report any incidents to the PMU using the ERSIT procedures provides in Appendix E; • Assess and approve use of temporary construction areas identified during construction such as laydown areas, access roads, etc. • Include environmental and social monitoring in monthly monitoring reports for submission to the PMU; and • Draft semi-annual environmental and social safeguard monitoring reports, as required by WB.
Upon completion of the works the SC shall prepare a report on the Project's environmental and social compliance performance, including lessons learned that may help PMU in their environmental monitoring of future projects. The report will be an input to the overall project completion report.
The SC should retain the use of a team of an Environmental and Social Specialist (ISS) for the above mentioned tasks. Qualified with at least a Masters degree in environmental sciences or equivalent. Preferably ten years’ international experience in conducting environmental impact assessments and implementation of environment mitigation plans and/or monitoring implementation of environmental mitigation measures and health and safety plans during implementation of projects including renewable power activities.
IMPLEMENTATION SCHEDULE The schedule for key environmental and social activities is defined in the table below.
Table 14: ESMP Implementation Schedule
Item Action Schedule Responsibility
Bid Documents Inclusion of ESMP measures During preparation of bid UHE and requirements in bid documents. documents.
Contract Inclusion of ESMP measures During preparation of UHE Documents and requirements in SC and contract documents. EPC Contractor contracts.
Design Measures Biodiversity Site Survey for During Design Phase UHE, through a qualified Steppe Plump Bush Cricket local (Ukrainian) Zoologist
Biodiversity Action Plan During Design Phase local (Ukrainian) (depending on the results of Zoologist the above survey)
Inclusion of ESMP design During detailed design. EPC Contractor measures in the detailed design.
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Item Action Schedule Responsibility
Review of designs by SC and During detailed design. SC UHE PMU.
Construction Implementation of Continuous EPC Contractor Mitigation and construction phase ESMP Monitoring mitigation.
Monitoring of ESMP Daily EPC Contractor mitigation measures Monthly SC
Management of GRM Continuous EPC Contractor and PMU
Environmental and Social Weekly EPC Contractor Checklists
Environmental and Social Monthly EPC Contractor Reports Semi-annual SC
PMU Training Prior to the start of SC construction
Staff Training Continuous EPC Contractor
Decommissioning Decommissioning plan 6 months prior to UHE decommissioning of facilities.
CAPACITY DEVELOPMENT AND TRAINING To ensure that UHE PMU have adequate capacity to implement the Project it is recommended that a full-time ESHS Specialist is hired to manage the day to day environmental and social aspects of the Project across all five sites. The ESHS Specialist should have at least five years experience of environmental and social impact issues relating to renewable power projects. The ESHS Specialist will also be responsible for managing the Stakeholder Engagement Plan and the Labour Management Plan. The SC will provide a series of training sessions to the ESHS Specialist and PMU staff during the detailed design phase specifically relating to:
• World Bank ESF • General Monitoring Activities • Labour Management Procedures • Stakeholder engagement and grievance redress mechanisms • Occupational and Community Health and Safety • Waste Management • Biodiversity
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The EPC Contractor will also be responsible for routine training of their workers throughout construction. Training should be focused on the key aspects of the ESMP, e.g. health and safety and waste management.
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GRIEVANCE MECHANISM
DEFINITIONS OF THE GRM Transparency and accountability are core elements of the Project. For this purpose, the project will include a GRM. The goal of the GRM is to strengthen accountability to beneficiaries and to provide channels for project stakeholders to provide feedback and/or express grievances related to project supported activities. The GRM is a mechanism that allows for the identification and resolution of issues affecting the project. By increasing transparency and accountability, the GRM aims to reduce the risk of the project inadvertently affecting citizens/beneficiaries and serves as an important feedback and learning mechanism that can help improve project impact. The mechanism focuses not only on receiving and recording complaints but also on resolving them. While feedback should be handled at the level closest to the complaint, all complaints should be registered and follow the basic procedures set out in this chapter.
GRM SCOPE AND USE Scope - Grievance Redress Mechanism will be available for project stakeholders and other interested parties to submit questions, comments, suggestions and/or complaints, or provide any form of feedback on all project-funded activities.
GRM’s users - Project beneficiaries, project affected people (i.e. those who will be and/or are likely to be directly or indirectly affected, positively or negatively, by the project), as well as the broader citizenry can use the GRM for the above purposes (see Scope).
GRM’s management - The GRM is managed by UHE.
Submission of complaints - Complaints can be expressed at any time throughout project implementation.
GRM OVERVIEW AND STRUCTURE, COMMUNICATION AND PROCESS Citizens’ appeals, complaints and recommendations procedure is specified in the Law on Citizens’ Appeals and amendments to the latter through the 2015 amendment on Electronic Petitions. According to the mentioned law and Constitutional Article 40, the Project proposes the following channels through which stakeholders can make complaints regarding project-funded activities (items in red text considered to be COVID-19 suitable methods):
• By Email: UHE’s email addresses: o [email protected] • Through the following web page: o https://uhe.gov.ua/kontakty • Through the phone line: o +38 04596 58 450 • In writing to UHE: Sent to the address of: o Vyshgorod city, Vyshgorod district, Kyiv region, 07300, Ukraine • In person: o at the above addresses or at the addresses of delegated authority by the latter. • Other: o Written complaints to project staff (through project meetings) 82
The project shall ensure flexibility in the channels available for complaints, as well as ensure accessibility to the contact information for individuals who make complaints.
To this effect, in addition to the Grievance Form provided by the project (see Appendix B), citizens can also file their appeals in accordance with Article 5 of the Law of Ukraine On Citizens’ Appeals. In the latter case, the appeals filed by citizens should contain full name, place of residence, the issue of the question, comment, application, claim, statement, request or demand.
A written appeal should be signed and dated by the appealer (appealers). An appeal sent via e-mail to UHE noted above should contain an e-mail address or postal address or any other means of communication in order to answer the appeal. The use of electronic signature is not required for e-mail appeals.
ANONYMOUS COMPLIANTS In case of anonymous complaints, the complaining party can submit their complaint without personal details. Given that personal details are not provided, UHE will be unable to respond directly with the result of any complaint investigation. As such it will be the responsibility of the complaining party to follow up with UHE for further understand the progress and result of the investigation.
CONFIDENTIALITY AND CONFLICT OF INTEREST Confidentiality will be ensured in all instances, including when the person making the complaint is known. For this reason, multiple channels to make a complaint have been established and conflicts of interest will be avoided.
RECEIPT AND RECORDING OF COMPLAINTS UHEs Project Manager or ESHS Managers (according to the competence), receiving the complaint will complete the grievance form (see Appendix B) and will record the complaint in the Register of Complaints. Then, the complaint is to be submitted immediately to the tracking system for sorting and redirecting to the appropriate department responsible for investigating and addressing the complaint, or to staff if the complaint is related to a specific project activity.
The ESHS Manager will be responsible for determining who to direct the complaint to, whether a complain requires an investigation (or not), and the timeframe to respond to it.
When determining who will be the investigating officer, the ESHS Manager should ensure that there is no conflict of interest, i.e. all persons involved in the investigation process should not have any material, personal, or professional interest in the outcome and no personal or professional connection with complainants or witnesses.
Once the investigation process has been established, the ESHS Manager enters this data into the Register of Complaints.
The number and type of suggestions and questions should also be recorded and reported so that they can be analyzed to improve project communications.
INVESTIGATION Under Article 20 of the Law of Ukraine on Citizens’ Appeals, appeals are considered and resolved no later than one month from the date of its receipt, and immediately to those that do not require additional 83
study, but not later than 15 days from the date of its receipt. If issues raised in the appeal cannot be resolved within one month, the head of the body, enterprise, institution, organization, or his deputy define necessary time for its consideration, and report about it to the person who filed the appeal. At the same time the entire term for resolving issues raised in the appeal may not exceed forty-five days.
To process the grievance the person responsible for investigating the complaint will gather facts in order to generate a clear understanding of the circumstances surrounding the grievance. The investigation/follow-up can include site visits, review of documents and a meeting with those who could resolve the issue.
The results of investigation and the proposed response to the complainant will be presented for consideration to the ESHS Manager, who will decide on the course of action. Once a decision has been made and the complainant informed, the investigating specialist describes the actions to be taken in the grievance form, along with the details of the investigation and the findings and submits the response to UHE Senior Management for signing.
RESPONSE TO COMPLAINANT The complainant will be informed about the results of verification via letter or email, as received. The response shall be based on the materials of the investigation and, if appropriate, shall contain references to the national legislation.
The deadline for investigating the complaint may be extended by 30 working days by the ESHS Manager, and the complainant is to be informed about this fact, whether:
• additional consultations are needed to provide response to the complaint; • the complaint refers to a complex volume of information and it is necessary to study additional materials for the response.
REPORTING Regular updates on the GRM system will be available on the UHE web page.
UHE will provide information on the following as part of monthly reports to the World Bank:
• Status of establishment of the GRM (procedures, staffing, awareness building, etc.); • Quantitative data on the number of complaints received, the number that were relevant, and the number resolved; • Qualitative data on the type of complaints and answers provided, issues that are unresolved; • Time taken to resolve complaints; • Number of grievances resolved at the lowest level, raised to higher levels; • Any particular issues faced with the procedures/staffing or use; • Factors that may be affecting the use of the GRM/beneficiary feedback system; • Any corrective measures adopted.
FURTHER ACTIONS The GRM does not substitute for—and should not obstruct— judicial and administrative remedies, such as mediation or arbitration, which are necessary for disputes beyond the scope of the GRM. A key function of a GRM is to address emerging concerns before they reach a level that may warrant judicial
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or administrative proceedings. Stakeholders will therefore be able to appeal to the court in case if they are not satisfied with the results of grievance investigation.
WORLD BANK GRIEVANCE REDRESS SYSTEM Communities and individuals who believe that they are adversely affected by a WB supported project may submit complaints to the above project-level GRM or the WB’s Grievance Redress Service (GRS). The GRS ensures that complaints received are promptly reviewed in order to address project-related concerns. Project affected communities and individuals may submit their complaint to the WB’s independent Inspection Panel which determines whether harm occurred, or could occur, as a result of WB non-compliance with its policies and procedures. Complaints may be submitted at any time after concerns have been brought directly to the World Bank’s attention, and Bank Management has been given an opportunity to respond. For information on how to submit complaints to the World Bank’s corporate Grievance Redress Service (GRS), please visit: http://www.worldbank.org/en/projects-operations/products-and-services/grievance-redress-service
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APPENDIX A - IMPACT ASSESSMENT METHODOLOGY
ESMP follows a set format during the impact assessment process. As shown in the following flow chart and described further below.
Identification of Project Aspects
Identification of Sensitive Receptors
Identification of Potential Impacts that may Result from Project Aspects
Impact Significance Rating
Proposal of Mitigation, Management and Good Practice Measures
Identification of Remaining Residual Impacts
PROJECT ASPECTS Firstly, the main environmental and social aspects of the Project are noted. An environmental and social aspect is any activity of the Project that interacts with the physical and/or social environment. E.g., an aspect of the Project that may impact upon air quality will be the movement of vehicles on unpaved roads through rural settlements.
IDENTIFICATION OF SENSITIVE RECEPTORS Once the main aspects of the Project have been identified any sensitive receptors within the Project area of influence are noted. Examples of sensitive receptors include; local residents, UHE staff, rivers, groundwater, avifauna, etc. Identification of receptors is a key part of the impact assessment process as without a receptor there will be no impact. For example, if a road generates significant noise but there are no sensitive receptors who can hear the noise, then there will be no noise impact.
IDENTIFICATION OF SIGNIFICANT ENVIRONMENTAL AND SOCIAL ASPECTS
Thirdly, the potential impacts of the identified aspects are outlined and how they could impact upon the identified receptors, in the case above, this could be the movement of a construction vehicle creating dust on an unpaved road which impacts upon local villagers.
The significance of an impact is determined based on the product of the consequence of the impact and the probability of its occurrence. The consequence of an impact, in turn, is a function primarily of three impact characteristics:
• magnitude
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• spatial scale • timeframe
Magnitude is determined from quantitative or qualitative evaluation of a number of criteria including:
• Sensitivity of existing or reasonably foreseeable future receptors. • Importance value of existing or reasonably foreseeable future receptors, described using the following: • inclusion in government policy. • level of public concern. • number of receptors affected. • intrinsic or perceived value placed on the receiving environment by stakeholders. • economic value to stakeholders.
Severity or degree of change to the receptor due to impact, measured qualitatively or quantitatively, and through comparison with relevant thresholds:
• legal thresholds—established by law or regulation • functional thresholds if exceeded, the impacts will disrupt the functioning of an ecosystem sufficiently to destroy resources important to the nation or biosphere irreversibly and/or irretrievably • normative thresholds – established by social norms, usually at the local or regional level and often tied to social or economic concerns • preference thresholds—preferences for individuals, groups or organizations only, as distinct from society at large • reputational thresholds—the level of risk a company is willing to take when approaching or exceeding the above thresholds
Spatial scale is another impact characteristic affecting impact consequence. The spatial scale of impacts can range from localized (confined to the proposed Project Site) to extensive (national or international extent). They also may vary depending on the component being considered.
The impact timeframe is the third principal impact characteristic defining impact consequence and relates to either its duration or its frequency (when the impact is intermittent). Impact duration can range from relatively short (less than four years) to long (beyond the life of the Project). Frequency ranges from high (more than 10 times a year) to low (less than once a year). These timeframes will need to be established for each Project based on its specific characteristics and those of the surrounding environment.
Once the impact consequence is described on the basis of the above impact characteristics, the probability of impact occurrence is factored in to derive the overall impact significance. The probability relates to the likelihood of the impact occurring, not the probability that the source of the impact occurs. For example, a continuous Project activity may have an unlikely probability of impact if there are no receptors within the area influenced by that activity. The characteristics are outlined in the table below.
Table 15: Characteristics Used to Describe Impact
Terms Used to Describe the Characteristic Sub-components Impact
Type Positive (a benefit), negative (a cost) or neutral
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Terms Used to Describe the Characteristic Sub-components Impact
Nature Biophysical, social, cultural, health or economic
Direct, indirect or cumulative or induced
Phase of the Project Construction and operation.
Magnitude Sensitivity of Receptor High, medium or low capacity to accommodate change
High, medium or low conservation importance
Vulnerable or threatened Rare, common, unique, endemic
Importance or value of receptor High, medium or low concern to some or all stakeholders
High, medium or low value to some or all stakeholders (for example, for cultural beliefs)
Locally, nationally or internationally important
Protected by legislation or policy
Severity or degree of change to Gravity or seriousness of the change the receptor to the environment
Intensity, influence, power or strength of the change
Never, occasionally or always exceeds relevant thresholds
Spatial Scale Area affected by impact – Area or Volume boundaries at local and regional covered Distribution Local, regional, extents will be different for transboundary or global biophysical and social impacts
Timeframe Length of time over which an Short term or long environmental impact occurs or term Intermittent (what frequency) frequency of impact when or continuous Temporary or intermittent permanent
Immediate effect (impact experienced immediately after causative project aspect) or delayed effect (effect of
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Terms Used to Describe the Characteristic Sub-components Impact
the impact is delayed for a period following the causative project aspect)
Probability – likelihood or chance an impact will occur Definite (impact will occur with high likelihood of probability)
Possible (impact may occur but could be influenced by either natural or project related factors)
Unlikely (impact unlikely unless specific natural or Project related circumstances occur)
IMPACT SIGNIFICANCE RATING
The impact significance rating process serves two purposes: firstly, it helps to highlight the critical impacts requiring consideration in the approval process; secondly, it serves to show the primary impact characteristics, as defined above, used to evaluate impact significance. The impact significance rating system is presented in Table 16 and described as follows:
Part A: Define impact consequence using the three primary impact characteristics of magnitude, spatial scale and duration.
Part B: Use the matrix to determine a rating for impact consequence based on the definitions identified in Part A; and
Part C: Use the matrix to determine the impact significance rating, which is a function of the impact consequence rating (from Part B) and the probability of occurrence.
Using the matrix, the significance of each described impact is rated.
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Table 16: Method for Rating Significance
PART A: DEFINING CONSEQUENCE IN TERMS OF MAGNITUDE, DURATION AND SPATIAL SCALE
Definition Criteria MAGNITUDE Negative Positive Major • Large number of receptors affected • Large number of receptors affected • Receptors highly sensitive and/or are of • Receptors highly amenable to positive change conservation importance • Receptors likely to experience a big • Substantial deterioration, nuisance or harm to improvement in their situation receptors expected • Relevant positive thresholds often exceeded • Relevant thresholds often exceeded • Significant public concern expressed during stakeholder consultation • Receiving environment has an inherent value to stakeholders Moderate • Some receptors affected • Some receptors affected • Receptors slightly sensitive and/or of moderate • Receptors likely to experience some conservation importance improvement in their situation • Measurable deterioration, nuisance or harm to • Relevant positive thresholds occasionally receptors exceeded • Relevant thresholds occasionally exceeded • Limited public concern expressed during stakeholder consultation • Limited value attached to the environment Minor • No or limited receptors within the zone of • No or limited receptors affected impact • Receptors not sensitive to change • Receptors not sensitive to change • Minor or no improvement in current situation • Minor deterioration, nuisance or harm to • Change not measurable receptors • Relevant positive thresholds never exceeded No • Change not measurable or relevant thresholds stakeholder comment expected never exceeded • Stakeholders have not expressed concerns regarding the receiving environment TIMEFRAME Duration of Continuous Aspects Frequency of Intermittent Aspects
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Short term / low • Less than 4 years from onset of impact • Occurs less than once a year frequency Medium term / medium • More than 4 years from onset of impact up to • Occurs less than 10 times a year but more than frequency end of life of project (approximately 30 years) once a year Long term / high • Impact is experienced during and beyond the life • Occurs more than 10 times a year frequency of the project (greater than 30 years) SPATIAL SCALE Biophysical Socio-economic Small • Within the defined ‘Project area’ • Within the defined ‘Project area Intermediate • Within the district in which is the facilities are • Within the municipality in which the activity located occurs Extensive • Beyond the district in which the facilities are • Beyond the municipality in which the activity located occurs
PART B: DETERMINING CONSEQUENCE RATING MAGNITUDE TIMEFRAME SPATIAL SCALE Small Intermediate Extensive Minor Short term / low frequency Low Low Medium Medium term / medium frequency Low Low Medium Long term / high frequency Medium Medium Medium
Moderate Short term / low frequency Low Medium Medium Medium term / medium frequency Medium Medium High Long term / high frequency Medium High High
Major Short term / low frequency Medium Medium High Medium term / medium frequency Medium Medium High Long term / high frequency High High High PART C: DETERMINING SIGNIFICANCE RATING CONSEQUENCE Negligible Low Medium High PROBABILITY (of Definite Not Significant Low Medium High exposure to impacts) Possible Not Significant Low Medium High Unlikely Not Significant Low Low Medium Negligible Not Significant Not Significant Not Significant Not Significant
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MITIGATION, MANAGEMENT AND GOOD PRACTICE MEASURES Wherever the Project is likely to result in unacceptable impact on the environment, mitigation measures are proposed (over and above the inherent design measures included in the Project description). In addition, good practice measures may be proposed however these are unlikely to change the impact significance. In the case of positive impacts, management measures are suggested to optimize the benefits to be gained.
The following mitigation hierarchy will be utilized in selecting practical mitigation measures for unacceptable impacts as follows (in order of preference):
• Avoid the impact wherever possible by removing the cause(s). • Reduce the impact as far as possible by limiting the cause(s). • Ameliorate the impact by protecting the receptor from the cause(s) of the impact.
Providing compensatory measures to offset the impact, particularly where an impact is of high significance and none of the above are appropriate.
RESIDUAL IMPACTS Once mitigation measures are declared and committed to, the next step in the impact assessment process is to assign residual impact significance. This is essentially a repeat of the impact assessment steps discussed above, considering the assumed implementation of the additional declared mitigation measures.
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APPENDIX B - CORRESPONDANCE
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APPENDIX C - POLICY, LEGAL AND REGULATORY FRAMEWORK
THE LEGAL, REGULATORY AND POLICY FRAMEWORK The Ukrainian legislative and regulatory framework on environmental, social, labor occupational health and safety (OHS) issues includes international conventions, protocols and agreements ratified by the Verkhovna Rada of Ukraine, Laws of Ukraine, Decrees and Orders of the Cabinet of Ministers of Ukraine (CMU), orders of ministries, various norms, procedures, standards and guidelines, regulatory framework, approved by CMU regulations and ministry orders. In order to become effective, each regulatory act must be registered by the Ministry of Justice of Ukraine.
There are numerous by-laws of government bodies (Ministries, state agencies, state inspections, public services and other central government bodies), which determine the powers of the relevant state body and procedures for environmental protection, social protection, access to information, etc.
Certain aspects of environmental protection are also regulated by the relevant legislative provisions contained in other parts of the country's legislation (civil law, water code, land code, administrative law, criminal law, etc.). More specifically, these provisions define the nature and limits of penalties and disciplinary rules, as well as the administrative, material and criminal liability applicable to the offender of environmental standards and related to the harm caused by the offender, environmental risk and severity of the negative consequences.
The Ukrainian legislative and regulatory base which governs environmental and social aspects is quite comprehensive, sophisticated and in places contradictory.
An overview of the legal framework of Ukraine in the field of environmental protection, occupational health and safety, and public issues is presented below.
• The Law of Ukraine “On Environmental Protection, #1264-XII, adopted on June 25, 1991: https://zakon.rada.gov.ua/laws/show/1264-12#Text; • The Law of Ukraine “On Environmental Impact Assessment”, #2059-VIII, adopted on May 23, 2017: https://zakon.rada.gov.ua/laws/show/2059-19#Text; • The Law of Ukraine “On Strategic Environmental Impact Assessment”, #2354-VIII, adopted on March 20, 2018: https://zakon.rada.gov.ua/laws/show/2354-19#Text ; • The Law of Ukraine “On Protection of Atmospheric Air”, #2707-XII, adopted on October 16, 1992: https://zakon.rada.gov.ua/laws/show/2707-12#Text; • The Resolution of the Cabinet of Ministers of Ukraine "On Some Issues of State Monitoring in the Field of Atmospheric Air Protection", #827 of August 14, 2019: https://zakon.rada.gov.ua/laws/show/827-2019-%D0%BF#Text; • The Water Code of Ukraine (initial Law #213/95-ВР adopted on June 6, 1995): https://zakon.rada.gov.ua/laws/show/213/95-%D0%B2%D1%80#Text; • The Law “On National Target Program of Water Management and Environmental Rehabilitation of the Dnipro River for the Period till 2021”, # 4836-VI, adopted on May 24, 2012: https://zakon.rada.gov.ua/laws/show/4836-17#Text; • The Resolution of the Cabinet of Ministers of Ukraine “On Statement of Rules on Protection of Surface Waters from Pollution by Wastewater”, #465 of March 25, 1999: https://zakon.rada.gov.ua/laws/show/465-99-%D0%BF#Text;
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• The Order of the Ministry of Regional Development, Construction, Housing and Municipal Facilities validating the Regulation “On Acceptance of Effluent Wastewater (Sewage) to Centralized Sewerage Systems and Calculation of Charges for Excessive Discharge of Effluent Waste Water (Sewage) to Centralized Drainage System”, #316 of January 1, 2017: https://zakon.rada.gov.ua/laws/show/z0056-18#Text; • The Resolution of the Cabinet of Ministers of Ukraine Regulation “On Approval of the Procedure for Issuing Permits for Special Water Use and Amendments to the Resolution”, #321 of March13, 2002: https://zakon.rada.gov.ua/laws/show/321-2002-%D0%BF#Text; • The Law of Ukraine “On the Fauna”, #2894-III, adopted on December 2001: https://zakon.rada.gov.ua/laws/show/2894-14#Text; • The Law of Ukraine “On the Flora”, #591-XIV, adopted on April 9, 1999: https://zakon.rada.gov.ua/laws/show/591-14#Text; • The Law of Ukraine “On the Red Data Book of Ukraine”, #3055-III, adopted on February 7, 2002: https://zakon.rada.gov.ua/laws/show/3055-14#Text; • The Law of Ukraine “On the Environmental Network of Ukraine”, #1864-IV, adopted on June 24, 2004: https://zakon.rada.gov.ua/laws/show/1864-15#Text; • The Law of Ukraine “On the Nature Reserve Fund of Ukraine”, #2456-XII, adopted on June 6, 1992: https://zakon.rada.gov.ua/laws/show/2456-12#Text; • The Law of Ukraine “On the Participation in the Convention on Wetlands of International Importance especially as Waterfowl Habitat”, # 437/96-ВР, adopted on October 29, 1996: https://zakon.rada.gov.ua/laws/show/437/96-%D0%B2%D1%80#Text; • The Law of Ukraine “On Ensuring Sanitary and Epidemiological Well-being of the Population”, #4004-XII, adopted on February 4, 1994: https://zakon.rada.gov.ua/laws/show/4004-12#Text; • The Order of Ministry of Health of Ukraine “On the Adoption of the State Sanitary Norms for the Noise Impact for Residential and Public Premises and in Residential Areas”, #463 of February 22, 2019: https://zakon.rada.gov.ua/laws/show/z0281-19#Text; • The Law of Ukraine "On Amendments to Some Legislative Acts of Ukraine to Protect the Population from Exposure to Noise", #1745-IV, adopted on June 3, 2004: https://zakon.rada.gov.ua/laws/show/1745-15#Text; • The Law of Ukraine “On Waste”, #187/98-BP, adopted on March 5, 1998: https://zakon.rada.gov.ua/laws/show/187/98-%D0%B2%D1%80#Text; • The Law of Ukraine “On Urban Planning Activities”, #3038-VI, adopted on February 17, 2011: https://zakon.rada.gov.ua/laws/show/3038-17#Text; • The Law of Ukraine "On the Protection of Cultural Heritage" #1805-III of June 08, 2000: https://zakon.rada.gov.ua/laws/show/1805-14#Text; • The Law of Ukraine ‘’On Land Protection”, # 962-IV, adopted on June 19, 2003: https://zakon.rada.gov.ua/laws/show/962-15#Text; • The Law of Ukraine “On State Control of Land Use and Protection”, # 963-IV of June 19, 2003: https://zakon.rada.gov.ua/laws/show/963-15#Text; • The Order of Ministry of Agricultural Policy of Ukraine “On Approval of the Regulation on Soil Monitoring on Agricultural lands”, #51, of February 26, 2004: https://zakon.rada.gov.ua/laws/show/z0383-04#Text; • The Law of Ukraine “On Access to Public Information”, #2939-VI, adopted on January 13, 2011: https://zakon.rada.gov.ua/laws/show/2939-17#Text; • The Law of Ukraine "On the List of Permitting Documents in the Sphere of Economic Activity", #3392-VI adopted on May 19, 2011: https://zakon.rada.gov.ua/laws/show/3392-17#Text; • The Labor Code of Ukraine (initial Law #322-VIII adopted on December 10, 1971): https://zakon.rada.gov.ua/laws/show/322-08/stru; • The Law “On Ensuring Equal Rights and Opportunities for Women and Men”, # 2866-IV, adopted on September 8, 2005: https://zakon.rada.gov.ua/laws/show/2866-15#Text;
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• The Law of Ukraine “On Leaves”, #504/96-BP adopted on November 15, 1996: https://zakon.rada.gov.ua/laws/show/504/96-%D0%B2%D1%80#Text; • The Law of Ukraine “On Remuneration of Labor”, #108/95-BP adopted on March 24, 1995: https://zakon.rada.gov.ua/laws/show/108/95-%D0%B2%D1%80#Text; • The Law of Ukraine “On Trade Unions, Their Rights and Guarantees of Activity”, # 1045-XIV, adopted on September 15, 1999: https://zakon.rada.gov.ua/laws/show/1045-14#Text; • The Law of Ukraine “On Labour Safety”, #2694-XII adopted on October 14, 1992: https://zakon.rada.gov.ua/laws/show/2694-12#Text . • Order of the Ministry of Social Policy of Ukraine “On Approval of the Minimum Health and Safety Requirements for the Use of Personal Protective Equipment by Employees at the Workplace” #1804 of November 29, 2018: https://zakon.rada.gov.ua/laws/show/z1494-18#Text; • The Order of Ministry of Regional Development, Construction, Housing and Communal Services “Drafting of Project Documentation for the Construction” #45 of May 16, 2011: https://zakon.rada.gov.ua/laws/show/z0651-11#Text; • DBN A.2.2-1-2003 “Composition and content of environmental impact assessment (EIA) materials for the design and construction of enterprises, buildings and structures” with Amendment №1 approved on November 20, 2009, in force since July 1, 2010: https://dbn.co.ua/load/normativy/dbn/1-1-0-242; • DBN A.2.2-3-2014 "Composition and content of design documentation for construction": https://dbn.co.ua/load/normativy/dbn/dbn_a_2_2_3_2014/1-1-www0-1168.
The key environmental laws of Ukraine are discussed below.
The Constitution of Ukraine, as the starting point of the entire legal framework, according to which every citizen has the right to a safe and healthy environment and to compensation for damage caused by violation of this right.
Everyone is guaranteed the right of free access to information on the state of the environment, the quality of food and household goods, as well as the right to disseminate it. Such information may not be kept secret by anyone. (Article 50, CC).
The Law of Ukraine "On Environmental Protection" is the basis for comprehensive regulation of public relations in the field of protection, use and reproduction of natural resources, ensuring environmental safety, prevention and elimination of negative impact of economic and other activities on the environment, conservation of natural resources, genetic fund of living nature, landscapes and other natural complexes, unique territories and natural objects associated with historical and cultural heritage.
The main principles of environmental protection are the priority of environmental safety requirements, the obligation to comply with environmental standards, standards and limits for the use of natural resources in the implementation of economic, management and other activities, guaranteeing an environmentally safe environment for human life and health, the obligation to evaluate environmental impact, publicity and democracy in decision making, the implementation of which affects the state of the environment.
Relations in the field of environmental protection in Ukraine are regulated by this Law, as well as land, water, forest legislation, legislation on subsoil, on the protection of atmospheric air, on the protection and use of flora and fauna and other special legislation.
The Law of Ukraine "On Environmental Impact Assessment" (hereinafter referred to as the EIA Law) came into force on December 18, 2017. This law introduces a new European model of the
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Environmental Impact Assessment (EIA) procedure instead of the abolished Environmental Expertise in order to approximate European standards. The Law sets legal and organizational policies for an environmental impact assessment (EIA/OVD) with a view to avoid and prevent environmental damage, ensure environmental safety, environmental protection, rational use and restoration of natural resources, in the process of decision-making on economic activities likely to cause a significant impact on the environment, taking into account state, public and private interests.
The EIA Law provides the list of planned activities (any construction, reconstruction, modernization etc.) which are subject to a mandatory environmental impact assessment procedure (article 3 of the Law).
The project contains three components: i) battery storage facilities; ii) solar arrays; iii) grid connection facilities (transformers, cables, etc.). The EIA law does not require OVD for solar PV projects, however the issue is not so definite for other project components
Regarding national EIA procedures; the regulations are unclear as to the level of assessment required for this type of project. On the one hand, the Project generally falls within Category II of planned activities and objects [facilities] that may have a significant impact on the environment and are subject to EIA according to the EIA Law, Article 3, part 3, paragraph 14) “Expansions and changes on planned activities, reconstruction / rehabilitation, technical re-equipment” referring to all other paragraphs of said part 3, including paragraph 4) “Energy Sector”. In that general case, an OVD (national EIA procedure) might be required for the Project, except for its solar PV component.
However, on the other hand, based on a sub-law regulation corresponding to the above-mentioned EIA Law, Article 3, part 3, paragraph 14)13 that provides for a detailed list of exemptions, given that the Project does not require any change of designated land (as the Project is planned to be implemented within land used for energy sector purposes – primarily, hydropower plant sites and protection zones), and neither has it a significant impact on the environment, the Project may be acknowledged as the one not subject to EIA. Accordingly, the exact requirements for the national EIA process will be determined as part of the preparation of the project design documents (so-called TEO) in accordance with national requirements and standards.
However, OVNS (‘оцінка впливу на навколишнє середовище’), (translated as EIA), should be a part of the project documentation and is needed at the stage of preparation of the Ukrainian Feasibility Study. This OVNS/EIA section should be made according to the Ukrainian national construction regulation (DBNs). It is more limited in scope than the case of OVD.
DBN A.2.2-1-2003 "Composition and content of materials for environmental impact assessment (EIA) in the design and construction of enterprises, buildings and structures" with Amendment №1 approved on November 20, 2009, in force since July 1, 2010. These building codes determine the procedure for the development of environmental impact assessment materials (OVNS/EIA) as part of the project documentation for new construction, expansion, reconstruction and technical re-equipment of industrial and civil facilities, the basic requirements for the composition and content of these materials.
DBN A.2.2-3-2014 "Composition and content of design documentation for construction". The norms determines the composition and content of project documentation for new construction, reconstruction, overhaul and technical re-equipment of houses, buildings, structures of any purpose,
13 CMU Resolution December 13, 2017, No. 1010 “on approval of criteria for determining the planned activities that are not subject to EIA as well as the criteria for detrmining expansions and changes in activities and facilities that are not subject to EIA”
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their complexes or their parts, linear objects of engineering and transport infrastructure. There are references to the DBN in the Order of Ministry of Regional Development, Construction, Housing and Communal Services “Drafting of Project Documentation for the Construction” #45 of May 16, 2011.
The Law of Ukraine "On Regulation of Urban Planning Activity" establishes the legal and organizational foundations of urban planning activity and aims at ensuring the sustainable development of territories taking into account state, public and private interests.
This law is the key that regulates all types of construction work, specifies what documentation should be prepared for different types of construction projects by different classes of consequences (responsibility) and how the examination of such documentation is conducted.
CONSTRUCTION REGULATIONS The legal framework related to construction and operation of energy facilities comprises: (1) regulations related to planning and construction, and (2) regulations related to energy production.
Regulations related to planning and construction
• Obtaining the urban planning conditions and restrictions – Urban planning and architecture authority (organizational unit of the district state administration or executive committee of the city council); • Obtaining technical specifications (a set of conditions and requirements to engineering support of the construction project which must comply with its design parameters, in particular those related to water, heat, electric power and gas supply, sewage, radio broadcasting, outdoor lighting, waste water disposal, telephone networks, telecommunications, building management systems, fire protection and technogenic safety) – The specifications are provided by the authorities responsible for engineering support of the construction project (water, heat, electric power and gas supply, sewage, outdoor lighting, telephone networks, fire protection and technogenic safety, etc.); • Negotiations on location and construction of facilities with actual height exceeding 50 meters – Ministry of Defense, State Aviation Authority, Ukrainian State Air Traffic Services Enterprise; • Preparation of design specifications and estimates (Feasibility Study, Project, Detailed Design Documentation, Financial Estimate) pursuant to State Construction Standards (SCS) А.2.2–3–2014 "Composition and content of design documentation for construction"; • Conducting a (comprehensive) expert review regarding integrity, reliability and durability of structures, their operational safety and engineering support; public sanitation and disease control; labor protection; ecology; fire protection and technogenic safety; energy saving and energy efficiency budget component of project construction – Expert organizations which have a special professional certification; • Registration of a notice on commencement of preparatory works – State Inspectorate for Architecture and Construction Control or its local office; • Obtaining a permit to perform construction works (for facilities of CС2 and CС3 class of consequences) – State Inspectorate for Architecture and Construction Control or its local office.
Regulations related to energy production:
• Filing an application for obtaining a license for electric power generation to National Commission for State Regulation of Energy and Public Utility Services (NEURC); • Issuance of a license for electric power generation (NEURC); • Filing an application for membership in the Wholesale Electric Power Market (the "WEM") with the Wholesale Market Board;
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• Admission to the Wholesale Electric Power Market – The Wholesale Market Board; • Signing "The Agreement between Participants in the Wholesale Electric Power Market in Ukraine" dated 15 November 1996; • Providing information on availability of ASKOE, types of metering devices, level of accuracy of the system of electricity and other information foreseen by p. 2.1.6. Agreement between Participants in the Wholesale Electric Power Market in Ukraine (15 November 1996).
OCCUPATIONAL HEALTH AND SAFETY The Ukrainian legal framework on labor protection and OHS is advanced. The Constitution of Ukraine stipulates the right for labor and for opportunity to earn for living by performing jobs that were chosen freely (article 43). The article 43 of the Constitution guaranties safe and healthy occupational environment, wages not lower that determined by the Law; prohibits employment of women and minors for occupations that pose health hazards. Also, the article 43 stipulates citizens’ protection from unlawful dismissal from a job and stipulates timely remuneration for completed job. The right of employees to go on strike is also guaranteed by the Constitution (article 44). The Article 45 of constitution guaranties the right for breaks, leaves and rest. The social protection to workers is also guaranteed by Article 46 of the Constitution.
The Law of Ukraine “On Labour Safety” defines the basic provisions for the implementation of the constitutional right of employed citizens to ensure occupational health in the course of their employment, as well as to proper, safe and healthy working conditions. In addition to many other provisions of the law, employees must receive training in occupational health and safety, as well as personal protective equipment. In the case of industrial accidents, the law provides that the employer is obliged to organize investigations and keep records in accordance with the procedure established by the CMU Resolution (No. 1232 of 30.11.2011).
Law of Ukraine “On Protection of Populations and Territories from Technogenic and Natural Emergencies”, this Law defines the organizational and legal bases of protection of citizens of Ukraine, foreigners and stateless persons who are in the territory of Ukraine, protection of objects of industrial and social purpose, environment from of man-made and natural emergencies.
In addition, the various building codes, sanitary standards and norms should be taking into account when the renovation of buildings are considered. Some relevant of the state building codes of Ukraine, sanitary rules and industry regulations are listed below:
• DBN A.3.2-2-2009 OSBP “Occupational Safety and Industrial Safety in Construction. Substantive provisions": https://dbn.co.ua/load/normativy/dbn/dbn_a322_2009/1-1-0-945; • DBN В.2.6-33:2008 “Construction of Buildings and Structures. Construction of Envelope with exterior heat insulation. Requirements for Design, Installation and Operation”: https://dbn.co.ua/load/normativy/dbn/1-1-0-257; • DBN В.2.6-31:2006 “Construction of Buildings and Structures. Thermal Insulation of Buildings: https://dbn.co.ua/load/normativy/dbn/1-1-0-13; • DBN B.1.2-7-2008 “Basic Requirements for Buildings and Structures. Fire Security": https://dbn.co.ua/load/normativy/dbn/1-1-0-86; • DBN B.1.2-9-2008 ‘Basic Requirements for Buildings and Structures. Safety of Operation”: https://dbn.co.ua/load/normativy/dbn/1-1-0-91; • DBN B.1.2-10-2008 “Basic Requirements for Buildings and Structures. Noise protection”: https://dbn.co.ua/load/normativy/dbn/1-1-0-995; • DBN B.1.1-31: 2013 "Protection of Territories, Buildings and Structures from Noise": https://dbn.co.ua/load/normativy/dbn/zakhist_vid_shumu/1-1-0-1814;
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• DBN A.2.2-1-2003 “Composition and content of environmental impact assessment (EIA) materials for the design and construction of enterprises, buildings and structures” with Amendment №1 approved on November 20, 2009, in force since July 1, 2010: https://dbn.co.ua/load/normativy/dbn/1-1-0-242. • DBN A.2.2-3-2014 "Composition and Content of Design Documentation for Construction": https://dbn.co.ua/load/normativy/dbn/dbn_a_2_2_3_2014/1-1-0-1168. • The Order of Ministry of Regional Development, Construction, Housing and Communal Services “Drafting of Project Documentation for the Construction” #45 of May 16, 2011: https://zakon.rada.gov.ua/laws/show/z0651-11#Text. • DSTU-N БB.1.1-27: 2010 "Building Climatology": https://dbn.co.ua/load/normativy/dstu/dstu_b_v_1_1_27_2010/5-1-0-929; • DSTU-N БB.1.1-33: 2013 "Guidance on the Calculation and Design of Noise Protection of Rural areas" - NAPS A.01.001-14 "Rules for Fire Safety in Ukraine": http://docs.dbn.co.ua/7947_1583178495697.html; • DSN 3.3.6.039-99 "State Sanitary Standards of Industrial General and Local Vibration": https://zakon.rada.gov.ua/rada/show/va039282-99#Text; • DSanPiN 2.2.4-171-10 "Hygienic Requirements for Drinking Water Intended for Human Consumption": https://zakon.rada.gov.ua/laws/show/z0452-10#Text.
SOCIAL PROTECTION FRAMEWORK
SOCIAL PROTECTION AND LABOR STANDARDS Ukraine is a member state of the International Labour Organization (ILO) since 1954 (as part of the former USSR) and since 1991 as an independent state. Ukraine has ratified 71 ILO International Labour Standards (Conventions), including the eight fundamental and four priority Conventions. The government plans to ratify 8 more ILO Conventions to comply with the Europe Social Charter. Social protection, safety and labor standards are governed by the following sets of laws:
• The Law of Ukraine “On Mandatory State Social Unemployment Insurance”, #1533-III, adopted on March 2, 2000: https://zakon.rada.gov.ua/laws/show/1533-14#Text; • The Law of Ukraine “On State Social Aid to Indigent Families”, #1768-III, adopted on June 1, 2000: https://zakon.rada.gov.ua/laws/show/1768-14#Text; • The Law of Ukraine “On State Aid to Families with Children”, adopted on November 21, 1992: https://zakon.rada.gov.ua/laws/show/2811-12#Text; • The Law of Ukraine “On Ensuring Equal Rights and Opportunities for Women and Men”, #2866- IV, adopted on September 8, 2005: https://zakon.rada.gov.ua/laws/show/2866-15#Text; • The Law of Ukraine “On General Mandatory State Social Insurance Against Industrial Accident and Occupational Disease Which Caused Disablement”, #№ 2240-III, adopted on September 23, 1999”: https://zakon.rada.gov.ua/laws/show/2240-14#Text; • The Law of Ukraine “On Vocational Education”, # 103/98-ВР, adopted on February 2, 1998: https://zakon.rada.gov.ua/laws/show/103/98-%D0%B2%D1%80#Text; • The Resolution of the Cabinet of Ministers of Ukraine “On Calculating the Average Wage (Income, Cash Collateral) to Calculate the Payments on Mandatory State Social Insurance”, #1266, adopted on September 26, 2001: https://zakon.rada.gov.ua/laws/show/1266-2001-%D0%BF#Text; • The Law of Ukraine “On Compulsory State Social Insurance Against Temporary Disability and Covering Costs Related to Childbirth and Funeral Needs”, # 2240-III, adopted on January 18, 2001: https://zakon.rada.gov.ua/laws/show/2240-14#Text;
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• The Law of Ukraine “On Mandatory State Pension Insurance”, # 1058-IV (2003), amended in 2004- 2012: https://zakon.rada.gov.ua/laws/show/1058-15#Text.
ACCESS TO INFORMATION AND PUBLIC PARTICIPATION IN UKRAINIAN LEGISLATION With respect to the Ukrainian citizens’ right to participate in the administration of state affairs and in all local referendums is granted by the Constitution of Ukraine, Articles 38. Article 40 of the Constitution also enables all citizens to file individual or collective petitions, or to personally appeal to bodies of state power, bodies of local self-government, and to the officials and officers of these bodies. People’s rights relating to access to information, consultation and engagement is further recognized in three Ukrainian legislative and regulatory acts.23
The first constitutes the Law of Ukraine “On Access to Public Information”, #2939-VI, adopted on January 13, 2011, the second, Law “On Appeals”, #47 of 1996, and the third is vested in the Order of the Cabinet of Ministers of Ukraine “Order of the Public Consultations on the Issues of Development and Implementation of the State Policy”, #996 of November 3, 2010. The Law of Ukraine “On Access to Public Information”, #2939-VI, adopted on January 13, 2011, determines procedures for exercising and securing the right of every person’s access to information of public interest possessed by government agencies and other providers of public information as identified by this Law. In Article 3 the law also stipulates guarantees of observance where providers’ obligation to: (i) provide and disclose information; (ii) to establish special information services and/or systems within information providing entities to secure access to public information in accordance with the established procedures; (iii) to simplify procedures for submission of requests and receipt of information; (iv) free access to open sessions of government agencies; (v) parliamentary, civil, and state control over observance of the right to access to public information and information access modes; (vi) legal responsibility for violation of the legislation on access to public information.
The Law of Ukraine “On Appeals”, #47 of 1996, further grants Ukrainian citizens the right “to apply to state bodies, local self-government, associations of citizens, enterprises, institutions, organizations regardless of ownership, mass media, officials according to their functional responsibilities with comments, complaints and proposals concerning their statutory activities, a statement or petition for the exercise of their socio-economic, political and personal rights and legitimate interests, and a complaint about their violation.”
The Law of Appeals was reinforced in 2015 by the citizens’ right to file electronic petitions on corresponding portals instituted for this purpose by the President Administration, Parliament, the Government (“central authorities”), and hundreds of local bodies of self-government (“local authorities”).
The last, third decree of the Cabinet of Ministers of Ukraine ensures that the public is consulted on the issues of development and implementation of state policies.
RELEVANT REGULATIONS AND STANDARDS
The following section presents the relevant Project standards.
AMBIENT AIR QUALITY STANDARDS
The following table presents the ambient air quality standards for Ukraine, European Union (EU) and World Bank Group (WBG).
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Table 17: Ambient Air Quality Standards
Parameter Ukraine WBG EU Ambient Averaging period Maximum Guideline Air Quality Permissible Value Guidelines value*
Sulphur dioxide (SO2) 350 350 1hr μg/m3 125 20 125 24hr
Nitrogen dioxide (NO2) 200 200 200 1hr μg/m3 40 40 40 1 year
Particulate matter (PM10) 50 50 50 24 hr μg/m3 40 1 year
Particulate matter (PM2,5) 25 10 25 1 year μg/m3
Ozone (O3) 120 100 120 Daily max.average 8 hr(2) μg/m3
*Source: The Resolution of the Cabinet of Ministers of Ukraine "On Some Issues of State Monitoring in the Field of Atmospheric Air Protection", #827 of August 14, 2019 (based on Directive 2008/50/EC of the European Parliament and of the Council “On Ambient Air Quality and Cleaner Air for Europe” of May 21, 2008).
The ambient air quality sampling for the Project will be assessed against national regulations (CMU Resolution "On Some Issues of State Monitoring in the Field of Atmospheric Air Protection and DSP 201-97).
WATER QUALITY STANDARDS Ambient water quality – according to the national legislation: the Resolution of the Cabinet of Ministers of Ukraine “On Statement of Rules on Protection of Surface Waters from Pollution by Wastewater”, #465 of March 25, 1999, and the Order of the Ministry of Regional Development, Construction, Housing and Municipal Facilities validating the Regulation “On Acceptance of Effluent Waste Water (Sewage) to Centralized Sewerage Systems and Calculation of Charges for Excessive Discharge of Effluent Waste Water (Sewage) to Centralized Drainage System”, #316 of January 1, 2017, as in the table below:
Table 18: Requirements to the composition and properties of wastewater in Ukraine
Indicators Unit The maximum allowable value of the indicator and (or) concentration pH pH 6,5-9
Biological Oxygen Demand Mg/l 15 (BOD)
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Indicators Unit The maximum allowable value of the indicator and (or) concentration
Chemical Oxygen Demand Mg/l 80 (COD)
Total Nitrogen Mg/l 50
Total Phosphorus Mg/l 5
Oil and Grease Mg/l 10
Source: The Resolution of the Cabinet of Ministers of Ukraine “On Statement of Rules on Protection of Surface Waters from Pollution by Wastewater”, #465 of March 25, 1999, and the Order of the Ministry of Regional Development, Construction, Housing and Municipal Facilities validating the Regulation “On Acceptance of Effluent Waste Water (Sewage) to Centralized Sewerage Systems and Calculation of Charges for Excessive Discharge of Effluent Waste Water (Sewage) to Centralized Drainage System”, #316 of January 1, 2017.
Effluent Discharge is within the legal requirements of the Resolution of the Cabinet of Ministers of Ukraine Regulation “On Approval of the Procedure for Issuing permits for Special Water Use and Amendments to the Resolution”, #321 of March 13, 2002, and the Order of the Ministry of Regional Development, Construction, Housing and Municipal Facilities validating the Regulation “On Acceptance of Effluent Waste Water (Sewage) to Centralized Sewerage Systems and Calculation of Charges for Excessive Discharge of Effluent Waste Water (Sewage) to Centralized Drainage System”, #316 of January 1, 2017.
The WBG provides guidelines values for effluent discharge. The following table provides these values with which the Project shall comply, for example relating to water discharge from construction camps.
Table 19: Indicative Values for Treated Sanitary Sewage Discharges
Pollutant Unit Guideline Value pH pH 6-9 BOD Mg/l 30 COD Mg/l 125 Total Nitrogen Mg/l 10 Total Phosphorus Mg/l 2 Oil and Grease Mg/l 10 Total Suspended Solids Mg/l 50 Total Coliform Bacteria MPNA / 100 ml 400
A – MPN = Most Probable Number
Surface Water Quality and Groundwater Project Standards – Any required baseline and construction phase water quality monitoring will be assessed against national standards.
Wastewater Discharge Project Standards - Waste water discharge from construction sites and camps shall be assessed against WBG values (for any treated sanitary sewage discharge).
NOISE STANDARDS
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Admissible noise standards of the WBG and the Order of Ministry of Health of Ukraine “On the Adoption of the State Sanitary Norms for the Noise Impact for Residential and Public Premises and in Residential Areas”, #463 of February 22, 2019.
Table 20: Ukrainian Standards for Noise Levels
Receptor Noise level (dBA)
Daytime Night-time
Residential premises 40 30
Office premises 50 50
Source: The Order of Ministry of Health of Ukraine “On the Adoption of the State Sanitary Norms for the Noise Impact for Residential and Public Premises and in Residential Areas”, #463 of February 22, 2019.
For WBG, noise impacts should not exceed the levels presented in Помилка! Джерело посилання не знайдено. or result in a maximum increase in background levels of 3 dB at the nearest receptor location off site.
Table 21: WBG Noise Level Guidelines
Receptor One-hour Laeq (dBA)
Daytime Night-time
07.00-22.00 22.00 – 07.00
Residential; institutional; 55 45 educational
Industrial; commercial 70 70
For workplace noise the following WBG standards are applicable.
Table 22: WBG Work Environment Noise limits
Type of Work, workplace EBG General EHS Guidelines Heavy Industry (no demand for oral 85 Equivalent level Laeq,8h communication) Light industry (decreasing demand for oral 50-65 Equivalent level Laeq,8h communication)
Project Noise Standards - For baseline monitoring, and construction and operational phase noise assessment, Ukrainian value will be followed. For workplace noise, WBG guidelines shall be followed.
VIBRATION STANDARDS
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The German Standard DIN 4150-3 – Vibration in Buildings – Part 3: Effects on structures provides short term and long-term limits 14 for vibration at the foundation for various structures (see Table 23). This standard is considered international best practice.
Table 23: Guideline Values for Vibration Velocity to be Used When Evaluating the Effects of Short-term and Long-term Vibration on Structures
Group Type of structure Guideline Values for Velocity (mm/s)
Short-term Long-term
At foundation Uppermost Uppermost Floor Floor
Less than 50 to 100 All All 10 Hz to 50 Hz 10 Hz Hz frequencies frequencies
Buildings used for commercial purposes, 1 industrial buildings and 20 20 to 40 40 to 50 40 10 buildings of similar design
Residential dwellings 5 2 and buildings of similar 5 to 15 15 to 20 15 5 (105 dB) design and/or use (105 dB)
Structures that because of their particular sensitivity to vibration, do not correspond to 3 3 those listed in Lines 1 or 2 to 8 8 to 10 8 2.5 (99.0 dB) 2 and have intrinsic (100.5 dB) value (e.g. buildings that are under a preservation order)
Source: DIN 4150-3, Structural Vibration, Part 3: Effect of vibration on structures
DIN 4150-3 notes that “experience has shown that if these values are complied with, damage that reduces the serviceability of the building will not occur. If damage nevertheless occurs, it is to be assumed that other causes are responsible. Exceeding the value in the table does not necessarily lead to damage”.
The relevant national legislation is the Law of Ukraine "On Protection of the Population from the Harmful Effects of Noise, Vibration and Other Physical Factors", #1745-IV, adopted on June 3, 2004, and DSN 3.3.6.039-99 "State Sanitary Standards of Industrial General and Local Vibration".
14 short-term vibrations are defined as those that do not occur often enough to cause structural fatigue and do not produce resonance in the structure being evaluated and long-term vibrations are all the other types of vibration.
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Project Vibration Standards - German Standard DIN 4150-3 will be followed during the construction phase.
SOIL QUALITY Soil quality indicators and soil protection measures are part of the national environmental legislation:
• The Law of Ukraine ‘’On Land Protection”, # 962-IV, adopted on June 19, 2003: https://zakon.rada.gov.ua/laws/show/962-15#Text; • The Law of Ukraine “On State Control of Land Use and Protection”, # 963-IV of June 19, 2003: https://zakon.rada.gov.ua/laws/show/963-15#Text; • The Order of Ministry of Agricultural Policy of Ukraine “On Approval of the Regulation on soil Monitoring on Agricultural lands”, #51, of February 26, 2004: https://zakon.rada.gov.ua/laws/show/z0383-04#Text. • DSTU 7843: 2015 Soil quality. The Procedure for Creating a Network of Objects for Monitoring Soil of Agricultural Lands: http://online.budstandart.com/ua/catalog/doc-page.html?id_doc=62725.
WORLD BANK GROUP ENVIRONMENTAL, HEALTH & SAFETY GUIDELINES The Environmental, Health, and Safety (EHS) Guidelines 15are technical reference documents with general and industry-specific examples of Good International Industry Practice (GIIP). When one or more members of the World Bank Group are involved in a project, these EHS Guidelines are applied as required by their respective policies and standards. These General EHS Guidelines are designed to be used together with the relevant Industry Sector EHS Guidelines which provide guidance to users on EHS issues in specific industry sectors.
The following EHS Guidelines shall be considered for use during the Project:
• Environmental o Air Emissions and Air Quality (Construction phase) o Wastewater and Ambient Water Quality (Construction phase) o Hazardous Materials Management (Construction and Operational phase) o Waste Management (Construction and Operational phase) o Noise (Construction phase) • Occupational Health and Safety o General Facility Design and Operation o Communication and Training o Physical Hazards o Personal Protective Equipment (PPE) • Community Health and Safety o Emergency Preparedness and Response • Construction and Decommissioning o Environment o Occupational Health and Safety o Community Health and Safety
OTHER RELEVANT WORLD BANK DOCUMENTS
15 https://www. .org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/sustainability-at-ifc/policies-standards/ehs-guidelines
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The World Bank developed Good practice notes that the Borrower is obliged to apply appropriate level of performance or measures referred in the Good practice notes for the subproject activities during preparation of subproject documentation as well as during its implementation.
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Good Practice Notes:
Note Web link Reference in ESMP
Addressing Sexual Exploitation http://pubdocs.worldbank.org/en/741681582580194727/ESF-Good-Practice-Note-on-GBV-in- Mitigation Measures for Labour and and Abuse/Sexual Harassment Major-Civil-Works-v2.pdf Working Conditions
Gender Based Violence http://documents1.worldbank.org/curated/en/399881538336159607/Environment-and-Social- Mitigation Measures for Labour and Framework-ESF-Good-Practice-Note-on-Gender-based-Violence-English.pdf Working Conditions
Non-Discrimination and http://documents1.worldbank.org/curated/en/573841530208492785/Environment-and-Social- Mitigation Measures for Labour and Disability Framework-ESF-Good-Practice-Note-on-Disability-English.pdf Working Conditions
Non-Discrimination: Sexual http://pubdocs.worldbank.org/en/590671570796800429/Good-Practice-Note-SOGI.pdf Mitigation Measures for Labour and Orientation and Gender Working Conditions Identity
Environment and Social N/A – See Appendix D Appendix D Incident Response Toolkit for Borrowers
World Bank Guidance on N/A – See Appendix E Appendix E COVID-19 Considerations in Construction/Civil Works Projects
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APPENDIX D – COVID-19 GUIDELINES FOR EPC CONTRACTOR
(a) ASSESSING WORKFORCE CHARACTERISTICS
• The Contractor should prepare a detailed profile of the project work force, key work activities, schedule for carrying out such activities, different durations of contract and rotations (e.g. 4 weeks on, 4 weeks off). • This should include a breakdown of workers who reside at home (i.e. workers from the community), workers who lodge within the local community and workers in on-site accommodation (i.e. workers camp). Where possible, it should also identify workers that may be more at risk from COVID-19, those with underlying health issues or who may be otherwise at risk. • Consideration should be given to ways in which to minimize movement in and out of site. This could include lengthening the term of existing contracts, to avoid workers returning home to affected areas, or returning to site from affected areas. • Workers accommodated on site should be required to minimize contact with people near the site, and in certain cases be prohibited from leaving the site for the duration of their contract, so that contact with local communities is avoided. • Consideration should be given to requiring workers lodging in the local community to move to site accommodation (subject to availability) where they would be subject to the same restrictions. • Workers from local communities, who return home daily, weekly or monthly, will be more difficult to manage. They should be subject to health checks at entry to the site and at some point, circumstances may make it necessary to require them to either use accommodation on site or not to come to work.
(b) ENTRY/EXIT TO THE WORK SITE AND CHECKS ON COMMENCEMENT OF WORK
Entry/exit to the work site should be controlled and documented for both workers and other parties, including support staff and suppliers. Possible measures may include:
• Establishing a system for controlling entry/exit to the site, securing the boundaries of the site, and establishing designating entry/exit points (if they do not already exist). Entry/exit to the site should be documented. • Training security staff on the (enhanced) system that has been put in place for securing the site and controlling entry and exit, the behaviors required of them in enforcing such system and any COVID -19 specific considerations. • Training staff who will be monitoring entry to the site, providing them with the resources they need to document entry of workers, conducting temperature checks and recording details of any worker that is denied entry. • Confirming that workers are fit for work before they enter the site or start work. While procedures should already be in place for this, special attention should be paid to workers with underlying health issues or who may be otherwise at risk. Consideration should be given to demobilization of staff with underlying health issues. • Checking and recording temperatures of workers and other people entering the site or requiring self-reporting prior to or on entering the site. • Providing daily briefings to workers prior to commencing work, focusing on COVID-19 specific considerations including cough etiquette, hand hygiene and distancing measures, using demonstrations and participatory methods.
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• During the daily briefings, reminding workers to self-monitor for possible symptoms (fever, cough, other respiratory symptoms) and to report to their supervisor or the COVID-19 focal point if they have symptoms or are feeling unwell. • Preventing a worker from an affected area or who has been in contact with an infected person from returning to the site for 14 days or (if that is not possible) isolating such worker for 14 days. • Preventing a sick worker from entering the site, referring them to local health facilities if necessary or requiring them to isolate at home for 14 days.
(c) GENERAL HYGIENE
Requirements on general hygiene should be communicated and monitored, to include:
• Training workers and staff on site on the signs and symptoms of COVID-19, how it is spread, how to protect themselves (including regular handwashing and social distancing) and what to do if they or other people have symptoms (for further information see WHO COVID-19 advice for the public). • Placing posters and signs around the site, with images and text in local languages. • Ensuring handwashing facilities supplied with soap, disposable paper towels and closed waste bins exist at key places throughout site, including at entrances/exits to work areas; where there is a toilet, canteen or food distribution, or provision of drinking water; in worker accommodation; at waste stations; at stores; and in common spaces. Where handwashing facilities do not exist or are not adequate, arrangements should be made to set them up. Alcohol based sanitizer (if available, 60-95% alcohol) can also be used. • Review worker accommodations, and assess them in light of the requirements set out in IFC/EBRD guidance on Workers’ Accommodation: processes and standards, which provides valuable guidance as to good practice for accommodation. • Setting aside part of worker accommodation for precautionary self-quarantine as well as more formal isolation of staff who may be infected (see paragraph (f)).
(d) CLEANING AND WASTE DISPOSAL
Conduct regular and thorough cleaning of all site facilities, including offices, accommodation, canteens, common spaces. Review cleaning protocols for key construction equipment (particularly if it is being operated by different workers). This should include:
• Providing cleaning staff with adequate cleaning equipment, materials and disinfectant. • Review general cleaning systems, training cleaning staff on appropriate cleaning procedures and appropriate frequency in high use or high-risk areas. • Where it is anticipated that cleaners will be required to clean areas that have been or are suspected to have been contaminated with COVID-19, providing them with appropriate PPE: gowns or aprons, gloves, eye protection (masks, goggles or face screens) and boots or closed work shoes. If appropriate PPE is not available, cleaners should be provided with best available alternatives. • Training cleaners in proper hygiene (including handwashing) prior to, during and after conducting cleaning activities; how to safely use PPE (where required); in waste control (including for used PPE and cleaning materials). • Any medical waste produced during the care of ill workers should be collected safely in designated containers or bags and treated and disposed of following relevant requirements (e.g., national, WHO). If open burning and incineration of medical wastes is necessary, this should be for as limited a duration as possible. Waste should be reduced and segregated, so that only the smallest amount of waste is incinerated (for further information see WHO interim guidance on water, sanitation and waste management for COVID-19).
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(e) ADJUSTING WORK PRACTICES
Consider changes to work processes and timings to reduce or minimize contact between workers, recognizing that this is likely to impact the project schedule. Such measures could include:
• Decreasing the size of work teams. • Limiting the number of workers on site at any one time. • Changing to a 24-hour work rotation. • Adapting or redesigning work processes for specific work activities and tasks to enable social distancing, and training workers on these processes. • Continuing with the usual safety trainings, adding COVID-19 specific considerations. Training should include proper use of normal PPE. While as of the date of this note, general advice is that construction workers do not require COVID-19 specific PPE, this should be kept under review (for further information see WHO interim guidance on rational use of personal protective equipment (PPE) for COVID-19). • Reviewing work methods to reduce use of construction PPE, in case supplies become scarce or the PPE is needed for medical workers or cleaners. This could include, e.g. trying to reduce the need for dust masks by checking that water sprinkling systems are in good working order and are maintained or reducing the speed limit for haul trucks. • Arranging (where possible) for work breaks to be taken in outdoor areas within the site. • Consider changing canteen layouts and phasing meal times to allow for social distancing and phasing access to and/or temporarily restricting access to leisure facilities that may exist on site, including gyms. • At some point, it may be necessary to review the overall project schedule, to assess the extent to which it needs to be adjusted (or work stopped completely) to reflect prudent work practices, potential exposure of both workers and the community and availability of supplies, taking into account Government advice and instructions.
(f) PROJECT MEDICAL SERVICES
Consider whether existing project medical services are adequate, taking into account existing infrastructure (size of clinic/medical post, number of beds, isolation facilities), medical staff, equipment and supplies, procedures and training. Where these are not adequate, consider upgrading services where possible, including:
• Expanding medical infrastructure and preparing areas where patients can be isolated. Guidance on setting up isolation facilities is set out in WHO interim guidance on considerations for quarantine of individuals in the context of containment for COVID-19). Isolation facilities should be located away from worker accommodation and ongoing work activities. Where possible, workers should be provided with a single well-ventilated room (open windows and door). Where this is not possible, isolation facilities should allow at least 1 meter between workers in the same room, separating workers with curtains, if possible. Sick workers should limit their movements, avoiding common areas and facilities and not be allowed visitors until they have been clear of symptoms for 14 days. If they need to use common areas and facilities (e.g. kitchens or canteens), they should only do so when unaffected workers are not present and the area/facilities should be cleaned prior to and after such use. • Training medical staff, which should include current WHO advice on COVID-19 and recommendations on the specifics of COVID-19. Where COVID-19 infection is suspected, medical providers on site should follow WHO interim guidance on infection prevention and control during health care when novel coronavirus (nCoV) infection is suspected. • Training medical staff in testing, if testing is available and permitted under national legislation. • Assessing the current stock of equipment, supplies and medicines on site, and obtaining additional stock, where required and possible. This could include medical PPE, such as gowns, aprons, medical
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masks, gloves, eye protection, etc. Refer to WHO guidance as to what is advised (for further information see WHO interim guidance on rational use of personal protective equipment (PPE) for COVID-19). • If PPE items are unavailable due to world-wide shortages, medical staff on the project should agree on alternatives and try to procure them. Alternatives that may commonly be found on constructions sites include dust masks, construction gloves and eye goggles. While these items are not recommended, they should be used as a last resort if no medical PPE is available. • Ventilators will not normally be available on work sites, and in any event, intubation should only be conducted by experienced medical staff. If a worker is extremely ill and unable to breathe properly on his or her own, they should be referred immediately to the local hospital (see (g) below). • Review existing methods for dealing with medical waste, including systems for storage and disposal (for further information see WHO interim guidance on water, sanitation and waste management for COVID-19, and WHO guidance on safe management of wastes from health-care activities).
(g) LOCAL MEDICAL AND OTHER SERVICES
Given the limited scope of project medical services, the project may need to refer sick workers to local medical services. Preparation for this includes:
• Obtaining information as to the resources and capacity of local medical services (e.g. number of beds, availability of trained staff and essential supplies). • Conducting preliminary discussions with specific medical facilities, to agree what should be done in the event of ill workers needing to be referred. • Considering ways in which the project may be able to support local medical services in preparing for members of the community becoming ill, recognizing that the elderly or those with pre-existing medical conditions require additional support to access appropriate treatment if they become ill. • Clarifying the way in which an ill worker will be transported to the medical facility, and checking availability of such transportation. • Establishing an agreed protocol for communications with local emergency/medical services. • Agreeing with the local medical services/specific medical facilities the scope of services to be provided, the procedure for in-take of patients and (where relevant) any costs or payments that may be involved. • A procedure should also be prepared so that project management knows what to do in the unfortunate event that a worker ill with COVID-19 dies. While normal project procedures will continue to apply, COVID-19 may raise other issues because of the infectious nature of the disease. The project should liaise with the relevant local authorities to coordinate what should be done, including any reporting or other requirements under national law. (h) INSTANCES OR SPREAD OF THE VIRUS
WHO provides detailed advice on what should be done to treat a person who becomes sick or displays symptoms that could be associated with the COVID-19 virus (for further information see WHO interim guidance on infection prevention and control during health care when novel coronavirus (nCoV) infection is suspected). The project should set out risk-based procedures to be followed, with differentiated approaches based on case severity (mild, moderate, severe, critical) and risk factors (such as age, hypertension, diabetes) (for further information see WHO interim guidance on operational considerations for case management of COVID-19 in health facility and community). These may include the following:
• If a worker has symptoms of COVID-19 (e.g. fever, dry cough, fatigue) the worker should be removed immediately from work activities and isolated on site.
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• If testing is available on site, the worker should be tested on site. If a test is not available at site, the worker should be transported to the local health facilities to be tested (if testing is available and permitted under national legislation). • If the test is positive for COVID-19 or no testing is available, the worker should continue to be isolated. This will either be at the work site or at home. If at home, the worker should be transported to their home in transportation provided by the project. • Extensive cleaning procedures with high-alcohol content disinfectant should be undertaken in the area where the worker was present, prior to any further work being undertaken in that area. Tools used by the worker should be cleaned using disinfectant and PPE disposed of. • Co-workers (i.e. workers with whom the sick worker was in close contact) should be required to stop work, and be required to quarantine themselves for 14 days, even if they have no symptoms. • Family and other close contacts of the worker should be required to quarantine themselves for 14 days, even if they have no symptoms. • If a case of COVID-19 is confirmed in a worker on the site, visitors should be restricted from entering the site and worker groups should be isolated from each other as much as possible. • If workers live at home and has a family member who has a confirmed or suspected case of COVID-19, the worker should quarantine themselves and not be allowed on the project site for 14 days, even if they have no symptoms. • Workers should continue to be paid throughout periods of illness, isolation or quarantine, or if they are required to stop work, in accordance with national law. • Medical care (whether on site or in a local hospital or clinic) required by a worker should be paid for by the employer. Also, see section (j) for contingency planning guidance.
(i) CONTINUITY OF SUPPLIES AND PROJECT ACTIVITIES
Where COVID-19 occurs, either in the project site or the community, access to the project site may be restricted, and movement of supplies may be affected.
• Identify back-up individuals, in case key people within the project management team (PIU, Supervising Consultant, Contractor, sub-contractors) become ill, and communicate who these are so that people are aware of the arrangements that have been put in place. • Document procedures, so that people know what they are, and are not reliant on one person’s knowledge. • Understand the supply chain for necessary supplies of energy, water, food, medical supplies and cleaning equipment, consider how it could be impacted, and what alternatives are available. Early pro-active review of international, regional and national supply chains, especially for those supplies that are critical for the project, is important (e.g. fuel, food, medical, cleaning and other essential supplies). Planning for a 1-2 month interruption of critical goods may be appropriate for projects in more remote areas. • Place orders for/procure critical supplies. If not available, consider alternatives (where feasible). • Consider existing security arrangements, and whether these will be adequate in the event of interruption to normal project operations. • Consider at what point it may become necessary for the project to significantly reduce activities or to stop work completely, and what should be done to prepare for this, and to re-start work when it becomes possible or feasible.
(j) CONTINGENCY PLANNING FOR AN OUTBREAK
The contingency plan to be developed at each site should set out what procedures will be put in place in the event of COVID-19 reaching the site. The contingency plan should be developed in consultation with national and local healthcare facilities and follow state guidance for COVID-19 response, to
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ensure that arrangements are in place for the effective containment, care and treatment of workers who have contracted COVID-19. The contingency plan should also consider the response if a significant number of the workforce become ill, when it is likely that access to and from a site will be restricted to avoid spread.
Contingencies should be developed and communicated to the workforce for:
• Isolation and testing procedures for workers (and those they have been in contact with) that display symptoms; • Care and treatment of workers, including where and how this will be provided; • Getting adequate supplies of water, food, medical supplies and cleaning equipment in the event of an outbreak on site, especially should access to the site become restricted or movements of supplies limited.
Specifically, the plan should set out what will be done if someone may become ill with COVID-19 at a worksite. The plan should:
• Set out arrangements for putting the person in a room or area where they are isolated from others in the workplace, limiting the number of people who have contact with the person and contacting the local health authorities; • Consider how to identify persons who may be at risk (e.g. due to a pre-existing condition such as diabetes, heart and lung disease, or as a result of older age), and support them, without inviting stigma16 and discrimination into your workplace; and • Consider contingency and business continuity arrangements if there is an outbreak in a neighboring community.
Contingency plans should consider arrangements for the storage and disposal arrangements for medical waste, which may increase in volume and which can remain infectious for several days (depending upon the material). The support that site medical staff may need, as well as arrangements for transporting (without risk of cross infection) sick workers to intensive care facilities or into the care of national healthcare facilities should be discussed and agreed.
Contingency plans should also consider how to maintain worker and community safety on site should sites closed to comply with national or corporate policies, should work be suspended or should illness affect significant numbers of the workforce. It is important that worksite safety measures are reviewed by a safety specialist and implemented prior to work areas being stopped.
In drawing up contingency plans, it is recommended that projects communicate with other projects/workforces in the area, to coordinate their responses and share knowledge. It is important that local healthcare providers are part of this co-ordination, to minimize the changes of the local providers being overwhelmed in the event of an outbreak and unable to serve the community.
(k) TRAINING AND COMMUNICATION WITH WORKERS
Workers need to be provided with regular opportunities to understand their situation, and how they can best protect themselves, their families and the community. They should be made aware of the procedures that have been put in place by the project, and their own responsibilities in implementing them.
16 For further guidance on preventing social stigma as a result of COVID-19 see WHO Guide to preventing and addressing social stigma.
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• It is important to be aware that in communities close to the site and amongst workers without access to project management, social media is likely to be a major source of information. This raises the importance of regular information and engagement with workers (e.g. through training, town halls, tool boxes) that emphasizes what management is doing to deal with the risks of COVID-19. Allaying fear is an important aspect of work force peace of mind and business continuity. Workers should be given an opportunity to ask questions, express their concerns, and make suggestions. • Training of workers should be conducted regularly, as discussed in the sections above, providing workers with a clear understanding of how they are expected to behave and carry out their work duties. • Training should address issues of discrimination or prejudice if a worker becomes ill and provide an understanding of the trajectory of the virus, where workers return to work. • Training should cover all issues that would normally be required on the work site, including use of safety procedures, use of construction PPE, occupational health and safety issues, and code of conduct, taking into account that work practices may have been adjusted. • Communications should be clear, based on fact and designed to be easily understood by workers, for example by displaying posters on handwashing and social distancing, and what to do if a worker displays symptoms.
(l) COMMUNICATION AND CONTACT WITH THE COMMUNITY
Relations with the community should be carefully managed, with a focus on measures that are being implemented to safeguard both workers and the community. The community may be concerned about the presence of non-local workers, or the risks posed to the community by local workers presence on the project site. The project should set out risk-based procedures to be followed, which may reflect WHO guidance (for further information see WHO Risk Communication and Community Engagement (RCCE) Action Plan Guidance COVID-19 Preparedness and Response). The following good practice should be considered:
• Communications should be clear, regular, based on fact and designed to be easily understood by community members. • Communications should utilize available means. In most cases, face-to-face meetings with the community or community representatives will not be possible. Other forms of communication should be used; online platforms, social media, posters, pamphlets, radio, text messages, virtual meetings. The means used should take into account the ability of different members of the community to access them, to make sure that communication reaches these groups. • The community should be made aware of procedures put in place at site to address issues related to COVID-19. This should include all measures being implemented to limit or prohibit contact between workers and the community. These need to be communicated clearly, as some measures will have financial implications for the community (e.g. if workers are paying for lodging or using local facilities). The community should be made aware of the procedure for entry/exit to the site, the training being given to workers and the procedure that will be followed by the project if a worker becomes sick. • If project representatives, contractors or workers are interacting with the community, they should practice social distancing and follow other COVID-19 guidance issued by relevant authorities, both national and international (e.g. WHO).
(m) COVID-19 REPORTING
ESIRT requires outbreaks of diseases to be reported. Contractor should report an outbreak following the guidance in ESIRT for a ‘Serious’ incident. An investigation into an outbreak of COVID-19 does
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not need to be undertaken but the contractor should keep the Borrower informed of any concerns or problems associated with providing care to infected workers on project sites, particularly if infection rate is approaching 50% of the workforce.
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APPENDIX E – ENVIRONMENTAL AND SOCIAL INCIDENT RESPONSE
1. Incident Management and Reporting Process A. Overview The incident management and reporting process comprises six steps (see Figure 1 below). Each step includes a sub-set of activities. Tools and templates have been designed to support specific activities in the process.
Figure 1 - Incident Management and Reporting Process
B. Step 1 – Initial Communication Borrower (through the SC) informs the PMU and Bank Team; informs appropriate authorities in compliance with local regulations; secures the safety of workers, public, and provides immediate care. As soon as any member of the Borrower’s team member (EPC Contractor, SC or PMU) becomes aware of an alleged or actual incident, the team member should notify the PMU and the Bank Team. This initial communication is sent prior to classifying the incident. The most crucial element of this communication is speed. When an incident is reported, the following questions are a guide to the type of information to be gathered quickly: • What was the incident? What happened? To what or to whom? • Where and when did the incident occur? • What is the information source? How did you find out about the incident? • Are the basic facts of the incident clear and uncontested, or are there conflicting versions? • What were the conditions or circumstances under which the incident occurred? • Is the incident still ongoing or is it contained? • Is loss of life or severe harm involved? • How serious was the incident? How is it being addressed? How is the Borrower responding? • What, if any, additional follow up action is required, and what are the associated timelines? • Are any Bank staff involved in the incident?
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C. Step 2 – Classification - Assessing the severity of the incident PMU promptly provides information about the incident to the Bank as well as further details as they become available.
D. Step 3 – Notification – Who needs to know about the incident? PMU: • Reports the incident to the Bank. The requirement to report should be defined in the Project’s Operating Manual. As required by the contracts, the EPC Contractor should report incidents to UHE – UHE should ensure that reporting obligations on compliance with ESHS requirements are incorporated into works and other relevant contracts. UHE should monitor the reports for incidents. • Follows national requirements for incident reporting and management. • Responds to Bank communications regarding investigation.
E. Step 4 – Investigation – What happened? UHE: • Promptly provides information requested by the Bank and facilitates incident site visits. • Undertakes or causes the EPC Contractor to undertake a Root Cause Analysis (RCA) to understand and document the root cause(s) of the incident. The RCA should be based on existing country processes, where available. It is only in the absence of systems or weak experience that consultants (national or international) may need to be recruited by the EPC Contractor to undertake the RCA. UHE or EPC Contractor usually is responsible for funding the preparation of the RCA. • An RCA should be completed as soon as possible, ideally within 10 days of the incident. The findings of the RCA should be used by the EPC Contractor and UHE to develop measures to be included in a Safeguards Corrective Action Plan (SCAP) • Shares the RCA with the Bank and provide complete information about the incident; facilitates additional site visit(s) if needed. UHE should ensure that incidents are investigated to determine what happened and why, so that processes and measures can be put in place to avoid reoccurrences and so that appropriate remedies are applied. The Bank Team may support UHE in ensuring an appropriate RCA is conducted by the EPC Contractor or the implementing agency, for example by identifying experts and providing sample ToRs.
The extent of the investigation (RCA) carried out by UHEs EPC Contractor should be proportionate to the severity of the incident. Suggested ToRs for engaging consultants for carrying out an RCA are provided at Annex 1. The RCA findings would be used by the EPC Contractor and/or UHE to develop a Safeguards Corrective Action Plan (SCAP) as a complement to existing project safeguards instruments.
F. Step 5 – Response UHE designs the SCAP and discusses with the Bank, including actions, responsibilities and timelines for implementation, and a UHE monitoring program.
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For Indicative incidents, documentation of the incident and the UHE/EPC Contractor response may be the only action required. For serious and severe incidents, where an RCA or other investigation is conducted by UHE/EPC Contractor, the Bank and UHE agree on a set of measures as appropriate to address the root causes to help prevent any recurrence of the incident. The measures determined as appropriate by the Task Team should be captured in a Safeguards/[Standards] Corrective Action Plan (SCAP). A rudimentary action plan is illustrated in Box 1 below; refer to Annex 2 for a more complete example of a SCAP outline. Box 1 – Example of a Borrower’s Action Plan Following a Project Related Fatality
1) Monthly site meetings attended by PMU and covering safeguards updates 2) The SC QPRs will provide details on ESMP implementation status as well as accidents and grievances 3) PMU will send to the Bank monthly progress reports within 1 week of receipt from the supervision consultants 4) Accidents and grievance log books are placed in all construction sites 5) Any severe injury (requiring off-site medical care) or fatality incident shall be reported to the Bank within 48 hours with basic information and a detailed incident report including the following will be submitted as soon as possible, ideally within 10 working days: a) root cause analysis and b) corrective action plan on: i) immediate mitigation measures in case of continuing danger (e.g. fencing, signboard, guards) ii) compensation to the affected family based on a clear rationale iii) risk assessment and correct application of ESHS management procedures, and iv) medium- and long-term mitigation measures including enhancement of safety measures, audits, and additional training. c) Progress monitoring and reporting
The SCAP specifies the actions, responsibilities, and timelines to be implemented by UHE. UHE is responsible for implementation of the SCAP. The SCAP may include, for example, actions such as the design or upgrading and implementation of Environmental, Social, Health and Safety management systems, processes and training to support consistent safe performance, compensation for injuries or a fatality, pollution prevention and control remedies to be implemented over a few weeks or a multi-year period, according to the specific project circumstances. The SCAP might include requirements for community consultation, compensation payments relating to a resettlement program, or remediation of farmland damaged by contractors. The SCAP also may include or request Bank actions such as provision of technical assistance by the Bank, and/or loan restructuring, including additional financing, if necessary.
If the Bank considers that the SCAP measures will not be effective, or where the UHE has shown itself unwilling or unable to put corrective measures in place, the Bank may consider a decision to fully or partially suspend disbursements until such actions are in place, or, in some circumstances, may consider cancelling all or part of the project following the suspension. Ordinarily, such considerations should be referred by the TTL, in close coordination with the Legal Department, to Senior Management for determination of the appropriate Bank action.
G. Step 6 – Follow up
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Borrower implements SCAP; monitors progress; reports on implementation to the Bank.
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2. Responses and Remedies
Illustrative examples of responses and remedies available for different types of incidents prior to and during project implementation are set out in this section for guidance of task teams and management. Health and Safety Examples
Examples of potential responses by the Bank and the Borrower to worker occupational health and safety incidents of varying severity are presented in Table 1. Table 1 Potential Responses to Health & Safety Incidents of Different Severity Health & Safety Issues Potential Borrower actions Severe Any fatality, • Improve barriers, alarms, signage, training, work processes permanent disability, or and procedures outbreak of life • Address gaps in competence, expertise, numbers of project threatening project- OHS team and/or project management team related communicable • Ensure that Health and Safety risk assessment has been disease conducted and appropriate management plans are put in place, implemented and enforced
Serious • Review relevant sections of health and safety risk assessment Major (non-fatal) accident for adequacy or near-miss • Improve barriers, signage, training, working methods • Enforce use of personal protective equipment • Complement project OHS or management team/PMU with adequate competencies and expertise Serious • Improve use of grievance redress mechanism Repeated observations of • Review relevant sections of health and safety risk assessment dangerous behavior or for adequacy clear violations of safety • Implement (revised) OHS management plan, including protocols training Indicative • Remedy the outstanding issues Repeated failure to • Repeat awareness training and messaging respond to notification to • Improve work process or procedure remedy safeguards issues (e.g., safety kit incomplete or not present)
E&S Examples
Examples of potential responses by the Bank and the Borrower to worker occupational health and safety incidents of varying severity are presented in Table 2.
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Table 2 Potential Responses to Environmental and Social Incidents of Different Severity Environmental/Social Potential Borrower actions Severe (Social) • Identify evicted people and provide compensation and Forced resettlement support for identification of new housing/other facilities as without due process or relevant, in line with Bank safeguards requirements, including compensation appropriate consultation • Clear instructions to project implementer(s) with respect to resettlement process, including sanctions for non- compliance with Borrower/Bank requirements; • Implement all measures identified in SCAP Severe • Engage with law enforcement to halt the poaching (Environmental) • Anti-poaching training for project workers and community Poaching or trafficking in members to make clear incentives and penalties endangered species • Include sanctions for inappropriate worker behavior, including poaching, in Contractors’ contracts • Develop an alternative livelihoods program for communities around protected areas Serious (Social) • Review GRM and address issues (upgrade, improve access, GRM not functioning publicize GRM in community/ies, better organize response process) • Train PIU staff on GRM management and monitoring • Assign responsibility to qualified PIU staff Indicative • Improve work process or procedures as necessary (Environmental) • Train project staff on spills and associated procedures Hydrocarbon or chemical • Increase on-site monitoring if necessary spills with low to medium • Review contract language for appropriate sanctions language environmental impact
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ANNEX 1: Suggested Terms of Reference for Borrower’s Consultant to Carry Out a Root Cause Analyses for a Workplace Accident
Background The Project was approved by the Bank’s Board of Executive Directors in (…) and was effective in (…). Construction Works started on (…) and are currently ongoing. The project closing date is (…). Environmental and Social Impact Assessments (ESIAs) (…) including Environmental and Social Management Plans (ESMPs) were prepared. All Safeguards documents included measures for mitigating Occupational Health and Safety (OHS) risks. The ESMP requires that workers should be trained to recognize potential hazards and use safe work practices (…). The objectives of these TORs are to: 1) identify the root cause of the accident, 2) identify immediate measures to be taken to improve the safety at the site and at other Project sites throughout the Project area and 3) identify effective preventive measures to be implemented to reduce OHS risks.
Scope of work - Conduct root-cause analysis of the incident and identify the sequence of events and factual circumstances. The analysis should identify what failing(s) led to the accident, what safety measures were in place, and the risk information/training provided to workers on site. The level of supervision of unskilled labour should also be assessed. - Recommend actions to be taken to rectify the failure(s) that led to the incident. - Review the safety procedures at different sites and identify the health and safety measures to be taken to minimize the risks of future accidents both to workers and to local residents. Site visits should be carried out to a representative sample of construction sites, activities, regions and Contractors as applicable. Health and safety representatives of the Contractors and implementing agencies, as well as other technical counterparts as necessary should be interviewed to gain a comprehensive understanding about health and safety management. - Review the OHS measures in Safeguards instruments and plans in construction contracts and recommend enhancements as needed. The assessment should identify what the existing procedures for safe performance of construction activities (excavation, - scaffolding, working at heights, welding, etc.) are and should recommend appropriate procedures should the existing ones have gaps. - Review the capacity of Contractors and supervision consultants to implement OHS standards. The assessment should review the training plans for skilled and unskilled labour for effectiveness and propose improvements to the training and communication program so that workers are adequately guided to safely perform their work. - Review the existing arrangements for recruiting labour and what type of insurance (life or injuries and occupational health risks) and compensations are provided. - Review compliance to the Labour Law and other international treaties by Contractors or Subcontractors. - Assess the sufficiency of the measures that the Contractors take to minimize risk on the local communities and communicate with them. Recommend improvements as necessary. Outputs The consultant shall prepare the following outputs: - A root-cause incident investigation report for the accident, including the recommended measures to improve OHS conditions at the site
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- A diagnostic analysis of OHS measures and recommended measures for improvements
Timing The draft incident investigation and OHS diagnostic analysis reports should be submitted within (…) days from commencement. The final report should be submitted within (…) days of receipt of comments on the draft.
Confidentiality All documents provided to the consultant for carrying out this task should be considered confidential except if otherwise indicated.
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APPENDIX F – CRITICAL HABITAT ASSESSMENT
1. INTRODUCTION Under the IFC Safeguard Policy 6 a Critical Habitat Assessment (CHA) is required for the project. The Project will add utility-scale battery storage facilities at four proposed hydropower generation plants (HPPs) and one hydropower pump storage plant (PSP), as well as photovoltaic capacity. The Project comprises five sites that are all located near large water bodies.
This report summarises the findings of the Critical Habitat Assessment for all 5 sites. It identifies the species and habitats with high biodiversity value that both regularly occur in the Project’s Area of Influence (AoI) and trigger Critical Habitat thresholds. The assessment has been desk-based and involved a review of data from the Integrated Biodiversity Assessment tool (IBAT), the Project Environment and Social Management Framework and other reliable data sources such as IUCN, GBIF, eBird and academic literature. This Critical Habitat Assessment has been produced in accordance with the IFC Performance Standard 6 (IFC PS 6) and Guidance note 6 (IFC GN6).
This assessment identified that 49 rare or sensitive species could be present in or close to the five sites. Further research confirmed one species, the Steppe Plump Bush Cricket triggers critical habitat, albeit on a precautionary basis. The species is endangered and restricted to just four small global ranges, one of which includes the Kaniv site. While there is no recent or reliable data to confirm its presence at Kaniv, it’s range is very restricted and the site supports the broad habitat types it requires. It is therefore assumed to be present. There are no other critical habitat triggers.
2. PROJECT DESCRIPTION PJSC “Ukrhydroenergo’s (UHE’s) operations are critical for providing balancing power in the Integrated Power System of Ukraine (IPS). UHE has significant hydropower and pumped storage resources that are used to provide load-supply balance at short notice, due to the large reliance on inflexible nuclear power generation. Despite UHE’s balancing role being complemented by less maneuverable thermal power generation, Ukraine’s IPS continues to rely on the Russian power system for the required flexibility, especially for rapid response requirements. The Project will support the integration of the IPS to the European Network of Transmission System Operators for Electricity (ENTSO-E) that requires a significant increase in the flexibility of the system, both during its isolated operation prior to full synchronization, when Ukraine disconnects from the Russian grid, as well as for post-synchronization operations, when Ukraine is finally connected to and becomes a part of the European grid. Construction of photovoltaic plants and storage facilities is planned across the following 5 sites in Ukraine:
1. Kyiv PSP (46 MW storage facility and 10.6MV Photovoltaic (PV) plant) 2. Kaniv HPP (3 x 22 MW storage facility and 13.5 MW PV plant); 3. Kremenchuck HPP (60 MW storage facility and 6.5 MW PV plant); 4. Seredniodniprovska HPP (25 MW storage facility and 5.3 MW PV plant); and 5. Dnistrovska HPP (28 MW PV plant and 15 MW 6hour Zinc Air Battery). The total capacity of the installed battery storage facilities is 197 MW and the total capacity of the solar PV arrays is 63.9 MW. The first 4 sites listed are all located along the Dnipro river and are situated close to hydroelectric dams, and the corresponding reservoirs, along its length, see Figure 1. The 5th site, Dnistrovoska, is situated in the west of Ukraine, and is also located next to a hydroelectric dam on the smaller Dnister River.
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The AoI for Biodiversity for all of the project development sites is 200m around all project sites (construction and operation zones). This does not include any areas of aquatic habitat as project construction and operation will have no impact on these.
Figure 10. The locations of the 5 project sites: Kyiv, Kaniv, Kremenchuk, Seredniodniprovska and Dnistrovska
3. Critical Habitat Process
Critical Habitat (CH) is defined in the IFC Performance Standard 6 (2019) as a subset of both natural and modified habitat that has high biodiversity value and deserves particular attention. Critical Habitat is fundamentally based on the following five criteria:
• Criterion 1: Critically Endangered (CR) and/or Endangered (EN) species • Criterion 2: Endemic or restricted-range species • Criterion 3: Migratory or congregatory species • Criterion 4: Highly threatened and/or unique ecosystems • Criterion 5: Key evolutionary processes
To help determine if Critical Habitat is present the International Finance Corporation (IFC) Guidance Note 6 (GN6) has been adopted throughout this process. IFC GN6 gives specific numerical thresholds that are broadly based upon globally standardised numerical thresholds published in IUCN’s A Global Standard for the Identification of Key Biodiversity Areas and Red List Categories and Criteria. The thresholds are indicative and serve as a guideline for decision-making only. There is no universally accepted or automatic formula for making determinations on critical habitat.
The first stage of assessment researches and identifies species and protected sites within 50km of the Project sites, the Area of Ecological Assessment (AoA). The Integrated Biodiversity Assessment Tool
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(IBAT) provides much of the foundation data. This data is supplemented with recent and reliable field data and additional desk-based study including for example the species present in local designated sites and the data gathered for the Environment and Social Management Framework. An assessment is made to determine if each species identified regularly occurs (as per IFC GN6) in the Project AoI. The likelihood of regular occurrence is informed by species characteristics including typical range size, habitat requirements, movement, migratory routes, breeding sites and population distribution.
The species that are likely to regularly occur in the Project AoI are further assessed to determine the potential to also meet the IFC criteria for Critical Habitat. All species that are likely to regularly occur in the AoI and that have the potential to meet critical habitat criteria, are subject to more detailed analysis to confirm if they trigger Critical Habitat. For certain species an ecologically appropriate area of analysis (AoA) may be required to quantify if the population represents a locally or globally significant population and critical habitat.
4. Biodiversity Context
4.1 Kyiv PSP The AoI for this site is situated within modified dry grassland and scrubland habitat close to residential and industrial areas, with some deciduous and occasionally coniferous trees more than 3 meters in height. Patches of bare ground are frequent. It borders a small reservoir with engineered concrete banks. There are 4 protected areas or areas of national or international importance for nature conservation within 10km of the Kyiv PSP site, see Table 1.
Figure 11: Photo from the Kyiv Site Table 24: Protected areas within 10km of Kyiv PSP project site
Name Designation Distance Direction (km)
Kyivske Reservoir Emerald site 0.4 East
Kyivske Podesennia Emerald site 5 South East
Staropetrivs'ki sosnovi Unknown national 8 North West nasadzhennya designation
Holosiivskyi National Nature Park Emerald site 9 South West
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4.2 Kaniv HPP The AoI is within largely modified dry grassland and scrubland, with occasional trees present towards the south west boundary. To the north east the AoI borders semi- natural forest. The AoI is adjacent to the edge of the large Kanivske reservoir to the north, which has engineered concrete banks along the length of the proposed development. To the south east is the Kremenchutske reservoir. There are 6 protected areas or areas of national or international importance for nature conservation within 10km of the Kaniv HPP site, Table 2. Figure 12: Photo from the Kaniv site Table 25: Protected areas within 10km of Kaniv HPP project site
Name Designation Distance Direction (km)
Kanivske Reservoir Emerald site 0.1 North
Kremenchutske Reservoir Emerald site 0.1 South east
Tarasiv obriy State Zakaznik (reserve) 0.7 South east
Kanivs'kyi Nature Reserve IBA 2 South
Kanivs'kyi State Zapovednik (strictly 3 South protected area)
Kanivskyi Nature Reserve Emerald Site 3 South
4.3 Kremenchuk HPP The AoI is dominated by modified dry grassland and with scattered small trees and bushes. The AoI is adjacent to the edge of the large Kanivske reservoir to the west, which has engineered concrete banks along the length of the proposed development. To the east it is adjacent to a large residential area, with many rows of dachas. There are 3 protected areas or areas of national or international importance for nature conservation within 10km of the Kremenchuk HPP site.
Figure 13: Photo from the Kremenchuk site
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Table 26: Protected areas within 10km of Kremenchuk HPP project site
Name Designation Distance Direction (km)
Kremenchutske Reservoir Emerald site 0 West
Kremenchutski Plavni Regional Emerald site 4.5 East Landscape Park
Bilets'kivs'ki plavni State Zazanik 4.5 East
4.4 Seredniodniprovska HPP The AoI is within largely modified dry grassland and habitat, with some trees and bushes present. The AoI runs adjacent to the edge of the large Kamianske Reservoir to the West, which has non- natural concrete banks along the whole length of the proposed development. The northern part runs adjacent to a large residential area, with many rows of dachas to the East of the AoI, and the Southern part of the project is in a more industrial area, although there are some areas of more natural habitat present. There are 3 protected areas or areas of national or international Figure 14:Photo from the Serednedniprovska importance for nature conservation within 10km of site the Seredniodniprovska HPP site.
Table 27: Protected areas within 10km of Seredniodniprovska HPP project site
Name Designation Distance (km) Direction
Kamianske Reservoir Emerald site 0.1 East
Dniprovske Reservoir Emerald site 0.1 West
Dniprovs'ko-Oril's'kyj Nature IBA 8 North Reserve
4.5 Dnistrovska HPP
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The Dnistrovska site is located at the Dnister hydroplower plant on the Dnister river, where it borders a smaller reservoir that has non-natural concrete banks along the whole length of the proposed development. The project site is mainly characterised as modified scrubland, with small trees and bushed although there are also stands of larger trees and some small wooded areas present. There are 5 protected areas or areas of Figure 15:Photo from the Dnistrovska site national or international importance for nature conservation within 10km of the Dnistrovska HPP site, see Table 5.
Table 28: Protected areas within 10km of Kremenchuk HPP project site
Distance Designation Direction Name (Km)
Emerald site 0.1 N/A Khotynskyi National Nature Park Podilskyi Dnister Emerald site 4
Vasylivski i Rozkopynski gullies Emerald site 4
Regional Nature 9 South Chotiri topoli Monument
Regional Nature 10 North Platan skhidniy (chinar) Monument
5. Critical Habitat Criterion 1 – Critically Endangered and Endangered Species
IFC criterion 1 for critical habitat is areas important for critically endangered or endangered species. The corresponding IFC GN(6) guidance for this requirement adds further detail to allow more accurate assessment, and is as follows:
a) Areas that support globally important concentrations of an IUCN Red-listed EN or CR species (≥0.5% of the global population AND ≥ 5 reproductive units GN16 of a CR or EN species) b) Areas that support globally important concentrations of an IUCN Red-listed Vulnerable (VU) species, the loss of which would result in the change of the IUCN Red List status to EN or CR and meet the thresholds in GN72(a) c) As appropriate, areas containing important concentrations of a nationally or regionally listed EN or CR species. Analysis of the IBAT data and supplementary sources identified 49 species that could be present within 50km of any of the 5 development sites and potentially meet the above IFC criteria summarised above. Further research was completed to screen whether these species are likely to regularly occur in the AoI for any of the 5 sites. The results of this screening can be found in Appendix A. Strictly aquatic species were ruled out of the Critical Habitat Assessment as the AoI does not include aquatic habitat.
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The screening process for Criterion 1 concluded that only 1 species has the potential to meet the IFC CH criteria and is assumed to regularly occur in the Project AoI. This is the globally Endangered Steppe Plump bush-cricket. IUCN data suggests that the Steppe Plump Bush Cricket is present in only four small sites globally, one being grassland in the Kaniv region. The other sites are in Russia. Figure 7 shows the Steppe Bush Cricket’s Ukrainian range17, which represents the Area of Analysis (AoA). The AoA overlaps with the Kaniv development site at the southernmost end.
Figure 16: Area of Analysis for the Steppe Plump Bush Cricket based on IUCN data. Kaniv development site AoI is represented in red.
There is no recent or reliable species abundance or distribution data for the Kaniv area but the species inhabits Mesophytic steppe grassland areas and grassland and shrubland are both present in the Kaniv AoI. With the data available its presence cannot be confidently determined. However, due to the site’s overlap with the specie’s IUCN range and the presence of potentially suitable habitat it must be assumed to regular occur.
In line with the precautionary approach, it must be assumed that the Steppe Bush Cricket regularly occurs within the AoI, as the habitat is potentially suitable, and that the AoA for this species contains a continuous population representing >0.5% of the global population. Therefore, the AoI for the Kaniv site is within Critical Habitat for the Steppe Plump Bush Cricket.
The habitat within the AoI, whilst potentially suitable, is modified and may not represent the optimum natural steppe grassland this species prefers. Therefore, pre-construction field surveys are required to determine whether this species is present in the AoI. If it is confirmed to regularly occur in the AoI measures to ensure no net loss and preferably achieve a net gain in its nature conservation status will
17https://www.iucnredlist.org/species/68399947/70270180
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be required. Such measures should be achieved via a Biodiversity Action Plan. If confirmed absent no further measures are likely necessary.
No other species with the potential to meet Critical Habitat criterion 1 were found to regularly occur across any of the sites.
6. Critical Habitat Requirement 2 – Restricted Range Species
IFC CH requirement 2 for critical habitat is areas having special significance for endemic or restricted- range species. The IFC GN6 defines a terrestrial restricted range species as having an Extent of Occurrence (EOO) less than 50,000 km2. The Critical habitat threshold for this requirement is defined as ‘areas that regularly hold ≥ 10% of the global population size AND ≥ 10 reproductive units of a species’.
The IBAT tool was used to identify any species potentially present within 50 km of the alignment that were listed by the IUCN as having an EOO of less than 50,000 km2. Only one restricted range species was identified within 50km of the 5 project sites, Nordmann’s birch mouse Sicista loriger. Research confirmed that there are a number of small, isolated populations in Ukraine, one of which is the Dnipro-Oril Floodplains protected area approximately 16km from the Seredniodniprovska project site18, Figure 8. This species is not thought to be found outside this protected area due to its specific habitat requirements of undisturbed steppe and shrubland habitat. Most of the habitat surrounding the Seredniodniprovska site is heavily modified, including the area planned for construction.
Figure 17: Known Sicista loriger distribution (IUCN)2 in relation to the Seredniodniprovska development site No other restricted range species were identified. This is not surprising as Ukraine does not have high rates of endemism compared to other geographic locations, with the majority of species widely distributed but rare across their range. Therefore, the project area does not contain Critical Habitat under Criterion 2.
18https://www.iucnredlist.org/species/110500058/175618666
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7. Critical Habitat Requirements 3 – Migratory or Congregatory species
The IFC definition of Critical Habitat includes areas of importance for migratory and congregatory species.
The IFC Thresholds for Critical Habitat Requirement 3 are as follows:
a) Areas known to sustain, on a cyclical or otherwise regular basis, ≥ 1 percent of the global population of a migratory or congregatory species at any point of the species’ lifecycle.
b) Areas that predictably support ≥10 percent of the global population of a species during periods of environmental stress. All 5 project locations are close to large waterbodies, which often host migratory and congregatory waterbird species. Migratory species that are present in the reservoirs bordered by the developments have been assessed to see whether they could meet the IFC thresholds. The detailed results are presented in Appendix C.
Three species present at Kaniv were identified as potentially meeting Critical Habitat thresholds. These are the Little Crake Zapornia parva, the Spotted Crake Porzana porzana and the Black-throated Diver Gavia arctica. The populations of Little and Spotted Crakes in the Kanivske Reservoir (bordering the Kaniv site) potentially represents more than 1% of the global population of each species (10% and 2% respectively), with a maximum of 10,000 individuals of each species. The population of the Black- throated diver in the Kanivske Reservior potentially represents 3.8% of the global population, also with a maximum of 10,000 individuals. All percentage calculations used the maximum local population and minimum global population (IUCN) in line with a precautionary approach.
The Kanivske Reservoirs represents part of the breeding range of the Little Crake and Spotted Crake. Both species are fully migratory and migrate to areas of Africa and Asia to overwinter. Both species have specific and similar habitat requirements in their breeding season. Suitable habitats include seasonal and permanent marshes and fens, bogs, damp meadows, swamps, seasonally flooded pans and the grassy margins of reservoirs and lakes. They require tall stands of emergent vegetation, with dense coverings of grass, sedges or rushes, preferably with a mixture of dead and living stems19,20. The edge of the Kanivske reservoir that overlaps with the AoI does not contain any of these habitat types, as it comprises concrete banks rather than natural, grassy margins or fenland areas. The main habitats in the AoI are modified dry grassland and scrubland. Therefore, these species, although they may be present in high numbers in the Kanivske reservoir, are unlikely to occur regularly in the Kaniv AoI, but rather in more suitable natural habitats along other banks of this very large reservoir.
The Black throated diver or Arctic Loon Gavia arctica is an aquatic diving bird that feeds exclusively on aquatic prey, primarily fish. It breeds to the North of Ukraine in Scandinavia, northern Russia and the Arctic circle and migrates to overwinter in coastal sites further South, for example the Black and Mediterranean Seas. This species is found in Ukraine only in Passage, where it stops off on migration. Kanivske reservoir is known to support this species as it stops off on its migration to/from breeding sites to the North, but it does not breed nor overwinter in this site. Apart from during its breeding season where it builds nests on the shores of reservoirs this species is exclusively aquatic and tends
19https://www.iucnredlist.org/species/22692676/86160125 20https://www.iucnredlist.org/species/22692663/86162074
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to spend most of its time in deeper water where it can hunt fish effectively21,22. Indeed, it is very ungainly out of the water and cannot take off or land on dry land. Therefore, during stop-offs in the Kanivske reservoir this species is very unlikely to leave the water, and therefore will not regularly occur within the AoI for the Kaniv site which is exclusively terrestrial.
The project area does not contain Critical Habitat under Criterion 3.
8. Critical Habitat Requirement 4 – Highly threatened and/or unique ecosystems The IFC definition of Critical Habitat includes areas situated within Highly threatened and or/unique ecosystems. The IUCN is developing a Red List of Ecosystems, following an approach similar to the Red List for Threatened Species. Where formal IUCN assessments have been performed, the Red list of ecosystems should be referred to. Where formal IUCN assessments have not been performed, the assessments may be carried out using systematic methods at the national/regional level, carried out by governmental bodies, recognized academic institutions and/or other relevant qualified organizations (including internationally recognized NGOs).
The IFC thresholds for Criterion 4 are as follows:
a) Areas representing ≥5% of the global extent of an ecosystem type meeting the criteria for IUCN status of CR or EN. −
b) Other areas not yet assessed by IUCN but determined to be of high priority for conservation by regional or national systematic conservation planning.
No IUCN red listed ecosystems are present in any of the AoIs for this project. Although the AoIs of 3 of the 5 sites overlap with Emerald sites designated under the Bern Convention, these sites have not been designated due to the presence of highly threatened or unique ecosystems, but rather to facilitate the long-term protection of the entire Dnipro river ecological corridor, which is an important stop-off and flyway for migratory waterbird species. Further, no priority habitat types listed in the Bern convention are known to occur within the AoIs, which represent modified grass and scrubland habitat types common in Ukraine and Eastern Europe. The species present in these Emerald sites have been appropriately assessed under Criteria 1, 2 and 3. Therefore, Critical Habitat is not triggered for Criterion 4.
8.1 Critical Habitat Requirement 5 – Key evolutionary processes The IFC definition of critical habitat includes areas associated with key evolutionary processes. The IFC GN6 gives some guidance on this, stating that areas associated with Key evolutionary processes tend to have high spatial heterogeneity, which can lead to speciation via isolation or divergent evolution, or environmental gradients, also known as ecotones, which produce transitional habitat and are associated with the process of speciation. None of the AoIs for these projects contain habitats fitting these criteria, and indeed in are mainly within areas of modified habitat.
The area is also not thought to provide key ecosystem services. The project area does not contain Critical Habitat under Criterion 5.
21https://www.iucnredlist.org/species/22697834/132606505 22 https://cdn.birdlife.se/wp-content/uploads/ornis_svecica/cms_20- s1_Vol%2017(2),%209094%20Polak%20o%20Ciach%20sm%c3%a5lom.pdf
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9. Conclusions
The project meets Critical Habitat Criterion 1 at one site, the Kaniv HPP. This is due to the likely presence of the globally Endangered species the Steppe Plump Bush cricket Isophya stepposa. Although there is no data available to confirm that this species regularly occurs in the Kaniv AoI, it is assumed that it does under the precautionary approach as the habitat is suitable and the IUCN distribution map for the local population overlaps with the site. Recent and reliable data is required to confidently confirm its regular presence in the AoI. Further pre-construction surveys are therefore recommended. If it is confirmed to regularly occur measures to ensure no net loss and preferably achieve a net gain in its nature conservation status will be required. Such measures could be achieved via a Biodiversity Action Plan. If confirmed absent no further measures are likely necessary.
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Annex A: Criterion 1 – Screening Assessment
Analysis of the IBAT data and supplementary sources identified 49 species that could be present within 50km of any of the 5 development sites and potentially meet the above IFC criteria. Details are provided.
Criterion 1(a) - Globally Endangered and Critically Endangered Species
The following 18 globally endangered and critically endangered species were identified as being potentially present within 50km of the project AoIs, see Table A1.
• Table A1: Endangered and Critically Endangered species potentially present. Species name Common name IUCN Taxonomic Category Class 1. Acipenser stellatus Stellate sturgeon CR Actinopterygii 2. Acipenser gueldenstaedtii Russian sturgeon CR Actinopterygii 3. Cricetus cricetus Common Hamster CR Mammalia 4. Huso huso Beluga CR Actinopterygii 5. Mustela lutreola European Mink CR Mammalia 6. Anguilla anguilla European Eel CR Actinopterygii 7. Vanellus gregarius Sociable Lapwing CR Aves 8. Buprestis splendens Goldstreifiger EN Insecta 9. Desmana moschata Russian Desman EN Mammalia 10. Alburnus EN Actinopterygii sarmaticus 11. Ampedus EN Insecta quadrisignatus 12. Agropyron Edge Flowered Crested EN Liliopsida dasyanthum Wheatgrass 13. Falco cherrug Saker Falcon EN Aves 14. Isophya stepposa Steppe Plump Bush-cricket EN Insecta 15. Homalia EN Bryopsida webbiana 16. Spermophilus European Souslik EN Mammalia citellus 17. Ropalopus EN Insecta ungaricus 18. Isophya Zubowski's Plump Bush- EN Insecta zubowskii cricket
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Criterion1(b) – Globally Vulnerable Species
The following 29 globally vulnerable were identified as being potentially present within 50km of the project AoIs, see table A2.
• Table A2: Vulnerable species potentially present. Species name Common name IUCN Taxonomic Category Class 1. Acipenser ruthenus Sterlet VU Actinopterygii 2. Alosa immaculata VU Actinopterygii 3. Cyprinus carpio Wild Common Carp VU Actinopterygii 4. Nyctalus lasiopterus Giant Noctule VU Mammalia 5. Pseudanodonta complanata Depressed River Mussel VU Bivalva 6. Spalax zemni Podolian Mole Rat VU Mammalia 7. Nehalennia speciosa Pygmy Damselfly VU Insecta 8. Sphaerium rivicola River Orb Mussel VU Bivalva 9. Anacyclus pyrethrum Atlas Daisy VU Magnoliopsida 10. Anser erythropus Lesser White-fronted Goose VU Aves 11. Aythya ferina Common Pochard VU Aves 12. Streptopelia turtur European Turtle-dove VU Aves 13. Otis tarda Great Bustard VU Aves 14. Clanga Greater Spotted Eagle VU Aves 15. Aquila heliaca Eastern Imperial Eagle VU Aves 16. Acrocephalus Aquatic Warbler VU Aves paludicola 17. Tricholoma VU Agaricomycetes acerbum 18. Sicista loriger Nordmann's Birch Mouse VU Mammalia 19. Bovista paludosa Fen Puffball VU Agaricomycetes 20. Cuphophyllus Toasted Waxcap VU Agaricomycetes colemannianus 21. Hygrocybe ovina Blushing Waxcap VU Agaricomycetes 22. Picipes rhizophilus VU Agaricomycetes 23. Sarcodontia crocea Orchard Tooth VU Agaricomycetes 24. Astacus Noble Crayfish VU Actinopterygii 25. Umbra krameri European Mudminnow VU Actinopterygii 26. Hapalopilus Orange Polypore VU Agaricomycetes croceus 27. Brachythecium VU Bryopsida geheebii 28. Spalax graecus Balkan Blind Mole Rat VU Mammalia 29. Baeospora VU Agaricomycetes myriadophylla
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Criterion 1(c) – Nationally endangered species
IFC guidance states that as appropriate, areas containing important concentrations of a nationally or regionally listed EN or CR species should be considered for Critical Habitat. These are summarised in National Red Lists. However, for a national/regional red list to be relevant to the Critical Habitat criteria it must have adhered to IUCN guidance. Although Ukraine has a national red list, it is not thought to have been carried out to IUCN guidelines. Criterion 1(c) is thus not applicable for this Critical Habitat Assessment. However, the Ukraine Red Data Book is still an important data source when identifying species that may occur in the Project area and further, key threatened species will be adequately assessed under Criteria 1 (a) and (b).
Screening Results
The initial Critical Habitat Screening Assessment concluded that 48 of the 49 species either did not regularly occur in the Project AoI or did not to have the potential meet the Criterion 1 threshold, and thus were screened out. The remaining species has the potential to meet the IFC CH criteria and, in accordance with a precautionary approach, has been assumed to regularly occur.
The results of the screening process are presented in table A3, including an assessment of the likelihood for each species to trigger critical habitat thresholds and being regularly present in the AoI.
Annex B: Criterion 1 – Screening Assessment Results
All possible Critical Habitat triggers within 50 km of the Project AoI’s were identified by consulting the IBAT database, Ukrainian National Red Book, and local Nature Reserve datasets. Each species was then analysed individually under Criterion 1 of the IFC PS6. Firstly, it was determined whether a species was likely to regularly occur in any of the Project’s 5 AoI. For those species identified as regularly occurring in the Project AoI further assessment was made to determine whether those species had the potential to meet the IFC PS6 Critical Habitat thresholds (as described in Section 5. Aquatic species are not included as aquatic habitat is not included within the AoI. The results of this process are detailed in Table A3 below: The acronyms used for each site are: Dnistrovka (DN), Kyiv (KY), Kaniv (KA), Kremenchuk (KR), and Seredniodniprovska (SE).
Table A3: Results of the Criteria 1 screening assessment of terrestrial habitat Scientific Common Status Critical Habitat triggered? Justification
DN KY KA KR SE
Isophya Steppe Plump EN No No Yes No No IUCN shows the Steppe stepposa Bush-cricket Plump Bush Cricket only has two habitats left in the world, one being the grassland next to the Kaniv plant and extending up to Rzhyshchiv. The IUCN distribution map for this area of habitat overlaps with the AoI for Kaniv. The species inhabits
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mesophytic steppe and forest steppe habitats at altitudes between 50 - 300 m Asl. Due to the overlap of the distribution map and the potential presence of suitable habitat, Critical Habitat has been triggered on a precautionary basis.
Cricetus Common CR No No No No No IUCN range indicates it may Hamster be present in Dnistrovska, Kyiv and Kaniv AoIs. Its original habitat was fertile steppe and grassland, but it has successfully spread into a variety of anthropogenic habitats including meadows, croplands (especially cereals), field edges, road verges and scrubby fallow areas on farms. In eastern parts of its range, it is found quite often in gardens and orchards, near human habitation. It is now more abundant in these man-made habitats than it is in natural grassland. It prefers relatively deep, heavy soils, in which it digs extensive burrows. GBIF dataset indicates many sightings across Ukraine with some outside of the IUCN range. Nearest sighting to Dnistrovska is 60 km away, to Kyiv is 45 km away, and to Kaniv is 66km away. 1950s it was widespread across the whole country. 2013 data suggests the only active burrows within 50 km of any of the sites are about 43 km from Kaniv. The Ukrainian Red book shows some sites that are a bit closer but still over 35 km away. Whilst some habitat around the project AoIs may be suitable for this species, with no recorded observations for decades, this
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species cannot be said to regularly occur in any of the AoIs and Critical Habitat has not been triggered for this species.
Mustela European CR No No No No No Extinct in all 5 project areas lutreola Mink and most of Ukraine (IUCN). Critical Habitat has not been triggered for this species.
Vanellus Sociable CR No No No No No Possibly extinct in Ukraine, gregarius Lapwing historic range is further east than all project sites apart from Seredniodniprovska. It uses dry wasteland, cultivated, ploughed and stubble fields (del Hoyo et al. 1996). On migration it uses mainly sandy plains with short grass, dry meadows, fallow land, and cultivated fields (del Hoyo et al. 1996). This species has not been listed as present in any Emerald sites or Important Bird Areas close to the 5 developments, including those containing suitable habitat, and thus it is infeasible that they regularly occur in any of the AoIs. Critical Habitat has not been triggered for this species.
Buprestis Goldstreifiger EN No No No No No Likely extinct in Ukraine. splendens Found historically across a small area close to Kiev but this population is possibly extinct which is within a few km of Kyiv site. As IUCN reports it has not been found in Ukraine for many decades so we can assume it is not regularly present in the Kyiv AoI (which does not overlap with the historic range anyway). Critical Habitat
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has not been triggered for this species.
Desmana Russian EN No No No No No IUCN does not show the moschata Desman Russian Desman to be present at or close to any of the 5 sites. Critical Habitat has not been triggered for this species.
Alburnus EN No No No No No Not present close to sarmaticus Dnistrovska and extinct in the river system of the other 4 locations. Critical Habitat has not been triggered for this species.
Ampedus EN No No No No No In Ukraine, it occurs in the quadrisignatus Carpathians and in the south of the forest-steppe zone (IUCN). Often in remnants of oaks, always inside forests; the preferred habitats are beech- oak woods of lowlands and foothills (Laibner 2000). It prefers dark, shady stands, old growth forest and trees with a large diameter. The Dnistrovska AoI contains some trees but no areas of mature forest so this species is very unlikely to occur. Critical Habitat has not been triggered for this species.
Agropyron Edge EN No No No No No IUCN shows it occurs in dasyanthum Flowered isolated sites from Crested Kremenchuk to the Black Sea. Wheatgrass It grows in sandy soils on beaches along permanent rivers, as well as in coastal areas. This habitat type is not found at the 5 development sites and so it is unlikely that this species regularly occurs in any of the AoIs. Critical
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Habitat has not been triggered for this species.
Falco cherrug Saker Falcon EN No No No No No Data from 2014 suggests between 250 and 400 mating pairs in Ukraine. Ukraine is the "nucleus" for the central European population. This species hunts in open steppe grasslands, including pasture areas, and tends to nest in cliffs or in stands of trees. The species has not been recorded in any of the 11 Emerald sites close to the planned project locations, the majority of which contain suitable habitat (grassland, steppe, and pasture with areas of forest). It is also not recorded in any Important Bird Areas within 50km of the project sites. Therefore, it is very unlikely to regularly occur in any of the AoI's, which generally contain more modified habitat than those in the nearby designated sites. Critical Habitat has not been triggered for this species.
Homalia EN No No No No No IUCN shows it present west webbiana of Cherkasy but not overlapping with any of the 4 river sites. Critical Habitat has not been triggered for this species.
Spermophilus European EN No No No No No IUCN and GBIF shows citellus Souslik presence in Dnistrovska, possibly within 15 km. The European Souslik has very specific habitat requirements. It is restricted to short-grass steppe and similar artificial habitats (pastures, airfields, lawns, sports fields, golf courses) on light, well-drained soils, where it can excavate its burrows (Kryštufek 1999,
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Spitzenberger 2002). Roadsides and riverbanks are very important habitats in some regions (e.g., southern Romania), where they are virtually the last remaining grassland habitats in large stretches of land and could also serve as important corridors for ground squirrels and other grassland species. Deemed likely to be extinct by EU report 2013 and not in Ukrainian Red Book so Critical Habitat has not been triggered.
Ropalopus EN No No No No No IUCN shows presence in ungaricus Dnistrovska. The beetles are likely to be absent from the planned site, as the site is dominated by moderate and disturbed habitats, as opposed to old growth maple and solitary trees, the species' preferred habitat. Therefore, it is infeasible that any local effect on this species would result in its IUCN threat level being raised. Critical Habitat has not been triggered.
Isophya Zubowski's EN No No No No No Zubowski's Plump Bush- zubowskii Plump Bush- cricket has been recorded cricket from the lowlands of southern and eastern Romania, Moldova, and southwestern Ukraine (Bey-Bienko 1954, Iorgu and Iorgu 2012). The border of its northern range in Ukraine and Moldova is uncertain. IUCN range does not overlap by quite a distance so Critical Habitat has not been triggered for this species.
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Alosa VU No No No No No Extinct from Kremenchuk and immaculata Seredniodniprovska sites. Never present in any of the others. Critical Habitat has not been triggered for this species.
Nyctalus Giant VU No No No No No IUCN shows its range at 4 of lasiopterus Noctule the sites. It is widely distributed across Europe although patchy. It is highly dependent on mature woodland which is absent from all sites. Therefore, it is infeasible that any local effect on this species would result in its IUCN threat level being raised, and Critical Habitat has not been triggered for this species.
Spalax zemni Podolian VU No No No No No The species occurs across Mole Rat Ukraine, where it is found from near the eastern Polish border to the Dnepr River in Central Ukraine and south to the Moldovan border. The species prefers virgin steppe as its optimal habitat, which are not found near the 5 proposed sites. Therefore, it is infeasible that the loss of the local population would result in its IUCN threat level being raised to EN. Critical Habitat has not been triggered for this species.
Nehalennia Pygmy VU No No No No No IUCN indicates possible speciosa Damselfly presence at Kyiv site. The wetland habitat that this species prefers, e.g., mires and bogs are not present within any of the sites proposed, therefore it is infeasible that any local effect on this species would result in its IUCN threat level being raised. Critical Habitat has not
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been triggered for this species.
Anacyclus Atlas Daisy VU No No No No No Found widely across Ukraine. pyrethrum The alpine nature of the species preferred habitat (400 - 3100m ASL) means it is unlikely to be found at any of the proposed sites as all sites are well below the 400m ASL that the species needs. Therefore, it is infeasible that any local effect on this species would result in its IUCN threat level being raised. Critical Habitat has not been triggered for this species.
Anser Lesser VU No No No No No Widely distributed across erythropus White- Ukraine (IUCN). This species fronted has been recorded in Kanivske Goose Reservoir, with a maximum population of 10, according to the Emerald site database. It has not been recorded in the reservoirs bordering the Kyiv, Kremenchuk or Seredniodniprovska developments. Whilst this species may be present at some sites, it is infeasible that any local effect on this species would result in its IUCN threat level being raised. Critical Habitat has not been triggered for this species.
Aythya ferina Common VU No No No No No IUCN shows Common Pochard Pochard to be widely distributed across Europe, including Ukraine. eBird also shows sightings around all the sites. This species has not been recorded in the reservoirs bordering the Kyiv, Kaniv, Kremenchuk or Seredniodniprovska developments, all of which are
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emerald sites. Whilst this species may be present at some sites, it is infeasible that any local effect on this species would result in its IUCN threat level being raised. Critical Habitat has not been triggered for this species.
Streptopelia European VU No No No No No IUCN indicates it is widely turtur Turtle-dove distributed across Ukraine. The species uses a wide variety of woodland types, as well as steppe and semi-desert (Baptista et al. 2015), frequently relying on agricultural land for feeding. Due to its large distribution across Ukraine and Europe, and whilst the species may occur close to the sites, it is infeasible that any local effect on this species would result in its IUCN threat level being raised. Critical Habitat has not been triggered for this species.
Otis tarda Great VU No No No No No IUCN data indicates the Great Bustard Bustard uses the area downstream from Kyiv in the river for passage only, with a potential breeding area around Kremenchuk. Although it could potentially pass over the other sites in passage, it is deemed unlikely to regularly occur in their AoIs and rather pass above these areas in flight, as none have been identified as known stop off locations. This species is not listed as present in the nearby Emerald site Kremenchutski Plavni Regional Landscape Park, despite this containing suitable habitat for this species (open grassland and hay meadow). Therefore, it is very unlikely to be present
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regularly in the Kremenchuk AoI, which contains more modified and less suitable habitat than the nearby landscape park. Critical Habitat has not been triggered for this species.
Clanga clanga Greater VU No No No No No This species occupies a Spotted Eagle fragmented range, and breeds in Ukraine (1 of several countries, IUCN). This species has been recorded close to the Kremenchuk and Kaniv sites, with a maximum of 2 individuals present at Kremenchutske Reservoir and another 2 (max) at Kremenchutski Plavni Regional Landscape Park. It is very unlikely they regularly occur in the Kremenchutski and Kaniv AoIs, and if they do it is in low enough numbers (max 4 individuals) that is infeasible that any local effect on this species would result in its IUCN threat level being raised. Critical habitat is not triggered for this species. Critical Habitat has not been triggered for this species.
Aquila heliaca Eastern VU No No No No No IUCN indicates this species is Imperial Eagle widely distributed across Ukraine, which is one of its breeding countries. The breeding range covers the Dnistrovska, Kremenchuk and Seredniodniprovska sites, with the Kaniv and Kyiv sites only being part of its passage distribution (on migration). This is a lowland species that has been pushed to higher altitudes by persecution and habitat loss in Europe. In central and eastern Europe, it breeds in forests up to 1,000
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m and in steppe and agricultural areas with large trees, and nowadays also on electricity pylons. It is sensitive to human disturbance; heavily modified habitat is not suitable for this species. This species is not listed as present in the Kremenchutski Plavni Regional Landscape Park or Kremenchutske Reservoir Emerald sites close to the Kremenchuk development, even though they both contain suitable breeding habitat. It is also not present in the Podilski Tovtry National Nature Park and Khotynskyi National Nature Park, both large national parks containing suitable habitat close to the Dnistrovska development. Finally, it is not recorded from the Kamianske Reservoir and Dniprovske Reservoir Emerald sites which the Seredniodniprovska development sits adjacent to, or the nearby Dniprovs'ko- Oril's'kyj Nature Reserve IBA. Therefore, it is very unlikely to regularly occur within the Kremechuk, Dnistrovska or Seredniodniprovska AoIs, which contain more modified and less suitable habitat than the nearby designated sites. Critical Habitat has not been triggered for this species.
Acrocephalus Aquatic VU No No No No No IUCN shows they are present paludicola Warbler in 4 sites on passage and Kaniv overlaps with its breeding range. This species breeds across a highly fragmented range at fewer than 50 regular breeding sites. It breeds in large open lowland sedge fen mires and similarly structured
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marshy habitats with a water depth of 1-10 cm. This species is not present in the Emerald sites the Kaniviske reservoir, Kanivskyi Nature Reserve or Kremenchutske Reservoir, all close to the Kaniv development. The habitat within the AoI is also not suitable for this species. For both reasons it is infeasible that this species regularly occurs within the AoI for Kaniv. Critical Habitat has not been triggered for this species.
Tricholoma VU No No No No No Widely distributed across all 5 acerbum AoIs (IUCN). The species occurs in montane forests with deciduous Quercus species (such as Quercus robur, maybe also Q. pubescens) and Castaneus in southern Europe, but in Mediterranean areas also with the sclerophyllous Quercus ilex. Despite its presence in the areas, it is infeasible that any local effect on this species would result in its IUCN threat level being raised. Critical Habitat has not been triggered for this species.
Sicista loriger Nordmann's VU No No No No No It is known to exist in only 7 Birch Mouse areas in Ukraine, the Tarutyno Steppe (Rusev et al. 2012), Kherson (Cserkész et al. 2015), Black Sea Reserve (Selyunina 2005), Askania nova (Zagorodniuk and Kondratenko 2000), Khomutovsky Steppe (Zagorodniuk and Kondratenko 2000), Dnipro- Orel reserve (Antonets and Shumkova 2008), Provalskaya steppe (Zagorodniuk and
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Kondratenko 2000). Nordmann’s Birch Mouse occupies sand, shrub and forest steppes, un-mowed grasslands with herbaceous vegetation, and pastures. Dnipro-Oril Floodplains protected area approximately 16km from the Seredniodniprovska project site. This species is not thought to be found outside this protected area due to its specific habitat requirements of undisturbed steppe and shrubland habitat, where most of the surrounding habitat is heavily modified, including the area planned for construction. Critical Habitat has not been triggered for this species.
Bovista Fen Puffball VU No No No No No The species is known from the paludosa Northern Hemisphere: Europe (lowlands, lower mountain regions, seldom above 1200 m. Widely present in Ukraine (IUCN). It is a saprotrophic species, frequently growing among mosses, solitary or in small groups in a rather wide range of wet mossy habitats (Wojewoda 2002, Fraiture and Otto 2015). It occurs most often in alkaline to neutral fens, bogs and mires, wet meadows including boggy peat meadows, wet heaths and sometimes in forest meadows, from June to October. This species is deemed unlikely to be present in any of the 5 AoIs, as none are within wetland areas, but rather in dry grassland and shrubland habitats. This species is also known from undisturbed wetland habitats, whereas the
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development sites are generally within modified habitat. Critical Habitat has not been triggered for this species.
Cuphophyllus Toasted VU No No No No No This is a widespread species colemannianus Waxcap across Europe. The species mostly occurs in semi-natural, nutrient poor, extensively managed grasslands. These grasslands are not found near any of the sites and so it is infeasible that any local effect on this species would result in its IUCN threat level being raised. Critical Habitat has not been triggered for this species.
Hygrocybe Blushing VU No No No No No Widespread across Ukraine. ovina Waxcap Hygrocybe ovina is a member of species rich fungal communities occurring in traditionally managed old semi-natural grasslands. These types of grasslands are not found by any of the proposed sites; therefore, it is infeasible that any local effect on this species would result in its IUCN threat level being raised. Critical Habitat has not been triggered for this species.
Picipes VU No No No No No Picipes rhizophilus grows in the rhizophilus dry steppe zone in continental Eurosiberia (Russia, Ukraine, Kazakhstan), in the Mediterranean region (Algeria, Morocco, Tunisia), and in coastal dune areas, mostly in agreement with the host grasses. This specific habitat is not found near any of the proposed sites, and therefore, it is infeasible that any local
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effect on this species would result in its IUCN threat level being raised. Critical Habitat has not been triggered for this species.
Sarcodontia Orchard VU No No No No No The IUCN range overlaps with crocea Tooth most of Ukraine including all 5 sites. It is a saprotroph. It colonizes dead, dry branches or appears in bark cracks and rotted hollows of the trees in orchards, gardens, and roadsides. It causes white rot (Szczepkowski 2010). It is confined to mature and old trees in orchards, parks, and gardens. None of the 5 AoIs significantly overlap with orchards or gardens and mature fruit trees have not been identified as a significant habitat type in any of the 5 sites. Therefore, this species is unlikely to regularly occur within any of the AoIs. Critical Habitat has not been triggered for this species.
Hapalopilus Orange VU No No No No No IUCN shows range comes croceus Polypore close to Dnistrovska but does not actually overlap. Hapalopilus croceus grows on old and coarse veteran trees, mainly oak (Quercus) and more rarely on Chestnut (Castanea) in old growth forests, also on old oak trees in farmland, parks, and pastures. Critical Habitat has not been triggered for this species.
Brachythecium VU No No No No No Rare moss species. The global geheebii population is thought to be 250-400 individual-equivalents. In the Balkans and Hungary, this species grows mostly on rocks in shady areas, but it is also found in beech forests. In
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mountainous areas, it occurs on tree bases. It usually occurs at high elevations. Almost negligible range overlap with project AoI. Critical Habitat has not been triggered for this species.
Spalax Balkan Blind VU No No No No No IUCN range does not overlap graecus Mole Rat with AoI. Spalax antiquus and S. istricus were previously considered to be sub-species of S. graecus, however they are now recognised as separate species. Its range is very fragmented. It occurs in lowland and upland areas. In Ukraine, the species has not been recorded over the last 20-40 years and it may be severely reduced, or already extinct there (I. Zagorodnyuk 2006). It inhabits steppe grassland, pastures, small, cultivated fields and orchards, often preferring northern exposures. Critical Habitat has not been triggered for this species.
Baeospora VU No No No No No A saprotrophic wood- myriadophylla inhabiting species and grows on coarse trunks of fir, spruce, maple, or alder wood in their middle to final decay stage. It is widespread but rare in North America, Europe, and Asia. Altogether, it is known from about 400 localities. IUCN range indicates it could be present in Dnistrovska AoI. IUCN refers to GBIF database which shows the 400 localities. None of those localities are in Ukraine but the west of the country is thought to be suitable habitat. These habitat types have not been identified in the Dnistrovska AoI which is characterised as steppe,
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meadow-steppe grass vegetation and deciduous hornbeam-oak forests. Critical Habitat has not been triggered for this species.
Annex C: Criterion 3 – Detailed Assessment
A migratory species is defined in the IFC GN6 as a species of which a significant proportion of its members cyclically and predictably move from one geographical area to another (including within the same ecosystem). Congregatory species are defined as species whose individuals gather in large groups on a cyclical or otherwise regular and/or predictable basis. Under Criterion 3, more than 1% of the global population of a migratory or congregatory species must regularly occur within a projects AoI to meet Critical Habitat thresholds. Local and global population figures for the migratory and congregatory species present in high numbers close to the 5 sites were obtained and are presented in the table below. Percentages highlighted in red exceed the Criterion 3 threshold (>1%). Local populations relevant to each site are shown for Dnistrovka (DN), Kyiv (KY), Kaniv (KA), Kremenchuk (KR), and Seredniodniprovska (SE).
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Local population size (max) Global Percentage of global population pop size (max) (min)
Scientific Name Common Name DN KY KA KR SE DN KY KA KR SE
Chlidonias leucopterus White-winged Black <500 <500 10,500 <500 <500 3,100,000 <1% <1% 0.34% <1% <1% Tern
Ficedula albicollis Collared Flycatcher 700 <500 10500 <500 800 3,000,000 0.02% <1% 0.35% <1% 0.03%
Calidris pugnax Ruff <500 <500 10000 <500 <500 1,594,000 <1% <1% 0.63% <1% <1%
Zapornia parva Little Crake <500 <500 10500 500 <500 100,000 <1% <1% 10.50% 0.50% <1%
Porzana porzana Spotted Crake <500 <500 10500 500 <500 500,000 <1% <1% 2.10% 0.10% <1%
Sterna hirundo Common Tern <500 <500 10700 <500 <500 1,600,000 <1% <1% 0.67% <1% <1%
Tringa glareola Wood Sandpiper <500 <500 10500 <500 <500 3,100,000 <1% <1% 0.34% <1% <1%
Ixobrychus minutus Little Bittern <500 <500 1500 500 <500 600,000 <1% <1% 0.25% 0.08% <1%
Gavia arctica Black-throated Diver <500 <500 11000 <500 <500 275,000 <1% <1% 4.00% <1% <1%
Ardea purpurea Purple heron <500 <500 500 <500 <500 180,000 <1% <1% 0.28% <1% <1%
Botaurus stellaris Bittern <500 <500 1000 <500 <500 115,000 <1% <1% 0.87% <1% <1%
Casmerodius albus Great Egret <500 <500 1000 <500 <500 590,000 <1% <1% 0.17% <1% <1%
Chlidonias hybridus Whiskered tern <500 <500 1000 <500 <500 300,000 <1% <1% 0.33% <1% <1%
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Chlidonias niger Black tern <500 <500 500 <500 <500 800,000 <1% <1% 0.06% <1% <1%
Circus aeruginosus Marsh Harrier <500 <500 500 <500 <500 500,000 <1% <1% 0.10% <1% <1%
Falco vespertinus Red-footed Falcon <500 <500 500 <500 <500 300,000 <1% <1% 0.17% <1% <1%
Grus grus Common Crane 500 <500 1000 <500 <500 491,000 0.10% <1% 0.20% <1% <1%
Mergus albellus Smew <500 <500 1000 <500 <500 130,000 <1% <1% 0.77% <1% <1%
Nycticorax nycticorax Night heron <500 <500 500 <500 <500 570,000 <1% <1% 0.09% <1% <1%
Ciconia ciconia White Stork 500 <500 <500 <500 <500 700,000 0.07% <1% <1% <1% <1%
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