6.18.09074.GLA.R.002

B6

SyvashEnergoProm LLC

Syvash Wind Farm

Environmental and Social Management Plan

04 April 2019

Syvash Wind Farm - Environmental and Social Management Plan

Report Details

Client: SyvashEnergoProm LLC

Client Contact: Boerge Tvorg

Report Distribution:

SyvashEnergoProm LLC: Boerge Tvorg, Thorstein Jenssen

Wood: Chris Parcell, File

Report Classification: Confidential

Approval Record

Name Job Title Signature

Prepared by: Vicky McLean Senior Consultant SIGNED

Craig Morton Senior Consultant SIGNED

Reviewed by: Suzy Yendell Senior Consultant SIGNED

Authorised by: Director of Feasibility Chris Parcell SIGNED and Development

Date of issue: 04 April 2019

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Amendment Record

Revision Date Summary of Amendments Purpose of Revision Number

A1 26/04/2018 n/a First draft

A2 01/05/2018 Minor amendments following Internal authorisation review

B1 09/05/2018 Minor amendments following Client issue authorisation

B2 27/09/2018 Updated to reflect ESIA Addendum Client issue

B3 11/10/2018 Updated with revised bat Client issue mitigation measures

B4 20/12/2018 Updated to reflect updated Client issue ecology & ornithology reporting.

B5 28/03/2019 Updated to reflect contact details, Client issue pre-construction ecology / bat survey protocols and monitoring requirements.

B6 04/04/2019 Minor edits Section 3. Client issue

NOTICE

This document entitled Environmental and Social Management Plan, document number 6.18.09074.GLA.R.002 B6 has been prepared solely for SyvashEnergoProm LLC in connection with Syvash Wind Farm. This document in whole or in part may not be used by any person for any purpose other than that specified, without the express written permission of Wood Group UK Limited.

Any liability arising out of use by a third party of this document for purposes not wholly connected with the above shall be the responsibility of that party who shall indemnify Wood Group UK Limited. against all claims costs damages and losses arising out of such use.

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Contents

1 Introduction ...... 8

1.1 Aims and Scope of the Environmental and Social Management Plan (ESMP) ...... 8

1.2 Implementation of the ESMP ...... 8

1.3 Structure of the ESMP ...... 9

2 SyvashEnergoProm LLC Environmental and Social Policy...... 10

2.1 SyvashEnergoProm LLC’s Commitment ...... 10

2.2 Providing a Healthy and Safe Working Environment ...... 10

2.3 Public Safety ...... 11

2.4 Community Engagement ...... 11

3 Roles and Responsibilities ...... 12

3.1 Corporate Management Structure ...... 12

3.2 Responsibilities ...... 12

3.3 Contact Details ...... 13

3.3.1 SyvashEnergoProm LLC ...... 13

3.3.2 EPC Contractor ...... 13

3.4 Environmental and Social Management Plan (ESMP) ...... 14

3.4.1 SyvashEnergoProm LLC ...... 14

3.4.2 EPC Contractor ...... 14

3.4.3 Plan Hierarchy ...... 15

4 Compliance with Legal Requirements ...... 22

4.1 Ukrainian Legislation ...... 22

4.2 International Criteria ...... 22

5 Environmental and Social Baseline ...... 23

5.1 Summary of Site Environmental Conditions ...... 23

5.1.1 Landscape Conditions ...... 23

5.1.2 Terrestrial Ecology ...... 23

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5.1.3 Birds ...... 35

5.1.4 Hydrology and Hydrogeology ...... 39

5.1.5 Geology and Soils ...... 40

5.1.6 Cultural Heritage ...... 41

5.1.7 Noise ...... 43

5.1.8 Transportation ...... 44

5.1.9 Socio-Economic Conditions ...... 45

5.2 Aviation ...... 50

6 Overview of Construction Works ...... 52

7 Management and Mitigation Measures ...... 53

7.1 General Management Approach ...... 53

7.1.1 Management Awareness ...... 53

7.1.2 Grievance and Incident Procedures ...... 53

7.1.3 HSE Performance Reviews ...... 54

7.1.4 Project Environmental Committee ...... 55

7.1.5 Occupational Health and Safety ...... 56

7.2 Potential Environmental and Social Impacts and Mitigation ...... 57

8 Monitoring of Environmental and Social Performance ...... 71

8.1 Monitoring Programme ...... 71

8.2 Key Performance Indicators ...... 71

8.3 Reporting ...... 71

9 ESMP Review ...... 72

9.1 Scheduling and Managing Reviews ...... 72

10 Record Keeping ...... 73

...... Key Performance indicators 74

...... Monitoring Checklist 76

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...... Pre-Construction Ecology Survey Protocol 80

...... Bat Survey Protocol 81

Tables

Table 3-1: Summary of Environmental and Social Plan Hierarchy ...... 16

Table 5-1: Background Noise Levels, LA90 + 2 dB, (Approximate LAeq) ...... 44

Table 7-1: Summary of Impacts and Mitigation ...... 58

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Glossary

Abbreviation or Term Definition

BOP Balance of Plant

EBRD European Bank of Reconstruction and Development

EHS Environment, Health and Safety

EIA Environment Impact Assessment

EPC Engineering, Procurement and Construction

EPs Equator Principles

ESAP Environmental and Social Action Plan

ERE-AB SyvashEnergoProm LLC

ERP Emergency Response Plan

ESMP Environmental and Social Management Plan

ESIA Environmental and Social Impact Assessment

GIS Geographical Information Systems

Ha Hectare. Equivalent to an area of 10,000m2

HGV Heavy Goods Vehicle

IFC International Finance Corporation

IUCN International Union for the Conservation of Nature

LCT Landscape Character Types

LVIA Landscape and Visual Impact Assessment

NES National Environmental Strategy

Red Data Book. - The IUCN Red List of Threatened Species is a RDB comprehensive, global approach for evaluating the conservation status of plant and animal species.

SEP Stakeholder Engagement Plan.

Vantage Point when used in the context of ornithological surveys to describe a specific location chosen to undertake bird surveys. VP Viewpoint when used to describe specific locations used to assess visual impacts.

WMP Waste Management Plan

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Abbreviation or Term Definition

WTG Wind Turbine Generator

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1 Introduction

1.1 Aims and Scope of the Environmental and Social Management Plan (ESMP)

This ESMP for the construction phase sets the standards of environmental performance for Syvash Wind Farm.

These standards will form the basis against which the Project site will be measured during environmental audits. The primary purpose of this document is to act as the mechanism by which the project developer and sub-contractors will incorporate the requirements of the ESIA, together with Equator Principles and EBRD Performance Requirements, into the construction and operation of the wind farm.

This ESMP for the Syvash Wind Farm will enable factors that affect wind farm construction, operation and decommissioning to be addressed. The ESMP will be further updated and expanded prior to commencement of construction, following the first construction site audit and on finalization of the SyvashEnergoProm LLC Environmental and Social Management System.

The document sets a number of objectives to ensure that the Project site is operated in an environmentally acceptable manner through managing the site’s significant environmental aspects. The scope of this ESMP for the Syvash Wind Farm includes all activities, whether conducted by SyvashEnergoProm LLC or other companies and sub- contractors that are part of the construction, operation and decommissioning of the wind farm. It will be detailed in all contractor’s contracts that they will have to demonstrate compliance with the sections of this ESMP relevant to their activities.

Each significant aspect has one or more objectives, which are followed by mitigation measures to ensure that the objectives are met through operational controls.

An Environmental Manager will be established to communicate progress of site operations and report the internal environmental performance audit results during the construction phase.

As outlined above the ESMP will be reviewed and updated as a live document prior to and during the construction phase.

1.2 Implementation of the ESMP

In order to successfully implement the ESMP, the following key tasks will be undertaken:

• Preparation of audit checklist based on the targets and objectives.

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• Undertake inspection/audit of the Project site and Project operations, including records of training, waste management etc. • Prepare a report detailing areas of compliance/non-compliance. • Prepare a list of actions (action plan) to address non-compliances with associated timescales for completion. • Audit the actions to ensure issues have been addressed.

It will be the responsibility of SyvashEnergoProm LLC to monitor the effectiveness of the project ESMP and identify improvement actions as necessary.

1.3 Structure of the ESMP

The ESMP is structured as follows:

• Chapter 2: SyvashEnergoProm LLC Environmental and Social Policy. • Chapter 3: Roles and Responsibilities. • Chapter 4: Compliance with legal requirements. • Chapter 5: Environmental and Social Baseline. • Chapter 6: Management and Mitigation Measures. • Chapter 7: Monitoring of Environmental and Social Performance. • Chapter 8: Review of the Management Plan. • Chapter 9: Record Keeping.

These topics are discussed in subsequent chapters.

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2 SyvashEnergoProm LLC Environmental and Social Policy

2.1 SyvashEnergoProm LLC’s Commitment

This Plan identifies specific actions that SyvashEnergoProm LLC considers necessary to address the environmental and social (E&S) issues related to our business activities, in satisfying national and international standards.

From planning through to decommissioning, SyvashEnergoProm LLC regards their employees, contractors, and visitors as the top priority in their E&S performance. General Manager(s), Department Managers, Workers, and Contractors should all understand their roles and responsibilities, effectively implement the ESMP, and strive to achieve sustainable development and maintain ‘zero fatality.’

To reflect their commitment in detail, this ESMP has been developed to provide clear instructions on how to comply with the relevant requirements and how to implement procedures, so they ensure that the E&S risks are managed and mitigated properly. The ESMP clearly defines the standards of environmental performance for Syvash Wind Farm and the requirements for assessing, monitoring, and reporting E&S performance.

This ESMP will evolve and mature over the years to satisfy the needs of SyvashEnergoProm LLC’s business development. The Director and the E&S Manager shall ensure this ESMP is updated on a regular basis and are directly responsible for its effective implementation.

2.2 Providing a Healthy and Safe Working Environment

SyvashEnergoProm LLC is committed to:

• Minimising occupational accidents, incidents and occupational diseases.

• Integrating E&S performance into our operation processes and services.

• Promoting environmentally friendly product design and procurement.

• Holding the environment, health, safety, and community as our core values.

• Providing a safe workplace with ‘zero fatality’.

• Increasing public disclosure and transparency through community outreach.

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2.3 Public Safety

Whenever there is a business operation in or nearby residential communities, the likelihood for the residents being impacted increases. These potential risks and impacts must be properly managed to the level of maximum control achievable. SyvashEnergoProm LLC will effectively manage the risks by providing training to raise public safety awareness, and to maintain regular communication with community residents in order to understand their needs and concerns.

2.4 Community Engagement

SyvashEnergoProm LLC are committed to a programme of community engagement. The Project Stakeholder Engagement Plan seeks to define a technically and culturally appropriate approach to consultation and disclosure. The goals are to ensure that adequate and timely information is provided to Project-affected people and other stakeholders, that these groups are given sufficient opportunity to voice their opinions and concerns, and that these concerns influence Project decisions.

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3 Roles and Responsibilities

3.1 Corporate Management Structure

The following chart shows the corporate management structure in relation to the various environmental and social management aspects. This is indicative and will be updated once the EPC management team is confirmed.

SyvashEnergoProm LLC Environmental & Social Manager

Owners Engineer (Wood)

EPC Contractor (Power China) Environmental & Social Manager

3.2 Responsibilities

Responsibilities of parties of the Syvash Wind Farm project are presented below. The responsibility of implementing the specific actions stated in the ESMP will be set out in the SyvashEnergoProm LLC Environmental and Social Action Plan (ESAP).

SyvashEnergoProm LLC has the overall responsibility of developing, reviewing, and updating the ESMP. It will also, on a regular basis, monitor and audit the implementation of the ESMP. SyvashEnergoProm LLC will provide appropriate training for their staff in relation to implementing the ESMP.

The Construction Phase Owners Engineer (Wood) contracted by SyvashEnergoProm LLC, will be responsible for overseeing of the implementation of the ESMP and relative contract obligations of the contractors.

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The EPC contractor (Power China) shall be responsible for management of the construction site and their activities in compliance with the ESMP, the relevant laws and regulations and the international standards set out in the ESMP, including taking the required precautions, carrying out the necessary actions to minimise environmental and social impacts that may occur during the construction of Syvash Wind Farm. Powerchina will be responsible for providing the required personnel.

SyvashEnergoProm LLC shall periodically review and monitor the implementation of the ESMP and provide guidance and support in the framework of its ESMS.

The Lenders and Shareholders will require compliance with the respective performance standards and requirements.

3.3 Contact Details

3.3.1 SyvashEnergoProm LLC

SyvashEnergoProm SyvashEnergoProm

Luidmya Goncharenko Anatolii Aleksieiev

Environmental Manager Health and Safety Manager

33 Sadova str., v.Hryhorivka, 33 Sadova str., v.Hryhorivka,

Kherson oblast, , Ukraine

+38 (055) 270-83-91 +38 (055) 270-83-91 [email protected] [email protected]

3.3.2 EPC Contractor

Denys Shofolov

EHS Manager

Nova Kakhovka City,

5 Promyslova Str,

Kherson region, Ukraine

Tel: +38 (067) 321-77-50 [email protected]

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3.4 Environmental and Social Management Plan (ESMP)

3.4.1 SyvashEnergoProm LLC

SyvashEnergoProm LLC’s Project Environmental and Social Management System consists of the following documents:

• Corporate Environmental and Social Management System (ESMS).

• Environmental and Social Action Plan (ESAP).

• Environmental and Social Management Plan (ESMP).

• Stakeholder Engagement Plan (SEP).

SyvashEnergoProm LLC’s Project ESMP will be the primary ESMP which provides overall control over the Project and contractors. Where discrepancies occur, SyvashEnergoProm LLC’s Project ESMP will take precedence over the sub-contractor’s management plans with the exception of health and safety issues.

The EPC contractor, PowerChina, will be the principle contractor on site and all work on site including that of SyvashEnergoProm LLC’s staff will be in accordance with the provisions of the EPC contractor’s H&S Plan and environmental and social sub plans presented in Table 3-1.

The ESMP will be updated prior to the Project’s operational phase to ensure all operational requirements and management plans are captured within the document.

3.4.2 EPC Contractor

Power China’s documentation will be developed in accordance with ISO14001 and ISO9001 and OHSAS18001 requirements. This will ensure best practise procedures for environmental, quality and health and safety management, in addition to complying with international lenders standards and guidelines.

The EPC contractor will adhere to SyvashEnergoProm LLC’s ESMS, ESAP, ESMP and SEP.

In addition, the EPC contractor will develop and implement the following plans:

• Environment management plan (including pollution prevention).

• Environmental and Social Responsibility Plan.

• Occupational health and safety management plan.

• Construction phase health and safety plan.

• Quality management plan.

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• HSEQ Monitoring Plan.

• QHSE competence assessment.

• Waste management plan.

• Hazardous materials safety and management plan (including spill prevention).

• Water and wastewater management plan.

• Dust management plan.

• Noise management plan.

• Flora and fauna management plan.

• Site reinstatement plan.

• Archaeological / cultural heritage chance find procedure.

• Noise management plan.

• Traffic and road safety / traffic management plan.

• Emergency preparedness and response plan.

• Community health and safety plan.

• Camp management plan / worker code of conduct.

• Security management plan.

• Local hiring plan.

• Communicable diseases management plan.

• Human resources policy (including worker grievance mechanism).

3.4.3 Plan Hierarchy

The hierarchy of management plans is set out below.

As outlined above the EPC contractor, PowerChina, will be the principle contractor on site and all work on site including that of SyvashEnergoProm LLC’s staff will be in accordance with the provisions of the EPC contractor’s H&S Plan and environmental and social sub plans presented in the table below. Where discrepancies occur, SyvashEnergoProm LLC’s Project ESMP will take precedence over the sub-contractor’s management plans with the exception of health and safety issues.

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Table 3-1: Summary of Environmental and Social Plan Hierarchy

Title Issues Phase Responsibilities

Environmental and Covers overarching project specific Construction & SyvashEnergoProm social management environmental and social management, Operation LLC plan. key performance indicators and monitoring requirements.

This plan will form the overarching plan, and in the event of a dispute, will take precedence over the Contractors’ plans.

Stakeholder Outlines procedures for stakeholder Construction & SyvashEnergoProm engagement plan. engagement, past and planned Operation LLC consultation / engagement.

Also sets out Project grievance mechanism.

The SEP will guide all stakeholder engagement activity undertaken by all project employees and contractors.

Environment Outlines overarching environmental Construction EPC management plan management for construction phase, includes pollution prevention.

Environmental and Sets out environmental and social Construction EPC social responsibility responsibilities. plan

Occupational health Detailed project-specific health and safety Construction & EPC and safety plan plan outlining preventative and protective Operation measures and training measures to minimise risk.

Construction phase The Plan includes management Construction EPC health and safety arrangements for health, safety and plan welfare of all those working on site, and ensuring the Plan is implemented and routinely monitored during the works.

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Title Issues Phase Responsibilities

Quality Sets out the policy, objectives and strategy Construction EPC Management Plan for quality management.

Provides a framework for quality management, contractor management, monitoring and review.

Outlines how client expectations for quality management, including those set out in the EPC contract, will be met

HSEQ Monitoring The HSEQ Monitoring Plan defines Construction EPC Plan. auditing and inspection activities for health, safety, environmental and quality management arrangements.

QHSE competence Sets out systems and processes in place to Construction EPC assessment. assess contractors QHSE competence / supply chain management.

Waste management Set up project waste management matrix Construction & EPC plan to determine most appropriate disposal Operation method for a given waste stream updated throughout Project.

Waste hierarchy developed.

Obtain any necessary permits.

Storage of different waste types.

Engagement of waste specialist to dispose of waste.

Recording of all wastes disposed off-site and reported monthly.

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Title Issues Phase Responsibilities

Hazardous Approval of materials prior to being Construction & EPC materials brought onto site. Operation management plan Identification of suitable storage and (including spill handling methods for hazardous wastes in prevention). accordance with manufacturer’s Material Safety Data Sheets (MSDs).

Hazardous Materials Register to be developed.

Identification of area for refuelling.

Identification of suitable PPE and training.

Spill prevention plan.

Water and Detail methodology for handling and Construction & EPC wastewater disposal of waste water. Operation management plan. Identify approved contractor for disposal of wastewater to water treatment facility.

Outlining water management and water quality control.

Dust management Identification of actions required to Construction EPC plan. minimise dust and other substances into the atmosphere.

Noise management Identification of actions required to Construction & EPC plan. minimise disturbance to communities Operation including restriction of working hours, personal protective equipment, regular maintenance and inspection of machinery, substitution of an alternative process, noise monitoring, complaints management, noise compliance testing on operation etc.

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Title Issues Phase Responsibilities

Flora and fauna Plan outlining mitigation to be Construction & EPC management plan. implemented including monitoring Operation requirements.

Identification / demarcating areas on site which are to be protected.

Worker training, communication / reporting procedures and toolbox talks.

Identification of responsible person(s) for reporting.

Site Reinstatement Development of plan to restore site Construction EPC Plan. following construction works.

Cultural heritage Development of provisions for protecting Construction SyvashEnergoProm management plan. existing features identified on site and LLC managing chance finds on site through a chance finds procedure applied in the event that any cultural heritage is discovered.

Worker training, communication / reporting procedures and toolbox talks.

Archaeological / Development of provisions for protecting Construction EPC cultural heritage existing features identified on site and chance find managing chance finds on site through a procedure. chance finds procedure applied in the event that any finds are discovered.

Worker training, communication / reporting procedures and toolbox talks.

Traffic and road Plan to identify, evaluate and monitor the Construction & EPC safety / traffic potential traffic and road safety risks to Operation management plan workers and affected communities throughout the project life cycle and develop measures to address risks.

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Title Issues Phase Responsibilities

Emergency Identify potential environmental Construction & EPC preparedness and emergencies and responses. Operation response. Selection and training of emergency response personnel.

Identify locations for provision of spill kits and training for use.

Inductions for staff and display of information on site.

Community health Communications / consultation procedure. Construction & EPC and safety plan. Operation Set out details for complaints / grievance procedure and recording.

Provision of environmental committee with local stakeholders to discuss key issues.

Worker camp Worker camp management plan in Construction EPC management plan / accordance with Workers’ accommodation: worker code of processes and standards, guidance note by conduct. IFC and the EBRD.

Setting out code of conduct for workers.

Security Outlining site security arrangements as Construction & EPC management plan. required in accordance with IFC good Operation practise handbook – use of security forces: assessing and managing risks and impacts.

Local hiring plan. Plan setting out procedures for prioritising Construction & EPC the hire of local workforce where Operation reasonable and practical.

Communicable To include measures to avoid or minimise Construction & EPC diseases transmission of communicable diseases Operation management plan. associated with Project workers.

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Title Issues Phase Responsibilities

Human resources To include human resources policies and Construction & EPC policy (including worker grievance mechanism. Operation worker grievance mechanism).

Shadow flicker Measures to manage operational shadow Operation. SyvashEnergoProm management plan. flicker. LLC

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4 Compliance with Legal Requirements

SyvashEnergoProm LLC will follow procedures and guidelines set out in their ESMS. Another key consideration of this ESMP is making sure all activities comply with national and international legislation and standards.

4.1 Ukrainian Legislation

The below mentioned laws and regulations include the legal requirements to reduce environmental impacts that may occur during construction activities of Syvash Wind Farm:

• Law of Ukraine on Environmental Protection. • Law of Ukraine on Flora. • Law of Ukraine on Fauna. • DBN A. 2.2-1-2003 “Environmental Impact Assessment during Design and Construction”. • SNiP II – 12-77 “Protection from Noise”. • GOST 12.1.003-83 “Noise. General Safety Requirements”. • DSP 3.3.6.037-99 “Sanitary Regulations of Industrial Noise, Ultra- and Infrasound”. • Sanitary Norms of Permissible Noise in Residential and Public Buildings and on the Territory of Residential Development. The Sanitary Norms SN # 3077-84”. • Regulation No. 935 of the Cabinet of Ministers of Ukraine “On the Measures for Protection of Wetlands of International Importance” dated 23.11.1995. • Regulation No. 1287 of the Cabinet of Ministers of Ukraine “On the Procedure for Assignment of the Wetlands of International Importance Status to Wetlands” dated 29.08.2002. • CMU Resolution # 465 dated 25 March 1999, Kyiv On Approval of the Rules for Protection of Surface Waters against Pollution with Wastewater (as amended by CMU Resolution #748 (748-2013-п) dated 07.08.2013). • GOST 12.1.007-76 “SSBT (System of Occupational Safety Standards). Harmful Substances. Classification and General Safety Requirements”.

4.2 International Criteria

The Equator Principles, EBRD Performance Requirements, and the IFC Performance Standards (PS) were considered during the preparation of the ESMP as lenders requirements.

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5 Environmental and Social Baseline

5.1 Summary of Site Environmental Conditions

5.1.1 Landscape Conditions

The Syvash is Europe’s largest shallow salt-water bay (lagoon of the Azov Sea), one of the most valuable territories within the Azov- ecological corridor and Europe as a whole. There are two Ramsar land sites in this area: the Central Syvash and Eastern Syvash. The water area of the Western Syvash adjacent to the Project site is not part of the wetlands.

The water area of the Syvash occupies about 2,640 km2 and is characterized by a very complex configuration of the coastline. Shoreline is low, flattened, foggy, and in the summer covered with a layer of salt. A system of small bays has formed here, which are divided by small peninsulas, spits; large, small and very small islands are scattered in the bays. In general, it is a maze of shallow water and semi-desert landscapes. The Syvash forms numerous bays, peninsulas and more than 60 islands. The northern and western shores of the Syvash are heavily cut, with winding outlines.

According to the physical-geographical zoning of Ukraine, the project area is located in the Syvash-Pryazovia lowland steppe of the Black Sea-Pryazovya dry-steppe biotic province. This landscape type is representative of the wider area. The following smaller landscape character types have been identified within the Project’s area of influence.

• Syvash-Pryazovia lowland steppe. • Syvash lake. • Small villages and settlements.

The Project would be located on the boundary of the Syvash-Pryazovia lowland steppe and Syvash lake LCTs.

5.1.2 Terrestrial Ecology

5.1.2.1 Designated Sites

There are no designated sites included within the search area around Project that are designated specifically for their value for terrestrial ecology and or terrestrial receptors they support.

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5.1.2.2 Habitats and Vegetation

The majority of the Project site is or has been affected by agricultural activities, such as cultivation of crops or grazing by livestock. Habitats within the agricultural areas include arable, steppe and grassland meadows. It is noted cultivated land within the Project site is related to an experimental agriculture project managed by the Project and will not progress after 2018.

Arable fields dominate flat inland areas within and immediately to the north of the Project site. At the time of the 2018 surveys much of the arable areas were cultivated with a variety of crops evident but where fields had been left uncultivated and fallow and/or dense ruderal vegetation was present. Russian Knapweed (Acroptilon repens) continues to dominate the ruderal vegetation with Cardario-Agropyretum, Convolvulo-Agropyretum repentis, Lepidietum drabae, Xanthietum spinosi, Melilotetum albi-officinalis, Artemisietum absinthii, Polygonetum avicularis, Bromo-Hordeetum murini, Ambrosio-artemisifoliae- Cirsietum setosi, Erigero-Lactucetum serriolae, Cirsio-Lactucetum serriolae, Cynancho acuti-Convolvuletum arvensis, Bromo-Hordeetum murini, Atriplicetum tataricae and Plantagini-Polygonetum avicularis also present. Field margins and fallow vegetation are dominated by Artemisia Taurica, Lepidium perfoliatum, Poa bulbosa, Bromopsis riparia, Eryngium campestre, Anthemis ruthenica, Senecio vernalis, Salvia aethiopis, Lamium amplexicaule, Descurainia Sophia, Carduus acanthoides, Cardaria draba and Convolvulus arvensis all also evident.

Steppe vegetation is present where areas are uncultivated or have avoided recent cultivation, such as margins between fields and tracks where tree shelter belts were once present and steeper slopes adjacent to drainage channels and wetland areas. The majority of these area are heavily grazed and badly degraded by livestock and are essentially secondary meadows growing on areas that would have formally been steppe grassland habitats. Species noted within these areas and usually associated with Steppe habitats include Festuca valesiaca, Elytrigia repens, E. іntermedia and E. preudocaesia as well as Elytrigia repens, Elytrigia preudocaesia, Alopecurus arundinaceus, Calamagrostis epigeos and Bromopsis riparia.

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Meadows are present in low lying areas around the edges of wetlands (both saline and freshwater) and within depressions where more moisture is present. In areas where seasonal flooding occurs, halophytic-beamed plant communities of Puccinellietum distans, Juncetum gerardii and Puccinellietum (aeluroposum) littoralis, Juncus maritimus, Eleocharis mitracarpa, Crypsis aculeata), Alisma gramineum and Ranunculus scleratus occur. Elytrigia elongata dominates lower areas of the meadow habitat as well as in more damp areas where there are formations of saline meadows. In these areas Puccinellietum distans and Juncetum gerardii also occur. Almost all meadows within the Project area are badly degraded as a result of excessive grazing and periodic burning. Although not located during the 2018 surveys, one species listed in the Red Book of Ukraine (2009) – Lepidium syvaschicum was found within the flood meadow habitats during previous surveys and this species is also listed in the European Red List (1991).

Freshwater wetlands which consist of waterbodies dammed off from saline water and surrounded by vegetation are scattered along the length of the Project site. Drainage channels seasonally filled with freshwater are also present behind the steep embankment and adjacent to existing access tracks running along the edge of the coast from the current wind farm east.

Aquatic vegetation includes Potamogeton pectinatus., Lemna triscula., Ceratophyllum demersum and Вatrachium kаuffmаnnii whilst marginal vegetation is dominated by dense stands of Phragmites australis and occasional stands of Typha angustifolia.

Extensive saline areas of the Western Syvash border the southern edge of the Project site with a saline inlet extending up into the far western part of the site. Vegetation in these areas is almost non-existent due to the high salinity and pollution with bare mud dominateing around the edges of any water. Stands of Phragmites australis do however occur along sheltered parts of the shoreline and on some of the offshore islands. Some Elytrigia elongate, Puccinellietum distans and Juncetum gerardii is present in areas above the level of regular inundation by saline water.

The communities of Pershokostiantynivka, Hryhorovka, Pavlivka, Novovolodymyrivka, Strohanivka and Ivanivka are all in close proximity to the Project site.

No species of national or international importance were found during the 2018 surveys. Lepidium syvaschicum was found during previous survey work and remains the only botanical species found on site that is listed within the Ukraine Red Book and European Red List. This species was only found to be present within meadow habitats at the far eastern end of the Project site and not within areas affected by WTGs or proposed access routes.

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Alien and/or invasive plant species are not currently frequent in habitats within or adjacent to the Project site.

Habitats Affected by the Proposals

Habitats present at the far western end of the Project site (Area A) include extensive meadows and areas of currently or previously cultivated arable and heavily grazed vegetation that includes steppe plant species. Freshwater and saline wetlands are also in close proximity to some of the WTGs and access routes. These habitats and WTG and access route locations are shown in Figure 5-1.

Figure 5-1: Habitats within Area A

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WTGs 1 and 3 will be located within arable habitat whilst WTGs 2 and 8 will be on the edge of arable and meadow habitats. WTGs 4, 6, 7, 9, 11, 13, 15 and 16 will all be located within meadow habitat grazed by livestock. WTGs 10 and 12 will be within habitat with steppe characteristics, although these areas are in close proximity to farms and the village and heavily grazed and disturbed. WTG 8 is located immediately adjacent to a freshwater wetland and WTGs 4, 9 and 11 are adjacent to saline habitats.

The proposed access routes will mainly utilise existing routes around the northern, western and eastern parts of Area A. Additional routes will however be created through mainly arable and meadow habitats with a short section through steppe habitat between WTG 12 and 10.

Habitats present within Area B include a mix of meadows, currently or previously cultivated arable, heavily grazed vegetation that includes steppe plant species, freshwater wetlands and saline habitats. These habitats and WTG and access route locations are shown in Figure 5-2.

Figure 5-2: Habitats within Area B

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WTGs 17, 18, 19, 20, 21, 22, 25 and 27 will all be located within meadow habitats that are currently grazed by livestock. WTGs 24, 26, 28 and 30 will be within an arable field that had been cultivated for crops in 2018. WTGs 23, 29, 31 and 33 will be within habitat with steppe characteristics, although WTGs 29, 31 and 33 are in close proximity to farms and the existing wind farm operations and heavily grazed and disturbed.

WTGs 17, 18, 20, 21, 22, 25, 27 and 31 will be adjacent to wetland areas with the main access route between Area A and Area B passing over a dam separating freshwater and saline wetlands.

The proposed access routes will mainly utilise existing routes associate with the village at the western end of the area and existing wind farm at eastern end. Additional routes will however be created through meadow habitats with a short section through steppe habitat to get to WTG 31.

Habitats present within Area C are dominated by extensive arable under cultivation during 2018. Strips of uncultivated steppe habitat are present around the edges of Area C and this habitat also occurs alongside many of the existing tracks and field margins where woodland shelter belts have been reduced to scattered individual trees. A narrow strip of meadow and saline habitats are present beyond the drainage channel and embankment that runs along the southern and eastern edge of Area C. These habitats and WTG and access route locations are shown in Figure 5-3.

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Figure 5-3: Habitats within Area C

Apart from WTG 51 all WTGs will be within cultivated arable habitats. WTG 51 will be located with steppe margins on the edge of an arable field. The majority of access routes within Area C will utilise existing tracks but where necessary new routes will only affect arable habitats and potentially small areas of steppe field margin.

Habitats present within Area D are a mix of steppe and meadow with a village on the northern edge and extensive arable fields to the north and east. A strip of meadow and saline habitats are present beyond the drainage channel and embankment that runs along the southern edge of Area D. These habitats and WTG and access route locations are shown in Figure 5-4.

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Figure 5-4: Habitats within Area D

WTG 50 will be located within an undulating uncultivated area of steppe, which is close to the village and farms and therefore heavily grazed and disturbed. WTGs 52, 53 and 54 will be within areas of meadow between an existing main track and uncultivated fields where steppe vegetation is present.

Proposed access routes will utilise an existing track that runs adjacent to the drainage channel and embankment along the southern edge of Area D. New routes will be created to access the WTG locations, and these will affect small areas of steppe and meadow habitat.

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Habitats present within Area E are dominated by extensive arable under cultivation during 2018. Patches and strips of uncultivated steppe habitat are present on steep slopes around the freshwater wetland at the north-western edge of Area E and adjacent to the existing track and drainage channel embankment that runs along the southern edge of the area. As well as the freshwater wetland at the north-western edge another freshwater wetland with open water and surrounding reedbeds is present in the middle of Area E. Narrow strips of meadow and vegetation associated with saline habitats are present along the southern side of the embankment. These habitats and WTG and access route locations are shown in Figure 5-5.

Figure 5-5: Habitats within Area E

WTGs 55 and 56 will be located within an area of steppe vegetation. WTGs 57, 58, 59, 60, 61 and 62 will all be within cultivated arable fields. WTGs 57, 59 and 60 will be in close proximity to the freshwater wetlands.

Proposed access routes will utilise an existing track that runs adjacent to the drainage channel and embankment along the southern edge of Area E. New routes will be created to access the WTG locations, and these will mainly affect arable habitats with small areas of steppe affected by short spur routes to access WTG 55 and 56.

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Habitats present within Area F are a mix of arable fields under cultivation during 2018, meadows, strips of steppe vegetation and two areas of freshwater wetland with open water and surrounded by dense reedbeds and scattered trees. An existing track and drainage channel embankment runs along the southern edge of the area, including across the dam that separates the freshwater wetlands from the saline habitats to the south of the embankments. A narrow strip of meadow habitat is located between the saline shoreline and embankment at the western part of Area F. These habitats and WTG and access route locations are shown in Figure 5-6.

Figure 5-6: Habitats within Area F

WTGs 63, 64, 67 and 68 will all be within cultivated arable fields. WTG 66 will be within meadow habitat between cultivated fields and the freshwater wetland habitats.

Proposed access routes will utilise an existing track that runs along the embankment between the drainage channel and saline habitats and over the dam between the freshwater wetland and saline habitats. New routes will be created to access the WTG locations, and these will mainly affect arable habitats with small areas of meadow around WTG 66 also affected.

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5.1.2.3 Fauna

No evidence of Otter was found within or adjacent to the Project site during the May 2018 surveys. The freshwater wetland habitats do appear suitable for Otter with the lakes at the western and eastern ends of the Project site supporting fish, but the saline habitats are unsuitable for Otter and as the drainage channels and watercourses are dry for large periods during the year, they are isolated from larger and more permanent watercourses. Eurasian Otter are listed as Vulnerable in the National Red Data Book, Near Threatened by the IUCN and are also included on Annex II of the EU Habitats Directive.

It is assumed that large mammals including Wild Boar and Deer could be present within and or adjacent to Project based upon species range. European Mink which are listed as Critically Endangered by both the IUCN and the National Red Data Book are considered to be absent based on known geographical ranges.

Ponds and wetland areas are present in the villages located within Project buffer zones are suitable breeding habitats for amphibians.

Two species of snake (Caspian Whip Snake and Eastern Steppe Viper) were recorded in or within the buffer zone of Project. Grass Snake, Blotched Snake and Smooth Snake are also known to occur in the biogeographical area of the Project. Eastern Steppe Vipers have been recorded on a number of occasions by the bird surveyors completing spring migration surveys in April and May 2018. A minimum of three observations were made with two records in meadow habitat at the far western end of the Project site and one in meadow habitat adjacent to VP2. No other reptiles have been recorded during 2018 but amphibians (European Common Spadefoot and Marsh Frog) were common in freshwater wetland habitats.

Habitats within Project are largely agricultural which are unsuitable for hibernating, breeding, foraging and commuting reptiles, however edge habitats (shelter belts, ruderal, wetlands, field margins, verges etc.) are all ideal habitats for reptiles for breeding, hibernating and commuting.

During 2018 surveys up to 13 species of bat were recorded in total across the summer survey period, of these, five are considered to be at medium or low risk from collision with wind turbines and eight considered to be at higher risk. Kuhl’s/Nathusius’ Pipistrelle were the most frequently encountered bat. Pipistrelles as a group accounted for a high proportion of registrations. There were 22 Transects completed in June 2018 with a total of 377 passes registered over this period. Kuhl’s/Nathusius’ Pipistrelle (Pipistrellus kuhlii/nathusii) were the most commonly encountered bat with 144 passes recorded,

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Assessment by transect point has shown that areas near to freshwater wetlands and villages were used more than those in saline habitats and arable farmland locations.

Recorded bat activity on transects was highest in August 2018, with approximately double the recordings when compared with June. Increases in activity during this month could be accounted for with the emergence of young bats from nursery colonies, as well as the early movements of migrating species - highlighted in particular by the increase in numbers of Nyctalus species and Vespertillio murinus which are known to migrate between breeding and hibernation sites in this region of the continent. This correlates with the results from previous surveys at the site which also showed higher levels of activity in August than in other months.

At risk species were encountered on average between 9.05 times and 17.8 times per transect per visit. This represents what would be considered a typical level of activity for a site with the habitat types present.

The species most frequently recorded during the static detector surveys were Pipistrellus kuhlii (596 passes) and Nyctalus noctula (546 passes), which account for 27% and 25% respectively of all recorded passes, or 52% of passes when combined. The months with highest activity were May and June however equipment failure in July and August limited the amount of data collected over these two months meaning direct comparison between transect and static results is not possible. Static detector surveys completed between May and September 2018 identified 13 species of bat using the four locations surveyed. Higher risk species made up the majority of calls recorded with 84% of passes in May, 73% of passes in June, 58% of passes in July and 92% of passes in September being from species listed as high risk

Roost search surveys confirmed just a single roosting location within a large crack on the eastern aspect of a concrete bridge over the drainage channel approximately 180m west of WTG 54. A small number (3) of small bat droppings (characteristic of a pipistrelle species) were present in the entrance to the crack. No bats could be seen within the crack and no bats were recorded during further survey effort (emergence / re-entry surveys completed as part of transect surveys). No features suitable for roosting bats were found to be present in the trees scattered within and adjacent to the Project site and although scattered farm buildings and existing wind farm buildings do have features suitable for roosting bats no roosting bats or evidence of bats was found during searches or additional activity survey effort.

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Previous surveys recorded a total of 14 bat species utilizing habitats within and adjacent to the wind farm were identified and of these a single pass of Barbastelle and Giant Noctule were recorded during the survey effort. The most frequently recorded bats were Common Noctule, Kuhl’s and Nathusius’ Pipistrelle and Parti-colored bats with generally increased activity of Common Noctule in Spring 2017 and greater frequency of the Pipistrelle species in the autumn 2017 surveys.

5.1.3 Birds

5.1.3.1 Protected Areas

There are a number of protected areas in the vicinity of the Project in relation to birds. Karkinits'ka and Dzharylgats'ka Bays International Bird Area (IBA) is approximately 10 km south-south-west of the Project site. It consists of 87,000 ha and has a threat score of high, condition as very unfavourable and an action score of medium.1 The high threats to the site include fishing and harvesting of aquatic resources, agricultural and forestry effluent and domestic and urban waste water. Both the grassland and marine coastal areas are considered to be in poor condition and very unfavourable. The key species populations within the site which are considered to be very unfavourable include the Red- breasted goose, Mallard, Egretta garzetta, Slender-billed curlew, Sterna nilotica, Little turn, Caspian turn and White-tailed sea-eagle. Conservation management measures are being implemented to improve the protected area.

Askania Nova Biosphere Reserve is located 23 km north of the Project site and consists of plots of natural steppe with man-made ponds bordered by cultivated land. The site has populations of IBA trigger species including red-breasted goose, greater white-fronted goose, ruddy shelduck, demoiselle crane, common crane, black-winged pratincole, paillid harrier, water birds and soaring birds / cranes.

Syvash Bay IBA is located 24 km south-east of the Project site. An extensive system of lagoons with sandy islands and shores, surrounded by steppe, in the coastal zone of the Black Sea and . It is an important site for water birds and birds of the steppe biome.

1 http://datazone.birdlife.org/site/factsheet/karkinitska-and-dzharylgatska-bays-iba-ukraine

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5.1.3.2 Bird Species

A total of 44 species were registered in the Spring 2013 migration period involving 32,942 individuals. The most numerous species included ruff, Mediterranean gull, dunlin, pied avocet, common shelduck, gull-billed tern and black-winged stilt. During the Spring 2015 migration a total of 34 species were recorded (2,536 individuals). The most numerous species were ruff, rook, common starling, Eurasian skylark, mute swan and black-headed gull. Finally, during the 2017 Spring migration, 89 species were observed (14,232 individuals). Most numerous species were ruff, common starling, black-headed gull, Caspian gull, greater white-fronted goose, common shelduck and rook.

Autumn migration surveys in 2012 and 2017 resulted in peak counts of several notable species including white stork, lapwing, ruff, sandpipers, black-headed gull, Mediterranean gull, dunlin and slender-billed gull amongst others.

With regards to breeding birds, based on information from the 2010 to 2015 surveys, it was considered that the number of nesting birds in the Project area has significantly reduced during recent years. In 2017, a total of 37 species and 638 nests were recorded, although just 12 species were observed in the area of the Project with 38 nests confirmed. The largest numbers of nests were for great reed warbler, which are common in the region. Four Red Book of Ukraine species, glossy ibis (15 pairs), red-crested pochard (2 pairs), black-winged stilt (2 pairs) and oystercatcher pairs were recorded. None were confirmed as nesting within the Project area, although they were present in wetland habitats immediately adjacent.

Wintering bird surveys were completed in 2013, 2015 and 2017. During 2013, the most numerous winter gatherings were mainly of small numbers of common terrestrial species but mallards (3,390), common gulls (150) and rare observations of hen harrier and white- tailed eagle. The most abundant rare species were common goldeneye. In 2015, a total of 2,165 individuals of 19 species registered within Project area. Rooks had greatest numbers and species dominated by terrestrial species with aquatic species recorded. During 2017, a total of 11,189 individuals of 30 species were recorded but only 165 individuals were recorded within Project site, which was attributed to poor food supply. Most numerous birds within Project site were mallard (70) and common starling (40). Four Red Book Ukraine species were recorded: ruddy shelduck, hen harrier, white-tailed eagle and lesser short-toed lark.

The Preliminary ESIA identified a number of further survey requirements to include:

• Spring migration survey (Vantage point surveys and point count surveys).

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• Breeding birds survey (Vantage point surveys and point count surveys). • Autumn migration survey (Vantage point surveys and point count surveys).

5.1.3.3 Spring Migration

A total of 77 bird species were recorded during the Spring 2018 VP surveys with five species (Black-tailed Godwit, Common Pochard, Northern Lapwing, Red-breasted Goose and Red-footed Falcon) listed as Near Threatened or Vulnerable on the IUCN Red List and 29 species in the Ukraine Red Book of threatened species.

A total of 88 species were recorded during peak count surveys. This include seven IUCN Red List species and adds two Near Threatened IUCN Red List species (Curlew Sandpiper and Ferruginous Duck) to the five recorded during VP counts. This also includes 26 Ukraine Red Book species and adds five Ukraine Red Book species (Black Stork, Gadwall, Glossy Ibis, Kentish Plover and Squacco Heron) to the list of 29 recorded during vantage point surveys.

No species were recorded migrating over site in internationally or nationally significant numbers and compared to species and overall numbers of birds found within the three IBAs in vicinity of the proposed wind farm, numbers were not of regional significance.

In general, although more species were recorded on site during the 2018 peak count surveys than during previous surveys outlined within the Preliminary ESIA (and summarised above), notable assemblages of birds such as Ruff, gulls and terns on or adjacent to the Project site were of similar numbers as previously recorded and no surprising bird species or numbers observed during the surveys.

5.1.3.4 Autumn Migration

A total of 77 bird species were recorded during the VP surveys with one species (Saker Falcon) listed as Endangered on the IUCN Red List, eight species (Black-tailed Godwit, Common Pochard, Eurasian Curlew, Northern Lapwing, Pallid Harrier, Red-breasted Goose, Red-footed Falcon and Turtle Dove) listed as Near Threatened or Vulnerable on the IUCN Red List and 29 species in the Ukraine Red Book of threatened species.

During the autumn migration VP surveys, a total of 1,464 (1,393 in spring) recordings were made from all the VP locations with 191,323 (30,484 in spring) bird flights observed and nearly 30 million (770,510 in spring) at risk flight seconds recorded. A total of 77 bird species were recorded during the observations across all VP locations.

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Of the total of 77 bird species recorded during the VP surveys, 70 species were recorded flying over the site at at-risk heights. One species (Saker Falcon) listed as Endangered on the IUCN Red List, eight species (Black-tailed Godwit, Common Pochard, Eurasian Curlew, Northern Lapwing, Pallid Harrier, Red-breasted Goose, Red-footed Falcon and Turtle Dove) listed as Near Threatened or Vulnerable on the IUCN Red List and 23 species in the Ukraine Red Book of threatened species were recorded flying at-risk heights.

The CRA results found that eight species (Common Crane, Mediterranean Gull, Mallard, Caspian Gull, Greater White-fronted Goose, Ruff, Northern Lapwing and Eurasian Teal) have predicted collisions of over one bird per annum.

Of the IUCN species, only Northern Lapwing has predicted collisions of any significance based on the relevant avoidance rates.

Of the Ukraine Red Book species, only Common Crane has predicted collisions of any significance based on the relevant avoidance rates. This species was the only one of the Ukraine Red Book species to be recorded in regular high numbers.

Regular movements of flocks of Common Crane were recorded over site during the surveys. The majority of birds passed through the VP3 viewshed between early October and early November with a total of 67,092 bird flights and nearly 17 million total at-risk flight seconds recorded. High numbers of birds and movements were also recorded from the adjacent VP4 viewshed, but observations were much lower over VP2, VP5 and VP6 and only small numbers recorded over VP1.

The largest flocks of Common Crane were recorded over VP3 and included five flocks of between 1,500 and 2,160 birds during mid to late October. A flock of 1,500 were recorded over VP2 on 17th October and three flocks of between 1,170 and 1,494 birds over VP4 in mid-October. Occasional flocks of up to 730 birds were recorded from VPs 2, 5 and 6. Only small flocks (peak of 174) were recorded from VP1.

A total of 189 bird species were recorded during the autumn peak count surveys. 121 of these are considered to be target species and included;

• One IUCN Red List Endangered species (Saker Falcon). • Nine IUCN Red List Status Near Threatened or Vulnerable species (Black-tailed Godwit, Common Pochard, Curlew Sandpiper, Ferruginous Duck, Great Snipe, Meadow Pipit, Northern Lapwing, Red-footed Falcon and Turtle Dove).

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• 29 Ukraine Red Book species (Avocet, Black Kite, Black-headed Bunting, Black- winged Stilt, Caspian Tern, Collared Pratincole, Common Crane, Demoiselle Crane, Eurasian Curlew, Ferruginous Duck, Gadwall, Glossy Ibis, Great Snipe, Hen Harrier, Kentish Plover, Lesser Short-toed Lark, Long-legged Buzzard, Montagu’s Harrier, Oystercatcher, Pallid Harrier, Red Crested Pochard, Ringed Plover, Roller, Ruddy Shelduck, Saker Falcon, Short-toed Eagle, Slender-billed Gull, Stock Dove and White-tailed Eagle).

With regards to breeding birds, a total of 136 species were considered as confirmed (46), probably (36) or possibly (54) breeding on or in the vicinity of site.

Species include six IUCN Red List species (Common Pochard, Ferruginous Duck, Meadow Pipit, Northern Lapwing, Red-footed Falcon and Turtle Dove) and 26 Ukraine Red Book species (Black-headed Bunting, Black-winged Stilt, Caspian Tern, Collared Pratincole, Gadwall, Glossy Ibis, Great Black-headed Gull, Kentish Plover, Lesser Short-toed Lark, Long-legged Buzzard, Montagu's Harrier, Oystercatcher, Red-crested Pochard, Roller, Ruddy Shelduck, Slender-billed Gull and Stock Dove).

No species were recorded migrating over site in internationally or nationally significant numbers, although the regular movements of flocks of Common Crane, Mediterranean Gull, Mallard, Caspian Gull, Ruff, Greater White-fronted Goose, Northern Lapwing and Eurasian Teal over site have resulted in predicted collisions of over one bird per annum. Compared to species and overall numbers of birds found within the three IBAs in vicinity of the proposed wind farm, numbers were not of regional significance.

5.1.4 Hydrology and Hydrogeology

The Project site is located in close proximity to the Gulf of Central Syvash water body. No major water courses / rivers are identified within the site boundary. Within the Project site, surface water is characterised by artificial ponds, drainage channels, streams and marsh / wetland areas with excess moisture. Irrigation infrastructure is present in the form of large drains and associated irrigation equipment, of note, a large channel runs to the south and west of the eastern portion of the site outwith the land plot boundaries.

Due to the high mineralization of surface waters and the periodic drying of watercourses, flora and vegetation are fairly poor. Localised wetland areas are present on the low lying coastal areas of the site.

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There is a high-water consumption in the region from irrigation systems for agricultural operations. There is one ground water well in place associated with the existing wind turbine generators (WTG) on site and is located adjacent to the current operations building. Two further wells are located within the site boundary utilised for irrigation purposes.

Average precipitation is in the region of 400 mm. Most of the precipitation occurs in summer as rainfall. During winter in the coastal area snow fall typically amounts to approximately 15 days.

The Project is located in the Fore Black Sea artesian basin hydrogeological area.2 Hydrogeological conditions in the region are complex because of diverse and discontinuous aquifers and low-permeable rocks, facial variability of the host rock lithological composition, diversity of groundwater quality. The region belongs to the zone of insufficient moisture and groundwater supply.

Shortage of fresh groundwater is a key issue in the Kherson region due to current irrigation practices, aquifer overexploitation and a complex of natural conditions. The main source of drinking water in the Region is the upper Miocene (the main Neogene) water-bearing aquifer complex, widespread in Kherson region.

The Project site is located predominately within an area of low flood risk, with some areas of higher risk of flooding identified associated with surface water bodies feeding into the Syvash Bay.

5.1.5 Geology and Soils

The Project site is predominately of flat terrain, absolute heights vary between 6 and 21 m above sea level. In the south and especially in the south-east, the flatness of the surface is disturbed by the pools (their depth is of 6-8 m (sometimes up to 15 m)) and gullies (the depth of their inlets reaches 10-15 m).

Geomorphologically, according to the Geological Map of Ukraine3, the Project area is located within the Akshahylsky Regional State (clays, alerites, sands and conglomerates. Akania Melitopol terrace.

2 Mineral Resources of Ukraine Groundwaters http://eng.minerals-ua.info/golovna/vodi-pidzemni/

3 Mineral Resources Ukraine (2007).

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According to the WHO Seismic Hazard Distribution Map of Ukraine4 the Project site is identified being in an area with low seismic hazard (0.2 – 0.8 PGA, m/s2). An area of medium seismic hazard lies to the south of the Project (0.8 – 2.4 PGA, m/s2). No significant earthquakes are identified by WHO in the Project area.

The soils within the Project area are characterised by their salinity typically due to previously higher ground water levels and bioclimatic factors. Some signs of erosion were identified during the site visit however this was not identified to be significant or widespread.

5.1.6 Cultural Heritage

The Department of Archaeology of and North-West Black Sea Region of the Institute of Archaeology of the National Academy of Sciences of Ukraine carried out a detailed desk-based assessment of site survey of the Project site in April and May 2018. The findings are summarised below:

The Project site has been subject to anthropogenic impact. The northern area is in many places spotted with various field emplacements due to the military operations directed to capture of Crimean Peninsula in 1920, 1941 and 1944. In 1987–1990, damage was inflicted to archaeological sites located along the edge of the Syvash lake due to the construction of Prysyvashshia portion of the drainage channel for the Kakhovka irrigation system.

The most numerous and the most frequently found cultural heritage sites of this area are burial mounds. In May of 2006, during the construction of foundations for the existing WTGs on site three burial places were discovered, which were determined to be the Hryhorivka burial grounds and interpreted as the remains of a Nogai cemetery dating back to the 16th –17th centuries.

Almost all known burial mounds are registered as those protected by the state. Those of particular note within the vicinity of the Project include three burial mounds located in close proximity to WTG 28, approximately 50 m at the closest point (prior to micrositing).

4 WHO (2010).

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In terms of settlements, a two-layered settlement Novovolodymyrivka ІІ (the Upper Paleolithic Age, ca. 16.5 to 16.0 thousand years ago, and the Early Bronze Age, from late ІV to ІІІ millenia B.C.) is located approximately 1.5 km south-west from Novovolodymyrivka village within the region of WTG 34 to 49. In close vicinity three more archaeological finds of Upper Paleolithic and Mesolithic ages have been discovered: Novovolodymyrivka VІІ, Novovolodymyrivka Х and Novovolodymyrivska Balka.

At least three of them (specifically the two-layered settlement site Novovolodymyrivka ІІ, as well as settlements Novovolodymyrivka Х and Tabirna Balka) are located beyond the construction site – to the north and west of WTG 49. Other sites (Novovolodymyrske settlement, Novovolodymyrivka V, VІІ and VІІІ settlement sites) may fall within proximity of WTG 44, 48 and 49, however it was not possible to identify the settlement areas during the site visit. It is also noted that during 1987–1990 the whole area fell directly into the zone of construction of the drainage channel and there is therefore the potential archaeological features were destroyed or impacted on during construction of the drainage channel.

Novovolodymyrivka І settlement, where several stemmed flints and a fragment of a smoking pipe have been found, is thought to be located between WTG 53 and WTG 54, however the location could not be determined, again due to the presence of the drainage channel and inaccurate referencing.

The Meso-Neolithic settlement of Ivanivka Prysyvaska ІІ under state protection, is located approximately 1.3–1.4 km to the south of WTG 67.

Strohanivka І and 4 to 9 settlements discovered by M.P.Olenkovskyi in 1983 have the potential to fall within the vicinity of construction sites of certain WTGs but only if they were spared by the construction of the drainage channel. Their existence could not be confirmed during site visit. Moreover, their georeferencing is relatively approximate. Again, the location of Strohanivka 1 to 3 has not been determined, it is thought that they were destroyed during the construction of the drainage channel.

Only Novovolodymyrivka ІІ and VІІ, as well as Ivanivka Prysyvaska ІІ settlement site and the Bronze Age settlement Novovolodymyrivka have state protection.

A number of cultural heritage features with local importance were also identified through consultation with local communities. These included:

• Pershokostyantynivka Community o World War Two commemorative sign for the Perekop charge.

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o Cemetery and graves of Soviet Army soldiers. The area includes a number of monuments for soldiers. • Hrygorivka Community o The cemetery, churches (both Orthodox and Catholic) and pray house within the village territory o Mass grave for Red Army soldiers. o Grave of unknown World War Two pilot. o Grave of World War Two hero Novikv. o Monument for village soldiers. o War headquarters location. • Pavlivka / Novovolodymyrivka Community o Cemetery and church o Mass grave for Red Army and Soviet Army soldiers. o Memorial to Victims of the Civil War. o Grave of World War Two Major. o Monument for village soldiers. • Stroganivka Community o The cemetery and church located within the village territory o Mass grave for Red Army and Soviet Army soldiers. o Monument for village soldiers. o Monument for Syvash crossing. o Monument for Syvash charge. o War headquarters location.

5.1.7 Noise

Background Noise (BGN) monitoring was undertaken at a total of four locations representative of settlements in close proximity to the Project. BGN was measured for two weeks between 29 March 2018 and 12 April 2018 at Pweahokoatyantynivka (Location A), Hryhorvika (Location B), Novovolodymyrivka (Location C) and Strohanivka (Location D). Measurements were made in accordance with best practice set out in ETSU-R-97.

The measured LA90 noise levels at 10-minute intervals have been correlated with the wind speed measurements at 10 minute intervals standardised to a height of 10m. IFC EHS guidelines, on which the Project WTGs operational noise assessment is based, use one hour LAeq (dBA). On review of the data obtained, the background LAeq was found to vary dramatically. Following the guidance of ETSU-R-97, the LA90,10min was used as the background noise descriptor.

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Table 5-1: Background Noise Levels, LA90 + 2 dB, (Approximate LAeq)

Receptor Location A Location B Location C Location D Wind Quiet Night- Quiet Night- Quiet Night- Quiet Night- Speed Day time Day time Day time Day time (m/s) 4 33.8 28.5 30.3 24.9 35.0 32.9 33.8 28.5

5 36.0 30.6 31.8 26.4 36.7 34.0 36.0 30.6

6 39.0 33.0 33.6 28.7 38.7 35.8 39.0 33.0

7 42.6 35.5 35.9 31.9 41.0 38.2 42.6 35.5

8 46.9 35.5 38.5 31.9 43.7 38.2 46.9 35.5

9 46.9 35.5 38.5 31.9 43.7 38.2 46.9 35.5

10 46.9 35.5 38.5 31.9 43.7 38.2 46.9 35.5

11 46.9 35.5 38.5 31.9 43.7 38.2 46.9 35.5

12 46.9 35.5 38.5 31.9 43.7 38.2 46.9 35.5

5.1.8 Transportation

The finalised transport route for WTG components to move to the Project site from Olvia Port is as follows:

• Arrival of materials at Olvia Port. • Continue onto the T1501 bypass for 15 km. • Turn right onto the E58 / M14 for around 60 km. • Continue straight onto the Kherson bypass E97/M17 for 22 km. • Turn onto the T2206 and follow for around 70 km. • Turn right onto the T2202 and continue for around 55 km. • Minor roads to the Project site.

A transportation study dated 03 May 2018 undertaken by Holleman Ukraine SLL has been carried out based on the Nordex WTG. This identifies key constraints to use of the proposed route for abnormal load vehicles. Areas where large modifications are required include:

• Area close to the port requires a road curve to be enlarged (Portside road intersection with Korabelov Avenue). • T2206 road – a tree, road sign and 6m of bridge fence requires removal. • T2202 Chaplinka bypass – three signs need to be removed and left curve modified.

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• The access road to the Project site needs to be developed with the junction and access road in accordance with the Nordex transport specifications.

The transportation study notes that 10 km of road sections are in very bad condition and will require repair prior to use. Permission will be required to repair governmental roads which belong to local branches of the National Automotive Road Agency, Ukravtodor. It is also noted that a further study will be required at least eight weeks prior to the start of deliveries to check the condition of the proposed route.

5.1.9 Socio-Economic Conditions

5.1.9.1 Land Administration

Land leased for the Project is state land leased from the Chaplynka District Data Administration. The rent is paid each month pro-rata to the accounts of Pershokostiantynivka village council, Hryhorivka village council, Pavlivka village council, and Stroganivka village council. The four village councils administer the use of land, some of which is to be used by the Project, for the grazing of animals and other purposes. Further detail in relation to leases is provided within the Preliminary ESIA, Chapter 14, particularly Table 14-8.

5.1.9.2 Village conditions, needs and NGOs

This section provides a summary of general village conditions, village needs and details of locally active NGOs.

Pershokostyantynivka

Consultation indicated that there has been no significant change to conditions within the village over the last five years. The population was stated to be 1,200 based upon the 2001 census. Village needs include:

• Improved reliability of electricity; • More jobs for young people; • Improvements to the public road network and street lighting. • Improvements to village infrastructure including the village administration building, local infirmary, library, cultural centre and kindergarten. Typical problems with village infrastructure include a lack of reliable electricity, equipment and heating; • Improvements to quality of pond area which is no longer utilised for fishing and swimming due to poor quality; and

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• Additional village spaces for the benefit of the wider population including recreational areas.

There are two locally active NGOs (Krasa Tavriyi and Shkilniy Dim) who are focused on education for children and the provision of child care facilities. There is also a grazing union made up of cattle owners which was developed to provide collective representation during the process of negotiating prices for farmers (such as for the sale of meat and milk), and to ensure that it is completed in accordance with national legislation.

Hryhorivka

Consultation indicated that there has been a recent improvement to village infrastructure, including access to emergency health care during the last five years. The population has also recently increased, although a decrease in the available grazing grounds has occurred due to the presence of large commercial farms in the area located outwith the Project site boundary. An impact from the presence of the commercial farms is that land has been increasingly allocated to the farms for crops, resulting in an overall loss of grazing land for the community. As stated above, there are no commercial farming activities within the Project area.

The population was stated to be 1,425 people (15% more women than men), with local infrastructure including a school, kindergarten, cultural centre and a small number of shops.

Village needs are similar to Pershokostyantynivka and include the need for a centre for elderly people to be established. A single NGO is active locally (Future of Grygorivka) which focuses on trying to improve local socio-economic conditions.

Pavlivka and Novovolodymyrivka

Consultation indicated that there has been a decrease in grazing grounds available within the last five years due to the presence of large commercial farms becoming established, all of which are outside the Project area. An increase in prices has recently occurred in relation to food, animal feed and gas prices and improvements to village infrastructure have been made, including kindergarten facilities.

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The population was stated to be 1,219 across the two communities, with Novovolodymyrivka featuring an estimated population of 54. There are approximately 15% more women than men, 300 people who are retired (approximately 4%); 90 school age children (0.7%), and 350 were specified as unemployed (29%). Important sources of local employment include a large commercial farm (Interra) and social workers such as teachers and other village workers).

Village needs include assistance with the legal allocation of additional grazing land, with the aim of legalising land not currently utilised or occupied so that this can be used for village grazing; improving access to health and poor condition of education facilities; supporting elderly and other people who have ill-health and improving local road conditions.

An NGO is active locally (Zlagoda) which supports village needs from other large investment companies through focused corporate social responsibility activities. There is also a veterans union and a social activists group; a combined group that provides social welfare support and assistance to cattle owners.

Strohanivka

Consultation indicated that within this village, there has been a recent decrease in population due to local people leaving to seek improved job opportunities elsewhere, a decrease in household income due to higher cost of living (as is the case in the other villages) and an increase in land rental payments within the last five years.

A new shop had opened recently within the village. The estimated population was stated to be 1,071 with more woman then men. This is common across the region as women typically have less opportunities to develop professionally, as they are married earlier in life and are traditionally 'homemakers'; bound to the household, children, taking care of elderly etc.

This region traditionally lived off selling vegetables and fruits to Crimea. Due to Crimea’s recent occupation the market for selling products is now closed and many people had to find alternative livelihoods, typically men who have been forced to seek formal employment elsewhere and live outside the Project area, away from their family household.

Village needs include an area for the disposal of construction waste, improvements to village infrastructure and medical equipment, modernisation of a kindergarten, establishing a retirement home, and improvements to the physical condition of roads.

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An NGO is active locally which deals with directing charity funds to village needs (Vid serdtsya do sedtsya) as well as a veteran’s union and a grazing union. The grazing union is made up of cattle owners, similar to Pershokostyantynivka discussed above.

5.1.9.3 Land Use

This section provides a description of land use conditions within the Project area.

Pershokostyantynivka

Land within this village council administration is currently used for animal grazing (mostly cattle), hay collection and the hunting of rabbits, ducks and geese. The soil is not suitable for large-scale agriculture. A servitude agreement is in place with the communal enterprise for use of the Project area land. Village cattle is represented by about 500 cows, 80% of the population live off sale of milk to two milk factories.

Hryhorivka

Consultation identified that the village residents are typically self-employed in agricultural sector (selling milk, meat, eggs for sale), with some working as seasonal workers on larger farms. Approximately 30% of population are cattle owners.

A servitude agreement is in place with the communal enterprise for use of the Project area land. No estimates were provided for the number of cattle in the village. Assuming that the ratio of cattle between residents is the same across other village administrations engaged with during the land use survey, it can be assumed that Hryhorivka has approximately 585 cattle.

Local disputes have arisen in relation to the identification of land users involved in the collection of hay and these were resolved though individual negotiation. The same level of conflicts has been reported, compared with five years ago. Local people use land within the Project area for the collection of hay and grazing.

Pavlivka and Novovolodymyrivka

Approximately 25% of the population are self-employed within the agricultural sector, generating vegetables, milk, eggs, meat with 300 head of cattle. A servitude agreement is in place with the communal enterprise for use of the Project area. There are seven to eight herds.

Strohanivka

Consultation identified 500 heads of cattle within the village. A servitude agreement is in place with the communal enterprise for use of the Project area land.

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People travel to land administrated by this village from outside the Project area for fishing. People do not travel from outside to graze their animals. Some disputes have occurred in recent years over access to grazing areas and have been settled through negotiations. There is the same frequency of disputes compared to five years ago.

Other than animal grazing, people use land within the Project area for collecting hay, hunting (rabbits, ducks and geese), fishing and collecting mushrooms.

5.1.9.4 Catch Interview Summary

In summary, data from the catch interviews provides a general picture of the type of people who are using the Project land for grazing. Specifically, the following common characteristics can be identified:

• The individuals grazing are both male and female; none of them under the age of 16 years; • The number of cattle varies significantly between herders, ranging from 2 to 45; • The number of ducks ranges from 10 to 150, with one interviewee indicating that they intend to release all of their ducks to the wild for conservation purposes; • All grazers typically use the land regularly between April and October and have to purchase feed for animals during the winter months. Some herders purchase feed during the summer months when the level of grass is low; • None of the animal grazers pay to use the land, or have any type of formal agreement in place with the village council; and • The incidence of land-related conflicts between different groups is relatively infrequent and is resolved through discussions with the people involved.

5.1.9.5 Vulnerable People

During the land use survey questions were asked about the type of vulnerable people that are present within the Project area, and the sources of their vulnerability. The following groups were identified:

• Families with a number of children as they have many dependants, and household income has to provide for all members of the household; • The disabled who often require additional support for daily living, and access to high-quality health care facilities; • The elderly and those in ill-health who often require additional support for daily living, and access to high-quality health care facilities; and

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• Veterans who have returned from a location of recent conflict. Some veterans find returning to civilian life difficult after experiencing conditions of conflict, experience stress, depression and difficulties in maintaining domestic relationships.

All of the above groups have equal access to land within the Project area, although the elderly and long-term sick predominately survive off social welfare payments. There is no evidence to suggest that vulnerable people are grazing animals within the Project area. Instead, the people involved in grazing activities are typically middle-aged and have been undertaking grazing activities for a significant portion of their lives.

5.1.9.6 Village Perceptions

The land use survey also investigated perceptions towards the Project, with a specific focus as to whether they believed that women and men may disproportionally be impacted. Specifically, the following common perceptions can be identified:

• Men and women are expected to be impacted equally by the Project; there is no differentiation by gender. One village representative stated that women may benefit more due to the creation of indirect job opportunities, for example cooking, laundry and cleaning services at the construction worker camp; • The Project will benefit the region from improved social infrastructure and employment opportunities; • The Project will contribute to the development of the country by providing renewable energy, generating electricity and taxation; and • The Project will demonstrate the application of the latest renewable wind turbine technology resulting in a sense of pride for the host region in the country.

5.2 Aviation

Consultation with the Ministry of Infrastructure of Ukraine, Ukrainian State Air Traffic Services Enterprise was carried out. An assessment was carried out based on the criteria of the ICAO Doc 8168 OPS/611 "Procedures for Air Navigation Services. Aircraft Operations" and departmental building codes "VSN 7-86 MGA."

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The approval letter dated 29 May 2018 confirmed that the Project will not affect aircraft flights in accordance with the established rules (standard departure, arrival and approach routes) to aerodromes (helicopter aerodromes), air traffic services on which is operated by Ukrainian State Air Traffic Services Enterprise, and the operation of communication, navigation and surveillance facilities that belong to Ukrainian State Air Traffic Services Enterprise. Further approval of the location and height of WTGs was granted on 10 October 2018 for updates to the layout of the Project.

Approval was also obtained from the Ministry of Defence of Ukraine, Armed Forces Air Force Command headquarters on 04 December 2018 for construction of the Project in accordance with Clause 57 of the Provision and Use of the Airspace of Ukraine adopted by the Cabinet of Ministers of Ukraine No. 954 dated 06 December 2018. The approval requires that the Armed Forces Air Force Command headquarters are informed of commencement and completion of construction of the wind farm.

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6 Overview of Construction Works

The wind farm is expected to be constructed from Q1 2019 to Q2 2020. The following sub-sections describe transportation of workers, materials, and equipment to the site, the temporary works to be used during construction, and construction of the various project components.

Construction works will consist of the following:

• Temporary Works. • Control Centre Compound. • Access Road. • Grid Connection (on site). • On-Site Roads and Underground Cabling. • 64 Wind Turbines with capacity up to 3.9 MW.

Temporary works to be used during construction will consist of a temporary compound for the storage of plant and materials and a staging area located near the future control centre and sub-station, and possibly other smaller temporary compounds in other areas of the site. The main compound will include a parking area, a generator with fuel storage, and temporary buildings to provide support facilities for managers and workers, secure storage, site offices, and welfare and first aid facilities.

It is anticipated that up to three permanent meteorological masts will be installed on-site during construction.

There is currently no paved road from the main public road to the Project site. On-site roads are required to connect the WTGs to each other and to the substation (control) building and compound. All access roads will be approximately 4 - 6 m wide. Where roads have to cross existing erosion features or ephemeral streams, drainage features will be incorporated into the design to control overland flow and minimize erosion. If major gullies or other erosion features are crossed, culverts will be installed to convey storm water under the road.

Typical road construction specifications include excavating topsoil and subsoil, grading to desired slope and grade using cut-and-fill methods, placement and compaction of gravel where needed, excavation of a drainage ditch along uphill sides where appropriate, and placement of low berms on downhill sides where necessary. Any surplus topsoil will be stockpiled and protected from erosion, for use in future reinstatement.

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7 Management and Mitigation Measures

7.1 General Management Approach

7.1.1 Management Awareness

Objective: To ensure that the Project Management team is fully aware of the site environmental standards and are committed to complying with the standards.

It is the site management’s responsibility to ensure that the actions contained in this ESMP are conducted and maintained. Therefore, the site management’s awareness of the environmental standards set out in the ESMP is critical to the successful working of the Syvash Wind Farm Site and the attitude that they take will be reflected in the overall conditions prevailing at the site.

The Site Manager appointed by SyvashEnergoProm LLC has overall responsibility for the implementation of the ESMP. The E&S Manager will be responsible for the day to day management of the ESMP.

ACTIONS

a) Regular site environmental audits, undertaken by the Environment Team to assess the site’s environmental performance against the ESMP, will be used to educate and motivate site management to achieve the desired environmental standards on site by explaining the importance of conforming to the standards and focussing on any areas that require improvement. The responsibility to ensure the mitigation measures are implemented and the relevant environmental legislation is complied with, is set with the site management.

b) The site management will have had environmental awareness training. This will be conducted by talks from the environment team and include the SyvashEnergoProm LLC environmental policy and environmental issues raised within the ESMP.

7.1.2 Grievance and Incident Procedures

Objective: To ensure that any environmental complaints and incidents that occur on site are reported, investigated and appropriate action taken by following complaint and incident procedures.

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Grievance and incident procedures will be in place, that state how any environmental complaint or incident that may arise from the site’s activities will be managed. Any complaint received will be logged at the site or the company offices. All complaints and incidents will be investigated, and any necessary corrective and/or preventative action will be taken and recorded.

Complaints and incidents are logged and investigated.

ACTIONS

a) Contact telephone numbers including a 24-hour number will be published in leaflets distributed to occupants of neighbouring premises before site operations commence and will also be detailed on the site entrance sign.

b) The complaint and notifiable incidents procedure/s will be followed by the site management and office staff.

c) Any complaints and incidents are reported to the E&S Manager who ensures that they are fully investigated, resolved and closed out.

7.1.3 HSE Performance Reviews

Objective: To ensure that the site is regularly audited against this ESMP to monitor the achievement of the environmental objectives at Syvash Wind farm.

Performance reviews are fundamental to ensuring that the actions for each objective contained within this ESMP are established and maintained on the Syvash Wind Farm.

Reviews are set to take place provisionally every month from the start of the construction works.

ACTIONS

Before a review, the following documents will be consulted in order to check compliance where applicable:

• Any discharge consents and abstraction licences.

• Planning Permission and conditions.

• Records of any previous environmental audits, non-conformance notices, complaints and environmental incidents. a) The measures to control significant aspects outlined in this report and their effective implementation will be checked during regular environmental audits of the site, during the site construction phase.

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7.1.4 Project Environmental Committee

Objective 4: To establish and maintain regular environmental committee meetings to communicate the Syvash Wind Farm’s progress and environmental performance and to discuss and address any issues raised.

ACTIONS

a) A Syvash Wind Farm environmental committee will be established prior to commencing the site construction phase and meetings will be held regularly during the construction phase. Meetings will also be held at a frequency agreed by the team, possibly extending into the first year of the operational phase if considered necessary.

b) The purpose of the committee is to discuss relevant issues that arise out of the development which could have an effect on people living or working in nearby properties or enjoying nearby land.

c) Representatives from the local government, Contractors, Wood and local residents’ representative will join SyvashEnergoProm LLC to form the environmental committee.

d) The aim of the committee is to act as a forum for the exchange of information on progress of the site and for the company to listen to any views of local residents relating to the development and respond accordingly.

e) Environmental audit findings will be presented to the committee.

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7.1.5 Occupational Health and Safety

Occupational and public health and safety concerns associated with operation and construction of the wind farm will be similar to those from construction and operation of any industrial facility in a remote area. The major potential hazards include:

• Movement or operation of passenger and construction vehicles, equipment, and materials could cause injury or death to humans (drivers, passengers, pedestrians) or animals (livestock or wildlife). • Using hand tools or larger equipment could result in accidents that harm or kill workers. • Falling overhead objects could cause injury or death to workers or trespassers. • Falls into or collapse of open excavations could cause injury or death to workers or trespassers. • Falls from heights (buildings, WTGs) could cause injury or death to workers or trespassers. • Blasting could cause injury or death to workers or trespassers. • Contact with electrical lines or transformers could cause injury or death to workers or trespassers. • Noise and vibration could distress or injure workers or distress residents.

SyvashEnergoProm LLC and its contractors will comply with international Occupational Health & Safety regulations and standards (for example, EU Directive 89/3918 and OSHA9 standards) in addition to Ukrainian safety standards regarding construction works, electrical works, structural climbing and other hazards. In general, construction operations will be planned and implemented in accordance with these standards and with IFC safety guidelines.

There will be a workforce manager (HSE Manager) in charge of all activities, and in charge of compliance with health and safety requirements. This individual will report directly to the SyvashEnergoProm LLC project manager and will have independent lines of reporting to SyvashEnergoProm LLC upper management. Prior to beginning work on the site, the workforce manager will develop a safety program to cover construction and then operation of the site. The program will describe in detail the potential hazards and the ways in which they will be prevented or avoided. All construction workers (including contractors) will be required to complete a training program that covers the safety program, and training will cover hazard awareness, job- and site-specific hazards, emergency procedures for fire, illness or injury, and natural disaster.

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Besides training, the safety program will include detailed requirements for inspecting, testing, and calibrating safety equipment, for monitoring the working environment for hazards, and for monitoring worker health. In addition, all incidents and accidents will be recorded if they resulted, or nearly resulted, in damage to equipment or injury or to humans or animals, will be recorded. On an annual basis, SyvashEnergoProm LLC will report to the lenders and shareholders on the status of the overall safety program, including information on training and on incidents.

Workplace inspections will be undertaken on a regular basis to monitor H&S aspects on site.

Health and Safety aspects are covered in more detail in the SyvashEnergoProm LLC Health and Safety Procedures.

7.2 Potential Environmental and Social Impacts and Mitigation

Table 7-1 summarises the potential impacts on the environmental and socio-economic resources as reported in the ESIA together with proposed mitigation measures. All impacts are adverse unless otherwise stated.

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Table 7-1: Summary of Impacts and Mitigation

Environmental Receptor Predicted Impact Mitigation

Impacts on landscape The main impacts on landscape character Limiting damage to any grassland by keeping the construction areas and roads to a character and visual and visual amenity result from the areas for minimum, and maintaining strict requirements for vehicles to remain on the roads at amenity during temporary works, construction compounds, all times. construction access road and on-site roads, areas for Reinstating grassland where construction areas and roads are no longer required. This WTG and control centre foundations. New would reduce the duration of the visual impact. machinery and equipment will be Provision of adequate facilities for the disposal of garbage. introduced into the landscape, including a Training of the workforce in waste management. crane, trucks (usually 20-tonne trucks, but

sometimes larger), excavators, bulldozers, Reduce the amount of waste to the maximum extent possible. and other heavy equipment. In addition, Collect all solid waste and store until transported to an appropriate waste disposal there will be temporary accommodation facility and disposed. and storage areas. Organization of clean-ups for existing garbage. The impacts will be temporary and medium term with the significance being Slight and Implementation of site reinstatement plan. not significant.

Impacts on landscape The main source of impact to the LCT Mitigation options are fairly limited during operation and would be focused on the character and visual during operation is the erection of the 64 full implementation of the community benefits package to ensure that any visual amenity during operation. WTGs. impacts on the local population is offset by an appropriate level of community Other elements of operation of the Project benefit. that will affect the landscape comprise: On-site roads, including WTG access roads, and occasional vehicles that pass along the roads. Additional structures at the Control Centre.

Designated sites, habitat Direct loss of vegetation and habitat The final locations of WTG and associated access routes will mainly avoid habitats and flora (including food sources). that have been identified as being of highest sensitivity. This includes freshwater Indirect impacts associated with wetlands, wet meadows and less disturbed uncultivated areas of meadow and steppe construction include potential pollution of vegetation. Habitat supporting the National Red Data Book Species Lepidium water courses and or other areas of higher syvaschicum, will also be avoided. This will ensure that negative impacts on habitats habitat value as well as disturbance of fauna and flora are kept to a minimum and of low significance. as a result of construction activities, noise, All areas of sensitive habitats and/or where notable species occur that are not being lighting and movement of vehicles and affected by construction activities will be clearly marked on the construction plans people. and will be marked on site to prevent construction activities in these areas. An Unmitigated, the potentially negative ecologist will be present to supervise any works that are required in close proximity to impacts of pollution on habitats and flora of these sensitive habitats. Project are considered to be of low to Pre-construction mitigation works to avoid and/or minimise the loss of sensitive moderate significance. species of flora will be completed. This will include pre-works checks for sensitive plant species that could be present in areas affected by construction works associated with WTGs and access roads during construction and where appropriate the translocation of species and/or recreation of habitats completed. Pre-works surveys will be targeted to specific areas where sensitive species are known to be present based on existing survey data and mapping. Detailed pre-construction survey protocols are provided in Appendix C. Certain plants could be difficult to detect during the winter months so where data and mapping suggests sensitive plants species could be present, they will be presumed present and translocation and/or recreation of wider areas completed where necessary. The recreation and enhancement of uncultivated steppe and meadow habitats, including the retention and increase of field margins, will also be completed as part of the proposals.

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Standard pollution control measures will be enforced during the construction phase of the Project to ensure there are no impacts on habitats. All fuel and lubricants will be stored in double bunded storage containers and dedicated re-fuelling areas will be maintained. Spill kits will be available at all storage and re-fuelling sites and all spillages will be cleaned up immediately. Any incidents will be reported and investigated, and additional control measures implemented as necessary. All vehicles being used on the site will be well maintained and subject to regular service and maintenance. Alien and/or invasive plant species are not currently frequent in habitats within or adjacent to the Project site. Vehicles and any materials being brought onto site will therefore need to checked for the presence of alien or invasive species prior to arriving on site to ensure none are introduced into habitats within and adjacent to the Project site. If alien or invasive species are found to be present within the Project area during the construction and operational phases of the development then these will be eradicated using appropriate methods. There will be no collecting of plant species within the Project site and this will be enforced by the Project team. The remaining shelter belt trees will also be protected from felling and or collection of fire wood by construction workers. Additionally, it will not be permissible to set fire to trees and/or steppe and meadow habitats during the construction and operation phases of the Project. The site will maintain excellent housekeeping practices to ensure that all refuse and other waste materials are disposed of correctly as well as ensuring high levels of recycling is completed.

Fauna Disturbance of fauna from presence of The final locations of WTG and associated access routes will mainly avoid habitats people, machinery, traffic, and noise. that have been identified as being of highest sensitivity for fauna species. This Indirect impacts associated with pollution includes freshwater wetlands, wet meadows and less disturbed uncultivated areas of incidents could affect habitats and breeding meadow and steppe vegetation. sites. This is of low to moderate Pre-construction mitigation works to avoid and/or minimise the loss, death or injury significance. to sensitive species of fauna will be completed. This will include pre-works checks by High sensitivity bat species could be a Project ecologist for notable fauna species that could be present in areas affected indirectly affected through noise by construction works associated with WTGs and access roads during construction, disturbance and/or lighting impacts watching brief of excavation works in areas deemed suitable for sensitive species of considered to be moderate to high fauna and where appropriate the translocation of species and/or recreation of significance. habitats completed. Detailed pre-construction survey protocols are provided in Appendix C. Construction is timed to start in early 2019 during the winter period and as such areas that could support hibernating herpetofauna, including Steppe Viper, will need to be avoided until a period of mild weather likely to be early Spring 2019, or if this is not possible completion of pre-construction walk over checks should be carried out. A pre-construction walk-over survey will be completed by the Project’s ecologist in all winter 2018 – 2019 construction zones and habitats or habitat features identified by the ecologist that could be suitable for hibernating herpetofauna will be clearly marked and will be protected from construction activities until animals are likely to be active. The tracks around site and agricultural fields affected by the proposals are unlikely to support hibernating herpetofauna but habitats where they could occur includes rocky outcrops, stone piles and former small animal burrows or holes. Habitats identified as being suitable hibernation habitats will be removed under supervision of the Project’s ecologist when herpetofauna are likely to be active.. Habitat that has been identified as being potentially suitable for Crimean Stone Grasshopper will, as far as is reasonably practicable, be avoided and will not be affected during construction. Where avoidance of potential impacts is not possible, habitat will not be removed during the winter so as to allow any instars that are hibernating to develop in to adults, thus minimising any impacts on this species. Habitat creation as part of wider mitigation and enhancement measures will increase the available habitat for this species, if present.

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Speed limits will be enforced within the construction sites to reduce the likelihood of collision with on-site vehicles. If animal crossings are identified by the on-site ecologist these will be clearly signed during construction and if necessary additional mitigation will be undertaken to reduce conflict with on-site traffic. This will include culverted animal crossings, particularly where access roads cross through or between areas of freshwater wetlands and/or less disturbed areas of steppe and meadow where reptiles, amphibians and mammals are most common, and moving animals off on-site roads. Standard pollution control measures will be enforced during the construction phase of the Project to ensure no impacts on habitats and faunal receptors. All fuel and lubricants will be stored in double bunded storage containers and dedicated re- fuelling areas will be maintained. Spill kits will be available at all storage and re- fuelling sites and all spillages will be cleaned up immediately. Any incidents will be reported and investigated, and additional control measures implemented as necessary. All vehicles being used on the site will be well maintained and subject to regular service and maintenance. There will be no hunting and or collecting of fauna within the Project site and this will be enforced by the Project team. The remaining shelter belt trees will also be protected from felling and or collection of fire wood by construction workers. Additionally, it will not be permissible to set fire to trees and/or steppe and meadow habitats during the construction and operation phases of the Project. The site will maintain excellent housekeeping practices to ensure that all refuse and other waste materials are disposed of correctly as well as ensuring high levels of recycling is completed. Proposed steppe and meadow habitat recreation, protection and enhancement should improve habitat suitability for invertebrates and in turn increase abundance and diversity of animals, such as reptiles, amphibians, small mammals and passerine birds, that feed on them. The retention and increase of margins around agricultural fields and alongside access tracks will also increase connectivity across the site and provide vegetated corridors providing cover, feeding and breeding opportunities for a range of fauna away from the WTGs.

Fauna – operational Possible killing and injuring of animals by In line with recommendations set out in Eurobats Publication Series no. 6 WTGs site traffic resulting in negative impacts of should be located away from sensitive areas shown to be used more frequently by low to moderate significance. bats. The majority of WTGs are located at least 200m from areas of freshwater and Killing of bats due to WTG operation, village outskirts, where most bat activity has been recorded and WTG micrositing has leading to moderate to high significant further increased distances from freshwater habitats. Some WTGs will be within 200m impacts. of freshwater, at the western and eastern ends of the Project site, but extensive suitable habitat will be unaffected by WTGs and main foraging and commuting routes across between village roost sites and freshwater will be retained and unsevered. Mortality of bats with the operational WTGs will be reduced as a result of locating the majority of WTGs away from habitat features that could support foraging and commuting and retaining extensive suitable habitat that will be unaffected by WTGs. Additional bat surveys will be completed, as further outlined below, in order to develop continued mitigation packages to further reduce impacts on receptors of high sensitivity. A carcass searching programme will also be completed, which will inform any additional mitigation (as detailed further below). Enforcement of speed limits on site. Monitoring of road conditions and any damages repaired. Maintenance of any animal crossings. Carcass searching should be undertaken at each operational turbine during the active season (March-October) for the entire first year of operation. The frequency of checks will be determined through scavenger removal trails however it is considered that checks during the active season are likely to be completed once every 7 to 14 days. Depending on the results of the carcass searching, monitoring effort and appropriate mitigation measures will be reviewed and adjusted accordingly.

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Additional survey should include the continuation of bat activity surveys (transects and static detectors) throughout construction. Survey visits should be completed monthly during the main bat active season (March to October) and patterns in activity analysed and mapped to allow amendments to the overall mitigation strategy to be made. A detailed survey methodology is provided in Appendix D. A survey report will be prepared within one month of survey completion providing analysis of results and the report will include any recommendations for operational bat activity surveys and or any additional mitigation. Based on current survey results and assessment, no curtailment is currently recommended however this requirement will be reviewed following construction surveys in the first instance and again on completion of the first year of carcass searching. Depending on the outcomes of additional surveys and/or carcass searching it may be necessary to introduce some level of turbine curtailment. If deemed required this could include increased turbine cut in speeds (at least 1.5m/s above the manufacturers specified cut in), timed shutdown of turbines to avoid operation during periods of high activity (nightly or seasonally i.e. early Autumn to avoid migrating bats). Maintain the ban on hunting and collecting of firewood. Prohibit fires to wooded areas or meadow habitats. Implement enhancements where possible including increasing the quality and amount of wet meadow habitat and improving woodland areas.

Birds - Impacts during Construction impacts are likely to include Design and Planning construction activities habitat loss and possible nest destruction Avoidance of areas of highest quality habitats and use of buffer zones where possible for passerine and ground nesting bird between wet grasslands and marshes. species as well as disturbance impacts in Continued survey effort to confirm and adapt all bird-related mitigation measures, the Project and adjacent areas. such as the extent and duration of any shutdown of WTGs which may be required. Site Preparation Habitats that will be lost during construction should be removed outside of the bird breeding season (March to August inclusive). If this is not possible, a check must be done by the on-site ecologist to ensure breeding birds not directly affected. Detailed pre-construction survey protocols are provided in Appendix C. Site Preparation Pollution prevention measures to be implemented. A designated storage area is established with an impervious base and impermeable bund walls. Capacity must be sufficient to contain the full volume within a bund and secured area. All fuel, oil and chemical storage is stored in a designated secure area. Establish a designated storage area with an impervious base and impermeable bund walls and protected from precipitation. Capacity must be sufficient to contain the full volume within a bund and secured area. Hoses and valves are checked regularly for signs of wear and ensure that they are turned off and securely locked when not in use. Diesel pumps and similar items are placed on drip trays to collect minor spillages. Trays should be checked regularly, and accumulated oil removed. Do not leave vehicle unattended during refuelling, never leave open a delivery valve. Sanitary waste to be collected in containers below portable toilets and transported for disposal. The waste will be disposed of by a licensed contractor.

Birds - Impacts during Disturbance of birds from WTG noise, Further Vantage Point surveys concentrating on the main Common Crane autumn operational activities shadow flicker, people, and traffic. migration period in 2019 and areas where most Common Crane were recorded in Loss of birds from collision with WTGs. 2018 (VPs 2, 3, 4 and 5) to confirm the presence/absence of any flocks of Common Crane over the wind farm site.

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These surveys will inform the need and extent of any required temporary or observer and / or technology-led shut down. Shut-down initiation parameters will be determined based on the results of the monitoring surveys and this ESMP will then be updated / amended accordingly. A minimum of three years operational mitigation and monitoring will be completed concentrating on the main Common Crane autumn migration period in 2019 and areas where Common Crane were mostly recorded in 2018 and likely to be recorded (VPs 2, 3, 4 & 5). After three years of monitoring, results will be assessed and discussed with the potential for continued observer presence during autumn to cover any variations in migration / movements in the area.

Birds - Enhancement and A number of enhancement measures Installation of small raptor (falcon) nest boxes on the pylons that are at least 1 km reinstatement measures identified which should be incorporated in away from operational WTGs. These artificial nesting opportunities have been shown to the Project in order to have a positive to be very successful in the UK and Europe. impact on breeding / resident birds: Development and enhancement of wet meadow habitat and shelter belts / small copses. Installation of bird boxes within the shelter belts that will provide a range of nesting opportunities for passerine birds. Following decommissioning, reinstatement will be important to re-establishing more natural meadow habitats, including wet meadows, across the site previously occupied by WTGs, site roads and other structures. A habitat management plan will be established which details all habitat reinstatement measures to be completed at the decommissioning phase of the Project.

Surface water drainage During construction earthworks, road The route of the access tracks should be optimized to reduce the need for cut-and-fill construction and use of heavy vehicles material and run-off and erosion control features should be incorporated in designs. could alter surface drainage patterns. Buffer distance of 50m is applied to any hydrological features shown on background maps or discovered by survey. Prior to final positioning of the WTG locations, an area-wide sheeting flow study should be carried out using detailed topographical data, and soils data from the ground investigation which will provide velocities and depths of flow during periods of intense rainfall. Pollution prevention measures (applicable to all aspects).

Increased surface run-off The removal of vegetation and compaction Ensure excavated areas are re-vegetated as soon as practical following initial of will reduce infiltration and surface run-off vegetation stripping. will increase. The risk is greatest during severe precipitation events.

Soil erosion and sediment The increased volume of water flowing Ensure that drainage channels are vegetated as soon as practical following initial loading down drainage channels and creeks is likely construction to stabilize areas of bare earth. to cause additional soil erosion and increase the size of the channels. Surface run-off will also contain larger amounts of suspended sediments during construction than would otherwise be the case. Impacts to surface waters in operation confined to increased runoff and erosion, primarily in existing or new erosion channels that receive run-off from roads.

Water pollution from Water discharge and pollution. Risk of soil A designated storage area is established with an impervious base and impermeable leaks and spills and water pollution from leaks and spills bund walls. Capacity must be sufficient to contain the full volume within a bund and through storage of oil secured area. All fuel, oil and chemical storage is stored in a designated secure area. Establish a designated storage area with an impervious base and impermeable bund walls and protected from precipitation. Capacity must be sufficient to contain the full volume within a bund and secured area.

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Hoses and valves are checked regularly for signs of wear and ensure that they are turned off and securely locked when not in use. Diesel pumps and similar items are placed on drip trays to collect minor spillages. Trays should be checked regularly, and accumulated oil removed. Do not leave vehicle unattended during refueling, never leave open a delivery valve.

Water pollution from Pollution of ground/surface water due to Sanitary waste to be collected in containers below portable toilets and transported for sewage effluent the inappropriate discharge of sewage disposal. The waste will be disposed of by a licensed contractor. effluent.

Groundwater Further survey work required to better A construction water availability / resource use assessment and management plan will inform the identification of potential be developed to confirm construction water use. impacts. Assessment of the ability and capacity of existing local supply to provide construction requirements.

Soil erosion particularly as Vehicle traffic along dirt tracks used during Clearly demarcate storage and staging areas and store all materials, equipment and a result of loss of construction of on- and off-site roads, vehicles in demarcated area to reduce soil damage. Furthermore, vehicles should be vegetation power lines, control centre and WTGs will confined to demarcated roadways. cause soil compaction. Establish native grasses in erosion control channels and in other areas immediately Off-road vehicle traffic will damage after final disturbance. vegetation and cause soil compaction. Salvage and store topsoil and subsoil before areas are excavated, with topsoil Any vegetation and some soil will be stripped and stockpiled separately. removed for the construction camp, the Segregate excavated soils into stockpiles dependent on material type and provide control centre, WTG foundations, and both erosion control while stockpiled. on- and off-site roads. On completion of earthworks, backfill material in the same stratigraphic sequence. The use of heavy equipment, including When wide roads are narrowed after WTG construction, scarify compacted areas and cranes for WTG erection, will cause soil establish native grasses. compaction if used off roads. Once construction and road-building are complete, scarify all areas compacted by Blasting will result in the removal of any off-road vehicle / equipment movements and establish native grasses. vegetation and topsoil and near-surface Store all materials within designated areas of temporary storage facilities and provide rock for WTG foundations, possibly for the supplies to clean-up of minor spills. control centre and for some on-site and Confine all vehicles and equipment to the roadway and, to extent possible, minimize access roads. activities during wet conditions. When activities must occur in wet conditions, control storm water by using fabric, straw bales and other measures to impede storm water flow and prevent erosion. When damage to wet soil occurs, repair once dry conditions return. For storage of oil, establish a designated storage area, with impervious base and impermeable bund walls. Capacity must be sufficient to contain full volume within a bund and secured area. Store all fuel, oil and chemical storage in the designated storage area. Check hoses and valves regularly for signs of wear and ensure they are turned off and securely locked when not in use. Place diesel pumps and similar items on drip trays to collect minor spillages. Check trays regularly and remove any accumulated oil. Reduce the amount of waste to the maximum extent possible. Collect all solid waste and store until transported to the designated disposal site.

Soil erosion as a result of Movement of staff and materials to and Confine all vehicles to roadways. continued vehicle traffic from the site along the access roads may Monitor road condition regularly; then repair damaged and rutted roads rather than during operational phase. result in degradation of tracks and erosion. bypassing damaged sections. Movements between the control centre and Monitor erosion controls and repair as needed. WTGs for operation and maintenance Where possible, maintain grass cover on berms and ditches. particularly if workers drive off designated Prohibit use of vehicles and equipment off prepared roads. tracks. Workers are expected to visit each Re-stabilize existing eroded tracks and restore grass cover as needed. WTG location least once per week for Do not collect firewood from the site. routine maintenance. Reduce wastes to the extent possible and maximise re-use and recycling of materials. Collect and store all waste and garbage before disposal at the designated site.

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Clean up and store oily and chemical waste and contaminated material before transport to the designated disposal site to reduce risk of soil and groundwater contamination. Establish a designated storage area with an impervious base and impermeable bund walls and protected from precipitation. Capacity must be sufficient to contain full volume within a bund and secured area. Store all fuel, oil and chemical storage in the designated secure area. Do not leave vehicles unattended during refuelling, never leave open a delivery valve. Check hoses and valves regularly for signs of wear and ensure that they are turned off and securely locked when not in use. Place diesel pumps and similar on drip trays to collect minor spillages. Check trays regularly and remove any accumulated oil.

Archaeology / Cultural Existing archaeological features located A cultural heritage management plan will be developed in accordance with the heritage within Project site. requirements of EBRD PR 8 and IFC PS8. The management plan will outline actions and

Due to presence of archaeological features measures necessary for the effective management of risks and impacts to cultural within the area there remains the potential heritage during the construction phase of the Project. to uncover previously buried archaeology The management plan will outline a program of consultation with Project affected (chance finds) during construction works. communities to ascertain requirements for accessing features of importance and

Community access to cultural heritage outline measures that will ensure access will be available to communities at all times features has the potential to be disrupted required taking into account community health, safety, and security considerations. during construction. This will also be managed through the Stakeholder Engagement Plan and Community Health and Safety Plan.

Existing features will be marked / fenced to ensure no direct impact by construction activities. Buffer distances required by Ukrainian Law will be maintained.

In accordance with the requirements of Ukrainian Law, EBRD PR 8 and IFC PS8, SyvashEnergoProm LLC will develop provisions for managing chance finds through a chance find procedure which will be applied in the event that cultural heritage is subsequently discovered.

An archaeological chance finds procedure is defined as a formal programme of observation and investigation conducted during any operation carried out for non- archaeological reasons (i.e. construction of a wind farm) within a specified area or site where there is the possibility that archaeological deposits may be disturbed or destroyed (the working area). The procedure will result in the preparation of a report and ordered archive.

An archaeological chance finds procedure will in all cases be intended:

• To allow, within the resources available, the preservation by record of archaeological deposits. The presence and nature of which could not be established (or established with sufficient accuracy) in advance of development or other potentially disruptive works. • To provide an opportunity, if needed, for the watching archaeologist to signal to all interested parties, before the destruction of the material in question, that an archaeological find has been made for which the resources allocated to the chance find procedure itself are not sufficient to support a treatment to a satisfactory and proper standard.

The archaeological chance finds procedure will be intended to establish and make available information about the archaeological resource existing on the site. The chance find procedure will be developed in consultation with the Archaeological Institute. Qualified archaeologists will carry out the watching brief.

In accordance with the Law of Ukraine On the Protection of Cultural Heritage if archaeological or historical objects are discovered during excavation works, such excavation shall be terminated with immediate notification to the District Inspection for the Historical and Cultural Monuments Protection.

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During construction, toolbox talks will be provided to ensure that workers will be alert to any signs of past cultural activity in the area. Should any artefacts or evidence of past activity be discovered, SyvashEnergoProm LLC will notify the appropriate authorities and await direction before taking action that would disturb the resources.

SyvashEnergoProm LLC or its contractors will not disturb any chance find further until an assessment by a competent professional is made and actions consistent with the requirements of EBRD PR8 and IFC PS8 are identified.

Conduct training of workers on the chance find procedure following start of construction.

Construction noise General nuisance to local population caused Construction activities will be scheduled, unless otherwise agreed, from Monday to by construction activities. Without a Saturday 0600 to 2000. Unattended plant equipment should be kept to a minimum. detailed noise management plan, the Implement a detailed Noise Management Plan for the construction phase and set up impacts could be significant. community relations with a compliant reporting system.

Operational noise levels The noise model predicts exceedance of the Mitigation in the form of WTG blade serrated edges will be installed at WTGs 6, 7, 9, at nearby receptors night-time 45 dB limit at night, resulting in 10, 11, 12, 13, 15, 17, 19, 21 and 22.

significant impact. Additional exposure An operational noise monitoring and management plan will be developed for the levels at Locations A over 10 dB indicate a Project prior to the operational phase commencing. significant impact.

Shadow flicker during A number of shadow flicker receptors An operational shadow flicker monitoring and management plan will be developed operation (approximately 100 properties) are expected setting out the mitigation measures in detail. to experience shadow flicker impacts in Mitigation measures to be implemented include: excess of the recommended limits subject to • Programming of WTGs to shut-down during periods when shadow flicker is the actual orientation of windows. predicted to occur at the affected receptors at times when shadow flicker limits are exceeded. • If any complaints are raised by the local community (through the grievance mechanism or other channels) relating to shadow flicker from the wind farm, the wind farm operator shall investigate and instigate, at their own expense and within one month of being advised of the complaint, appropriate measures to mitigate the shadow flicker effects.

Transport - Abnormal Impact of the Project HGV / abnormal load Pre-construction

loads and HGV traffic traffic during construction on the existing Finalise the proposed transport route to site undertaking an access route study to during construction road. include: Increased total daily traffic flow on the local • Visual inspection of proposed route. road network. • The Project swept path analysis. • Identification of possible pinch points. • Identification of works required to bridges / boundaries etc. • Consultation with local roads authorities to determine the suitability of the proposed route.

Review the potential to source the required road stone on-site via borrow pits, negating the need for transportation of these materials to site.

Develop a Construction Transport Management Plan (CTMP) to manage potential impacts on the road network and its users. This should include (but not limited to):

• Details of the proposed route. • Commitment to all construction vehicles only using approved access routes to site. • Movement of abnormal loads restricted to outside of peak traffic periods. • The requirement (if any) for escort of abnormal loads. • When required, on-coming traffic halted to enable abnormal load transporters to negotiate any pinch points along the route. • Temporary direction signs indicating local routes to site and site entrances (statutory and site identification boards) provided along with advisory speed limit (to be agreed) signs along the length of the access route. • Maintenance of the access route during construction by the main contractor to a condition suitable for use.

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• Minimisation of mud and debris on road through use of wheel washing facilities at the site exit point and regular inspections of roads including maintenance such as road sweeping if required. • Encouragement of construction personnel to car share where possible. • Development of Incident and Contingency Plan. • Parking requirements / restrictions on site.

Consultation with local authorities regarding proposals and any authorisations / escorts required for the movement of abnormal loads.

• Consultation will be required with services / utility providers to determine the exact location of any underground and overhead services / utilities and prior to removal or re-alignment of any overhead cables. • Prior to construction of the Project, a series of leaflets and notices should be posted making local residents and businesses aware of any likely disruption.

Construction

Monitoring of the efficiency of deliveries of construction materials to the site and if necessary sufficient storage provision made available on site to prevent any delays to the construction process.

Construction TMP adhered to in order to reduce risks to drivers, local road users and pedestrians (where applicable).

Transport - Road works Damage to road edges and general ‘wear It is recommended that the route for the transportation of abnormal loads, and tear’ of the road may occur through particularly where the route crosses any bridges, be verified through further increased HGV movements. assessment (including swept path analysis and route inspection). Further re-enforcement work undertaken as necessary.

Transport - Operational Increased loading on local roads during Development of operational TMP. impacts routine maintenance and servicing. The majority of these will be light vehicles with HGVs only required if WTG components need replacing.

Population and Temporary jobs during the construction Communicate employment estimates, timeframes and skills requirements clearly to the employment phase of the Project. community on a continuous basis.

Long-term, high quality jobs created for the Invest in skills training to enable greater employment of local population throughout life of Project. Project life, for both construction and operations phases, to start as early as possible

Indirect job creation from service and supply ensuring maximum employment during construction. jobs to meet demands from resident Implement a local hiring plan in consultation with the community and in a way that workforce. meets long term operational needs of the Project as well as the short-term construction

Potential to fail to meet community needs, taking into account the relatively low skill base of the local population when it expectations for job creation due to a) lack comes to wind power related jobs. of suitability of local candidates, especially Development of Stakeholder Engagement Plan.

during construction and b) during the Water use and resource studies will be conducted to understand the water use transition from construction to operations. requirements of the Project and the water resources available in the region, to ensure that water is obtained from suitable sources and the Project does not have a negative impact on the current water supply for local communities and agriculture in the area.

Consultation activities will be conducted with local farmers to disclose Project activities, project schedules, and availability of grazing land.

Construction activities will be conducted in such a way as to minimise the effects on local communities and farmers.

Reclamation of the land will be conducted to backfill and restore native vegetation.

Provide detailed and regular information to local community members about Project activity to mitigate community concerns as a result of misinformation.

Enhancement measures include:

• Investigate local sourcing and procurement opportunities to promote sustainable small business development.

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• Assess investments in capacity building for small businesses to enable them to meet standards for procurement required by the company and to service the needs of indirect employees (through service industries). • Work with local vocational training schools to develop curricula which will qualify local students to better meet the needs to the developing wind industry locally.

Land Use / Economic The assessment associated with the loss of It is considered that a Livelihood Restoration Plan is not required, as the loss is not displacement grazing land has indicated that the expected to impact animal health in any significant way.

proportion lost during construction and Consultation and monitoring will be undertaken with land users as follows: operation is insignificant for • Pre-construction meeting with land users (to include heads of grazing / herders Pershokostyantynivka, Hryhorivka and association where applicable) to provide details of potential construction Strohanivka. In relation to Pavlivka and impacts, provide mapping of construction area and associated grazing Novovolodymyrivka whilst the current implications and the construction programme to allow land users to plan grazing available land is unable to support the /other activities in advance. estimated numbers of cattle present, • Regular monitoring meetings every two months to track perceptions towards the implementation of the Project is predicted to impacts to livelihoods arising from the loss of grazing land during the have a negligible impact, and therefore is not construction period. All meetings will be recorded. expected to have a significant impact on the • Where concerns are raised in relation to insufficient food for livestock during overall availability of grazing land, with just construction, these will be evaluated to determine if any further action is 0.8% and 0.4% being lost during necessary and additional mitigation is required. Should additional mitigation construction and operation respectively. be required this will be reviewed and determined as appropriate on a case by case basis, however may include provision of additional animal fodder. • If no concerns are raised during construction when the footprint is higher, these meetings will no longer be needed and not continued during operation. • If concerns are raised, meetings will continue every quarter during operation for the first year of operations. Outcome of meetings will be reviewed and if no concerns are raised meetings will be discontinued.

In addition, the grievance mechanism will be available throughout the construction and operational to record any concerns raised by land users.

Measures will be included within the Community Health and Safety Plan to ensure safe access is obtained to grazing land during the construction phase which will include, for example, cordoning off the working area to prevent the unauthorised entry of third- parties.

Population influx None of the village representatives stated Monitoring will be undertaken to quantify any influx into the region during that they believed population influx would construction. Monthly community meetings to monitor any Project impacts associated occur during the construction phase and on with job seeker influx. A management plan will be developed should influx occur. In this basis influx is not expected to occur. addition, the grievance mechanism will be available throughout the construction and operational to record and mitigate any concerns raised by the community.

Construction workforce Potential for direct short term negative Contractors will be responsible for meeting the labour and working condition impacts on a local scale if accommodation requirements. for a diverse workforce is not provided.

Construction camps. A number of contractors will be A Construction Camp Management Plan will be prepared and will describe the accommodated within the vicinity of the applicable controls on the contractor workforce. Project within construction camps. The Pre-construction community meetings will be held to provide information regarding camps will be developed in accordance with the construction workforce and camp and monthly community meetings will be held IFC and EBRD worker accommodation to discuss issues arising, review and monitor Project impacts resulting from standards and will ensure facilities are in construction workforce. Camp management plans and mitigation measures will be place so as there will be no associated reviewed following each meeting and updated if required. In addition, the grievance impact on existing community facilities. mechanism will be available throughout the construction and operational to record and mitigate any concerns raised by the community.

Local economy. Initial investment in the Chaplynka District, Additional training resources and funding for local people to be employed during due to the use of domestic materials, construction and operation. labour, and services. Construction supplies and equipment purchased locally are likely to have a minor beneficial effect.

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Benefits due to local construction workers increased earnings. Creation of full time jobs during operation could benefit the local economy.

Social cohesion. In the event that an accommodation camp Establishing clear rules for worker behaviour will avoid these issues. is constructed for construction workers coming into the area, there is potential for conflict between local livestock farmers and construction workers.

Safety risks from traffic. The increase in HGV traffic during Provide appropriate traffic safety training to all drivers (employees and contractors) as construction presents a risk of accidents. part of their induction and on an ongoing basis. Emergency response capacity is limited As part of pre-construction engagement activities, ensure that traffic safety and “rules (lack of responders, transportation and of the road” are discussed with local communities. Discuss and address community equipment). Hence, response time to concerns. Special sessions may be required for particularly vulnerable groups such as potential accidents is unlikely to be rapid. children. At minimum communicate type, frequency and traffic risks before heavy traffic begins for the construction phase. Use grievance mechanism and other means to monitor driver conduct. Implementation and compliance with the Community, Health and Safety Management Plan.

Personal safety. Increased risks to community safety and Develop and implement Site Security Plan. security are likely as a result of Project Ensure that Project security is aware of the Project’s goals to establish good workforce and other individuals to the area relationships with local stakeholders; the grievance mechanism for communities to as posing a threat to security, primarily in voice concerns; and receives human rights and cultural sensitivity training to ensure relation to their property and potential the respect and protection of the local community. unruly or destructive behaviour. Develop a code of conduct for security personnel, which outlines appropriate conduct, engagement and appropriate use of force. Ensure all security personnel read and sign code of conduct as part of their induction program. Introduce head of security personnel to neighbouring communities and outline the necessary safety precautions that will need to be put in place to ensure both the safety of the Project and safety of local communities. Community safety meetings should be organised with all potentially affected groups and be conducted in advance of construction activities. As part of ongoing stakeholder engagement efforts, ensure that all potentially affected stakeholders know how to contact the company and to file grievances (in accordance with the Grievance Mechanism).

Poor air quality. Construction activities will result in fugitive Implementation and compliance with a Traffic Management Plan which should dust. It will be generated by vehicle traffic identify the strategies used to manage dust on the road during the execution of the on unpaved roads, naturally occurring Project. windblown dust from disturbed lands and Implementation and compliance with the Dust Management. dust generated during construction Use of properly maintained vehicles and construction equipment with emission activities. controls. Fugitive dust will have the greatest potential Communicate project risk to local communities and address concerns accordingly. impact on communities close to the site, and Monitor any complaints filed (via grievance mechanism) from local stakeholders as an farmers who use grazing land close to the additional tool to monitor dust management measures. site.

Contamination of Increased Project waste and effluents may Implementation of the Waste Management Plan, to ensure that household and groundwater. increase pressure on local waste project waste is disposed of in line with Ukrainian standards; management and sanitation services and Where appropriate, support local public health campaigns against food and water infrastructure and have the potential to borne diseases. contaminate groundwater, risking the Implementation of a Camp Management and Security Management Plan to ensure spread of disease. the provision of a safe and healthy environment for workers.

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Introduction & spread of The rapid increase in population from the Ensure health screening is being conducted for employees and contractors before communicable diseases. presence of large, male workforces, coupled contracting workers and on a periodic basis throughout their employment/contract. with in-migration of income seekers to the As part of health and safety induction for workers, provide awareness training on area of influence, increases the risk of communicable disease prevention. Provide this training on an ongoing basis. introducing and spreading communicable Work in collaboration with an onsite medical team to ensure that such awareness and diseases. education training is appropriately provided to workers and contractors. Close living conditions, poor water and sanitation, and deprivation (whether inside Identify opportunities to support local public health campaigns that focus on or outside of the construction camp), can prevention of communicable diseases. increase the risk of respiratory disease, as Implementation of exposure to disease plan will be developed. well as food and water-borne diseases.

Health services & Project activities will result in an increase of Ensure that all Contractors are provided with adequate health care (for work related infrastructure. non-resident population and workforce, injuries and off the job-related health issues) that is independent of the local health which in turn could increase pressure on care system. local health services and infrastructure. Liaise with local health professionals to identify ways that the Project can provide sustainable investments in the health care facilities used by their workers.

Alcohol use. Project workforce will increase the size of Enforce and monitor the zero-alcohol tolerance policy, including current intoxication, the workforce with disposable income in a for workers during working hours. generally impoverished area. This is likely to Ensure random alcohol testing is conducted for workers entering and leaving the site. result in increased demand for alcohol in Design a system of penalties for anyone found with alcohol within the workers camp the area. or on site. This could also result in a potential increase in aggression or conflicts between workers and community members.

Injury from construction Potential for harm to workers due to Keep Project plant and equipment to pre-defined routes and areas. Use appropriate activities and emergency accidents related to construction activities signage. events. and emergency events. Provide information to local community via the SEP that they should not enter the construction area. Develop an emergency response plan (ERP). Work with local emergency responders to at minimum: (i) communicate ERP; (ii) depending on level of risk from emergency events build local capacity to ensure appropriate local response in case of emergency. Communicate potential risks and ERP to those potentially most affected by emergency events.

Occupational and Public Movement or operation of passenger and SyvashEnergoProm LLC and its contractors will comply with international Health and Safety construction vehicles, equipment, and Occupational Health & Safety regulations. materials could cause injury or death to A workforce manager in charge of all activities, and in charge of compliance with humans (drivers, passengers, pedestrians) or health and safety requirements reporting directly to the SyvashEnergoProm LLC animals (livestock or wildlife). project manager and will have independent lines of reporting to SyvashEnergoProm Using hand tools or larger equipment could LLC upper management. result in accidents that harm or kill workers. Prior to beginning work on the site, the workforce manager will develop a safety Falling overhead objects could cause injury program to cover construction and then operation of the site. or death. The safety program will include requirements for inspecting, testing, and calibrating Falls into or collapse of open excavations safety equipment, for monitoring the working environment for hazards, and for could cause injury or death. monitoring worker health. Falls from heights (buildings, WTGs) could All incidents and accidents will be recorded if they resulted, or nearly resulted, in cause injury or death. damage to equipment or injury. Blasting could cause injury or death. On an annual basis, SyvashEnergoProm LLC will report to the lender on the status of Contact with electrical lines or transformers the overall safety program, including information on training and on incidents. Both could cause injury or death. SyvashEnergoProm LLC and all its contractors will be required to produce a Health Noise and vibration could distress or injure and Safety Plan for both construction and operational phases. workers or distress residents.

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Medical facilities Risk of increased pressure to already Assess investments in local, social infrastructure (e.g. hospitals, schools, roads). stretched medical resources during Provision of on-site medical facilities. construction due to Project workforce. Negligible impacts during operation.

Aviation No impacts are predicted following The Ministry of Defence will be notified on the commencement and completion of consultation. State Aviation requirements construction. will be met. State Aviation Service aviation lighting requirements will be followed. The aircraft warning lights shall be installed in accordance with the State Aviation Service regulations / International Civil Aviation Organization Annex 14, Aerodromes. The Armed Forces Air Force Command headquarters will be informed of commencement and completion of construction of the wind farm.

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8 Monitoring of Environmental and Social Performance

8.1 Monitoring Programme

A programme of Environmental and Social Monitoring will be undertaken in order to verify the effectiveness of the proposed mitigation measures in reducing impacts and also to allow mitigation measures to be refined or developed as needed to further address potential impacts or to develop plans for future development. More specifically, the objectives of the monitoring program are to:

• Record project impacts during construction and operation. • Meet legal and community obligations. • Evaluate the effectiveness of the mitigation measures and identify any shortcomings. • Allow refinement and enhancement of mitigation measures to further reduce impacts. • Allow identification unforeseen issues or changes in operations and provide information for development of mitigation measures to deal with those issues or changes.

The environmental and social monitoring program was developed in accordance with the best international practices for the wind energy sector.

8.2 Key Performance Indicators

Key environmental performance indicators for monitoring plan are shown in Appendix A. Appendix B presents the monitoring program for the Project.

8.3 Reporting

Details of monitoring together with results will be summarised in a monitoring report which will be submitted by SyvashEnergoProm LLC to the Lenders for approval.

Each monitoring report will cover a period of three months and will be submitted one month subsequent to the end of that monitoring period.

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9 ESMP Review

An effective ESMP requires monitoring and updating. If this is not undertaken, the policy that governs it may become out of date and ineffective.

9.1 Scheduling and Managing Reviews

The implementation of clear internal auditing systems will ensure that the measures contained in the policy are being implemented on a day-to-day basis. As part of the ESMP SyvashEnergoProm LLC will:

• Monitor the overall effectiveness of the ESMP against the Key Performance Indicators.

• Develop mechanisms to monitor the targets and objectives.

• Provide clear definitions of reporting and management responsibilities.

• Regularly schedule reviews of the procedures and practices that underpin the ESMP.

The ESMP will be reviewed following each detailed audit during construction. This is likely to occur on a two-monthly basis. During the first year of operation, the ESMP will be reviewed every six months. Following this period, the ESMP will be reviewed annually.

The results of the review will be used to update the ESMP if deemed necessary to either ensure targets are met or to ensure continual improvements in environmental performance.

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10 Record Keeping

The following documents are important to the environmental management of the Syvash Wind Farm Site. These will be available on site and will be kept up-to-date by Site Management.

• The Syvash Wind Farm ESMP (this document) and all associated plans. • Syvash Environmental and Social Impact Assessment and Addendum. • Planning permission, planning/loan conditions and associated documents. • Any discharge consents and abstraction licences. • Complaint and incident log books and procedures (including grievance mechanism). • Site inspection forms. • Results of any site environmental monitoring. • Contact names, addresses and telephone numbers for environmental or safety incidents. • Emergency Response Procedure. • Environmental audit reports and non-conformance notices. • Waste transfer notes for removal of waste from site. • Site Waste Management Plan. • Training records. • Details of ESMP reviews.

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Key Performance indicators

SyvashEnergoProm LLC sets ambitious environmental targets in order to reduce the Syvash Wind Farm environmental footprint. The targets will be assessed by the following key performance indicators which were set according to the national standards and international best practice (adhere to more stringent lender’s standards) for the Project (WTGs, substation, control centre, access roads, storage areas, and other parts) during construction and operational phases.

Environmental Project activities Key performance indicators Project phase Compliance with EBRD standards/international best practice and national component standards

Earthwork and removal of vegetation cover Fugitive dust and particles (SPM, Construction Ukrainian national standard on air pollution, air quality and air pollutants. Transportation of materials, equipment, and PM10) Decommission Best international standard of no visible dust emission at 50 m distance.

employee commuting Greenhouse gas (CO2 emission) IFC EHS General Guidelines. Storage of chemicals, materials, and waste on No more than100kt CO emission for the entire project per year to be on track of low to 1. Ambient air quality 2 site medium emission category according to EBRD’s greenhouse gas assessment methodology

On-site energy and heat consumption Other indirect supply chain activities

2. Ambient noise and Earthwork and site preparation Observed sound levels in Leq dBA for Construction Ukrainian national standards for noise and vibration vibration level Transportation of materials, equipment, and day and night time against nature and Operation IFCs general guidelines (operational fixed night time limit of 45dBA, daytime limit of 55 employee commuting recipient Decommission dBA). WTG electricity generation process (aerodynamic noise caused by blade rotation and mechanical noise caused by nacelle operation and others).

3. Shadow flicker WTG operation Complaints Operation Shadow flicker events must meet IFCs EHS wind energy guideline limit (30 hour per year / Shadow flicker monitoring 30 minute per day limit).

4. Surface and groundwater Storage of oil, lubricating materials, chemicals, pH (SI) Construction Ukrainian national standard on surface and drinking water quality quality domestic and industrial waste on site Conductivity (µS/cm) Operation Ukrainian national standard on groundwater pollution protection Transportation of oil, lubricating materials, TDS (mg/L) Decommission IFC EHS wind energy and general guidelines. chemicals, and other computations TSS (mg/L)

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Environmental Project activities Key performance indicators Project phase Compliance with EBRD standards/international best practice and national component standards

Earthwork DO (mg/L) ORP Metals (mg/L) E-coli (cfu) Hydrocarbons 5. Soil quality and erosion Storage of oil, lubricating materials, chemicals, Erosion rate observation Construction Ukrainian standard on maximum permissible level for soil pollutants domestic and industrial waste on site Soil contaminants identified in the Operation Ukrainian standard on soil quality Transportation of oil, lubricating materials, Ukrainian and international standards Decommission Ukrainian standard on top soil removal and storage during earthwork chemicals, and other computations since soil contaminants vary in International best practice on restoring degraded land and re-establishing grassland Earthwork properties from organic to water vegetation relevant to wind farm construction, operation, and decommissioning. soluble contaminants, radioactive contaminant properties. Incidents requiring clean-up operations – spill kits 6. Flora protection Earthwork Destruction rate observation Construction Ukrainian national standards Transportation Operation International best practice on restoring degraded land and re-establishing grassland Decommission vegetation relevant to wind farm construction, operation, and decommission

7. Fauna protection Earthwork Bird and bat injury, mortality, and nest Construction Best international standards and practices for bird and bat surveys and monitoring WTGs abandonment in the vicinity of the Operation OHL WTGs Feeding bird species and prey concentration near the WTGs 8. Archaeology / Cultural Earthwork Chance finds Construction Ukrainian national standards. heritage Damage to existing cultural heritage Best international practice (EHS Guidelines for wind energy)

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Monitoring Checklist Component Project phase Parameters Responsibility Deliverables Frequency Location Standard Pre-construction SPM, PM10, CO2 emissions Powerchina 1 sample per location Once Along the roadway Ukrainian standard on At control assessing fugitive dust in air Construction SPM, PM10 Powerchina 1 sample per location Once per construction season Worker camp quality in workplace.

CO2 emissions Following any complaint Closest residential Best international practices. 1. Ambient air quality Operation CO2 emissions SyvashEnergoProm LLC 1 desktop study Once per year receptors Construction compound

Construction dBA level Powerchina Records of each location Once per construction season Along the roadway Best international standard (IFC Annual or 6 monthly The identified General EHS Guidelines Limit) independent audits recipient location / 2. Ambient noise Following any complaint receptor quality Substation Operation dBA level SyvashEnergoProm LLC Records of each location Start of operations The identified Best international standard (IFC Following any complaint recipient location / General EHS Guidelines Limit) receptor Operation Duration of shadow flicker SyvashEnergoProm LLC Records of each location Following any complaint Residential receptors Best international standard (IFC 3. Shadow flicker events EHS Wind Energy Guidelines Limit) Pre-construction pH (SI) Powerchina 1 sample per location Once At the groundwater Ukrainian national standards Conductivity (µS/cm) boreholes. Best international standard for TDS (mg/L) Any other natural groundwater and drinking TSS (mg/L) waters used as water quality standards DO (mg/L) potable water. Construction Powerchina 1 sample per location Once per construction season BOD (mg/L) Nearest surface water

4. Surface and ORP (mV) locations. groundwater Operation E-coli (cfu) SyvashEnergoProm LLC 1 sample per location Annual quality Metals (mg/L) for After any spill within 1 km of any groundwater. well Hydrocarbons

Pre-construction Erosion rate observation. Powerchina Photographic records Once (geotechnical study) General Ukrainian standards

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Component Project phase Parameters Responsibility Deliverables Frequency Location Standard Construction Metal screen (AS, B, Cd, Cr, Powerchina Records at each location Pre-construction Pre-construction International best practices Cu, Pb, Hg, Ni, Se, Zn) Checklist observation reports Continuous during construction sampling by site PAH (USEPA 16) Annual photographic record After any accidental spill section/plot. pH All areas destructed Phenol (total) by earthwork, Cyanide (total) construction Organic materials content equipment, and 5. Soil quality and TPH workers erosion All roadways

All areas of accidental spills Operation SyvashEnergoProm LLC Annual photographic record Quarterly observation for Checklist observation record evidence of soil erosion After major spills, precipitation/run-off event

Pre-construction Pre-works surveys for Powerchina Photographic and narrative Once Soil monitoring Ukrainian Standards sensitive plant species. record locations Best international standards Grassland disturbance level. Construction Powerchina Before construction and after of Soil monitoring 6. Flora protection construction season locations (reclamation)

Operation Annually Soil monitoring locations Pre-construction Breeding bird survey SyvashEnergoProm LLC Bird survey Once Past and present Ukrainian Standards Pre-construction animal Fauna survey nests Best international standards survey Vantage points Construction 2019 VP survey SyvashEnergoProm LLC Bird survey Each construction season Past and present Operational monitoring (breeding, migration season) nests 7. Fauna protection Animal carcass survey Vantage points Carcass searching for birds Entire project area Operation and bats SyvashEnergoProm LLC Bird survey Migration seasons, wintering At base of each WTG Survey report season. Vantage points During the audits Entire project area

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Component Project phase Parameters Responsibility Deliverables Frequency Location Standard After any incident with large number of bird collisions or electrocution Construction Chance finds Powerchina Chance find recording Daily All areas destructed Ukrainian Standards by earthwork, Best international standards 8. Archaeology / construction cultural heritage equipment, and workers.

Construction Noise, fire safety, hazardous Powerchina Incident reporting Daily At construction camp Ukrainian standards on materials registrar, solid and Training records All roadways occupational health and safety; Operation sanitary waste SyvashEnergoProm LLC Incident reporting Daily All turbine locations fire safety, incident notification, PPE use Training records Local herder area disaster management and Health and safety trainings others 9. Occupational and Traffic safety, signs, road Best international practices public health and inspection safety Accident, incident registration Speed limit enforcement Health checks Workers grievances Other workplace inspections Pre-construction Baseline social economic SyvashEnergoProm LLC Baseline socio-economic Once Project affected Best international practices condition conditions report (completed communities Construction Population size SyvashEnergoProm LLC as part of ESIA Addendum) Continuous Local grazing areas Grievances Quarterly reports. Construction camp 10. Socio – Available grazing lands Annual summary report economic Operation Social and employment SyvashEnergoProm LLC Annual summary report Continuous conditions records (wage rate, unemployment rate, local government annual budget, contracts with local service) Construction Number of security Powerchina Inspection and security Continuous Construction areas Best practices 11 - Safety and personnel employed; reports Security Number of inspection missions.

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Pre-Construction Ecology Survey Protocol

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Pre and During Construction Ecological Mitigation and Monitoring Protocol, Syvash Wind Farm

Prepared for Wood.

March 2019

ECOLOGICAL MITIGATION AND MONITORING PROTOCOL

TURNSTONE ECOLOGY

Project Number TT2386

Title Syvash Wind Farm, Ukraine

Document Number TT2386-R06-Ecological Mitigation and Monitoring Protocol- Rev00

Client Wood.

Issue Date March 2019

Prepared by: Tristan Evans Director 19/03/2019

Checked and Approved For Issue by: Stephen Wilson Director 19/03/2019

This report has been prepared by Turnstone Ecology Limited, with all reasonable skill, care and diligence within the terms of the Contract with the client.

We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above.

This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their own risk.

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Table of Contents

1 Introduction ...... 5 2 Habitats / Flora ...... 6 2.1 General ...... 6 2.1.1 Agricultural land ...... 6 2.1.2 Freshwater wetland ...... 7 2.1.3 Saline habitats ...... 8 2.2 Habitats affected by proposals ...... 8 2.3 Evaluation...... 14 2.4 Mitigation ...... 15 3 Bats ...... 17 3.1 General ...... 17 3.2 Evaluation...... 17 3.2.1 Roosting Bats...... 17 3.2.2 Bat Activity ...... 18 3.3 Mitigation ...... 19 4 Otter ...... 20 4.1 General ...... 20 4.2 Evaluation...... 20 4.3 Mitigation ...... 20 5 Birds ...... 21 5.1 General ...... 21 5.2 Evaluation...... 21 5.2.1 Spring Migration...... 21 5.2.2 Breeding ...... 22 5.2.3 Autumn Migration ...... 22 5.2.4 Winter ...... 23 5.3 Mitigation ...... 23 6 Herpetofauna ...... 25 6.1 General ...... 25 6.2 Evaluation...... 25 6.3 Mitigation ...... 25 7 Invertebrates ...... 27

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7.1 General ...... 27 7.2 Evaluation...... 27 7.3 Mitigation ...... 27 8 Mitigation and Monitoring Timings ...... 29 8.1 Summary of Mitigation and Monitoring ...... 29

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1 INTRODUCTION

The purpose of this document is to outline pre- and during construction ecological mitigation and monitoring at the proposed Syvash Wind Farm, Kherson Oblast, Ukraine.

Ecological surveys and assessment of the project site have previously been completed and then updated during 2018. Mitigation and monitoring is required to minimise impacts on the following features and species: • Habitats and flora; • Bats; • Otter; • Birds; • Herpetofauna; and • Invertebrates.

This document provides information on the assessment of impacts on the above features and species/groups and fully details the proposed mitigation and monitoring. It also includes information on the timings of the mitigation and monitoring and who is responsible for the relevant tasks.

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2 HABITATS / FLORA

2.1 General

Botanical surveys were completed as part of original survey effort undertaken by Melitopol State Pedagogical University with the habitats and species composition of the site summarised in the 2018 Wood ESIA.

Previous surveys identified that the habitats within the Project site are dominated by agricultural land (arable, fallow fields and grassland) with some areas of steppe vegetation, salt marshes and freshwater pools within and immediately adjacent to site. Sand-shelly spits and islands and reedbeds associated with saline waters of the Western Syvash border the southern edges of site and protrude into site at the western end.

Agricultural activity within the Project is influenced by the salinity of the surface soils. In the more coastal areas of the site agricultural productivity is low and fields have been cultivated for a maximum of three to four years, after which they’ve been left fallow. This cultivated land within the Project leased area relates to an experimental agricultural project to determine the productivity of the land within the region. This is managed by the Project and will not be progressed after 2018.

Uncultivated Steppe and halophytic vegetation is present as narrow strips along the edges of tracks and steep slopes of embankments and bunds that run along the coast and drainage channels, which cannot be cultivated.

Woodland shelter belts have been cleared or died off leaving lines of scattered trees along the edges of existing access tracks and drainage channels.

The communities of Pershokostiantynivka, Hryhorovka, Pavlivka, Novovolodymyrivka, Strohanivka and Ivanivka are all in close proximity to the site.

The 2018 surveys have been used to update and confirm habitat types and any botanical species of importance that will be affected by the Project. Details of these habitats and species are given in the following sections with the Project area divided up for illustrative purposes and the habitats affected by WTGs and access tracks within each section summarised.

2.1.1 Agricultural land

The majority of the Project site is or has been affected by agricultural activities, such as cultivation of crops or grazing by livestock. Habitats within the agricultural areas include arable, steppe and grassland meadows.

Arable fields dominate flat inland areas within and immediately to the north of the Project site. At the time of the 2018 surveys much of the arable areas were cultivated with a variety of crops evident but where fields had been left uncultivated and fallow and/or dense ruderal vegetation was present. Russian

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Knapweed (Acroptilon repens) continues to dominate the ruderal vegetation with Cardario- Agropyretum, Convolvulo-Agropyretum repentis, Lepidietum drabae, Xanthietum spinosi, Melilotetum albi-officinalis, Artemisietum absinthii, Polygonetum avicularis, Bromo-Hordeetum murini, Ambrosio- artemisifoliae-Cirsietum setosi, Erigero-Lactucetum serriolae, Cirsio-Lactucetum serriolae, Cynancho acuti-Convolvuletum arvensis, Bromo-Hordeetum murini, Atriplicetum tataricae and Plantagini- Polygonetum avicularis also present. Field margins and fallow vegetation are dominated by Artemisia Taurica, Lepidium perfoliatum, Poa bulbosa, Bromopsis riparia, Eryngium campestre, Anthemis ruthenica, Senecio vernalis, Salvia aethiopis, Lamium amplexicaule, Descurainia Sophia, Carduus acanthoides, Cardaria draba and Convolvulus arvensis all also evident.

Steppe vegetation is present where areas are uncultivated or have avoided recent cultivation, such as margins between fields and tracks where tree shelter belts were once present as well as steeper slopes adjacent to drainage channels and wetland areas. The majority of these areas are heavily grazed and badly degraded by livestock and are essentially secondary meadows growing on areas that would have formally been steppe grassland habitats. Species noted within these areas and usually associated with Steppe habitats include Festuca valesiaca, Elytrigia repens, E. іntermedia and E. preudocaesia as well as Elytrigia repens, Elytrigia preudocaesia, Alopecurus arundinaceus, Calamagrostis epigeos and Bromopsis riparia.

Meadows are present in low lying areas around the edges of wetlands (both saline and freshwater) and within depressions where more moisture is present. In areas where seasonal flooding occurs, halophytic- beamed plant communities of Puccinellietum distans, Juncetum gerardii, Puccinellietum (aeluroposum) littoralis, Juncus maritimus, Eleocharis mitracarpa, Crypsis aculeata), Alisma gramineum and Ranunculus scleratus occur. Elytrigia elongata dominates lower areas of the meadow habitat as well as in more damp areas where there are formations of saline meadows. In these areas Puccinellietum distans and Juncetum gerardii also occur. Almost all meadows within the Project area are badly degraded as a result of excessive grazing and periodic burning. Although not located during the 2018 surveys, one species listed in the Red Book of Ukraine (2009) – Lepidium syvaschicum was found within the flood meadow habitats during previous surveys and this species is also listed in the European Red List (1991).

2.1.2 Freshwater wetland

Freshwater wetlands which consist of waterbodies dammed off from saline water and surrounded by vegetation are scattered along the length of the Project site. Drainage channels seasonally filled with freshwater are also present behind the steep embankment and adjacent to existing access tracks running along the edge of the coast from the current wind farm east.

Aquatic vegetation includes Potamogeton pectinatus., Lemna triscula., Ceratophyllum demersum and Вatrachium kаuffmаnnii whilst marginal vegetation is dominated by dense stands of Phragmites australis and occasional stands of Typha angustifolia.

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2.1.3 Saline habitats

Extensive saline areas of the Western Syvash border the southern edge of the Project site with a saline inlet extending up into the far western part of the site. Vegetation in these areas is almost non-existent due to the high salinity and pollution with bare mud dominating around the edges of any water. Stands of Phragmites australis do however occur along sheltered parts of the shoreline and on some of the offshore islands. Some Elytrigia elongate, Puccinellietum distans and Juncetum gerardii is present in areas above the level of regular inundation by saline water.

2.2 Habitats affected by proposals

To identify what habitats will be affected by the proposed WTGs and associated access routes, the Project site has been divided into six areas (Figures 3 - 8) with summaries of the different habitats provided.

Area A

Habitats present at the far western end of the Project site (Area A) include extensive meadows and areas of currently or previously cultivated arable and heavily grazed vegetation that includes steppe plant species. Freshwater and saline wetlands are also in close proximity to some of the WTGs and access routes. These habitats and WTG and access route locations are shown in Figure 3.

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Figure 3. Area A

WTGs 1 and 3 will be located within arable habitat whilst WTGs 2 and 8 will be on the edge of arable and meadow habitats.

WTGs 4, 6, 7, 9, 11, 13, 15 and 16 will all be located within meadow habitat grazed by livestock.

WTGs 10 and 12 will be within habitat with steppe characteristics, although these areas are in close proximity to farms and the village and heavily grazed and disturbed.

WTG 8 is located immediately adjacent to a freshwater wetland and WTGs 4, 9 and 11 are adjacent to saline habitats.

The proposed access routes will mainly utilise existing routes around the northern, western and eastern parts of Area A. Additional routes will however be created through mainly arable and meadow habitats with a short section through steppe habitat between WTG 12 and 10.

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Area B

Habitats present within Area B include a mix of meadows, currently or previously cultivated arable, heavily grazed vegetation that includes steppe plant species, freshwater wetlands and saline habitats. These habitats and WTG and access route locations are shown in Figure 4.

Figure 4. Area B

WTGs 17, 18, 19, 20, 21, 22, 25 and 27 will all be located within meadow habitats that are currently grazed by livestock.

WTGs 24, 26, 28 and 30 will be within an arable field that had been cultivated for crops in 2018.

WTGs 23, 29, 31 and 33 will be within habitat with steppe characteristics, although WTGs 29, 31 and 33 are in close proximity to farms and the existing wind farm operations and heavily grazed and disturbed.

WTGs 17, 18, 20, 21, 22, 25, 27 and 31 will be adjacent to wetland areas with the main access route between Area A and Area B passing over a dam separating freshwater and saline wetlands.

The proposed access routes will mainly utilise existing routes associate with the village at the western end of the area and existing wind farm at eastern end. Additional routes will however be created through meadow habitats with a short section through steppe habitat to get to WTG 31.

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Area C

Habitats present within Area C are dominated by extensive arable under cultivation during 2018. Strips of uncultivated steppe habitat are present around the edges of Area C and this habitat also occurs alongside many of the existing tracks and field margins where woodland shelter belts have been reduced to scattered individual trees. A narrow strip of meadow and saline habitats are present beyond the drainage channel and embankment that runs along the southern and eastern edge of Area C. These habitats, WTG and access route locations are shown in Figure 5.

Figure 5. Area C

Apart from WTG 51 all WTGs will be within cultivated arable habitats.

WTG 51 will be located within steppe margins on the edge of an arable field.

The majority of access routes within Area C will utilise existing tracks but where necessary new routes will only affect arable habitats and potentially small areas of steppe field margin.

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Area D

Habitats present within Area D are a mix of steppe and meadow with a village on the northern edge and extensive arable fields to the north and east. A strip of meadow and saline habitats are present beyond the drainage channel and embankment that runs along the southern edge of Area D. These habitats and WTG and access route locations are shown in Figure 6.

Figure 6. Area D

WTG 50 will be located within an undulating uncultivated area of steppe, which is close to the village and farms and therefore heavily grazed and disturbed.

WTGs 52, 53 and 54 will be within areas of meadow between an existing main track and uncultivated fields where steppe vegetation is present.

Proposed access routes will utilise an existing track that runs adjacent to the drainage channel and embankment along the southern edge of Area D. New routes will be created to access the WTG locations and these will affect small areas of steppe and meadow habitat.

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Area E

Habitats present within Area E are dominated by extensive arable under cultivation during 2018. Patches and strips of uncultivated steppe habitat are present on steep slopes around the freshwater wetland at the north-western edge of Area E and adjacent to the existing track and drainage channel embankment that runs along the southern edge of the area. As well as the freshwater wetland at the north-western edge another freshwater wetland with open water and surrounding reedbeds is present in the middle of Area E. Narrow strips of meadow and vegetation associated with saline habitats are present along the southern side of the embankment. These habitats and WTG and access route locations are shown in Figure 7.

Figure 7. Area E

WTGs 55 and 56 will be located within an area of steppe vegetation.

WTGs 57, 58, 59, 60, 61 and 62 will all be within cultivated arable fields.

WTGs 57, 59 and 60 will be in close proximity to the freshwater wetlands.

Proposed access routes will utilise an existing track that runs adjacent to the drainage channel and embankment along the southern edge of Area E. New routes will be created to access the WTG locations and these will mainly affect arable habitats with small areas of steppe affected by short spur routes to access WTG 55 and 56.

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Area F

Habitats present within Area F are a mix of arable fields under cultivation during 2018, meadows, strips of steppe vegetation and two areas of freshwater wetland with open water and surrounded by dense reedbeds and scattered trees. An existing track and drainage channel embankment runs along the southern edge of the area, including across the dam that separates the freshwater wetlands from the saline habitats to the south of the embankments. A narrow strip of meadow habitat is located between the saline shoreline and embankment at the western part of Area F. These habitats and WTG and access route locations are shown in Figure 8.

Figure 8. Area F

WTGs 63, 64, 67 and 68 will all be within cultivated arable fields.

WTG 66 will be within meadow habitat between cultivated fields and the freshwater wetland habitats.

Proposed access routes will utilise an existing track that runs along the embankment between the drainage channel and saline habitats and over the dam between the freshwater wetland and saline habitats. New routes will be created to access the WTG locations and these will mainly affect arable habitats with small areas of meadow around WTG 66 also affected.

2.3 Evaluation

Additional habitat survey work and assessment has been completed during July 2018 to provide an update to what habitats are present within the Project area, identify any species of importance and

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confirm the type and extent of habitats affected by the proposals based on confirmed WTG layouts and proposed access routes.

No species of national or international importance were found during the 2018 surveys. Lepidium syvaschicum was found during previous survey work and remains the only botanical species found on site that is listed within the Ukraine Red Book and European Red List. This species was only found to be present within meadow habitats at the far eastern end of the Project site and not within areas affected by WTGs or proposed access routes.

Habitat loss associated with the construction of WTGs and proposed access routes will be minimal and mainly affect arable and grazed meadow habitats that are common in the region. Small areas of steppe habitat will also be affected but this habitat is patchy and fragmented on site and heavily grazed and disturbed. Habitat creation and enhancement included as part of the proposals would offset any loss of steppe habitat as a result of turbine and access route construction.

Freshwater wetlands and areas of seasonally flooded meadow, which are not common habitats in the region, will not be directly affected by the proposals and appropriate mitigation measures will be put in place to ensure potential indirect impacts, such as from pollution and changes to hydrology, will be minimised.

2.4 Mitigation

The final locations of WTG and associated access routes will mainly avoid habitats that have been identified as being of highest sensitivity. This includes freshwater wetlands, wet meadows and less disturbed uncultivated areas of meadow and steppe vegetation. Habitat supporting the National Red Data Book Species Lepidium syvaschicum, will also be avoided. This will ensure that negative impacts on habitats and flora are kept to a minimum and of low significance.

All areas of sensitive habitats and/or where notable species occur that are not being affected by construction activities will be clearly marked on the construction plans and will be marked on site to prevent construction activities in these areas. An ecologist will be present to supervise any works that are required in close proximity to these sensitive habitats.

Pre-construction mitigation works to avoid and/or minimise the loss of sensitive species of flora will be completed. This will include pre-works surveys for sensitive plant species that could be present in areas affected by construction works associated with WTGs and access roads during construction and where appropriate the translocation of species and/or recreation of habitats completed. Pre-works surveys will be targeted to specific areas where sensitive species are known to be present based on existing survey data and mapping. Certain plants could be difficult to detect during the winter months so where data and mapping suggests sensitive plants species could be present, they will be presumed present and translocation and/or recreation of wider areas completed where necessary.

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The recreation and enhancement of uncultivated steppe and meadow habitats, including the retention and increase of field margins, will also be completed as part of the proposals.

Standard pollution control measures will be enforced during the construction phase of the Project to ensure there are no impacts on habitats. All fuel and lubricants will be stored in double bunded storage containers and dedicated re-fuelling areas will be maintained. Spill kits will be available at all storage and re-fuelling sites and all spillages will be cleaned up immediately. Any incidents will be reported and investigated, and additional control measures implemented as necessary. All vehicles being used on the site will be well maintained and subject to regular service and maintenance.

Alien and/or invasive plant species are not currently frequent in habitats within or adjacent to the Project site. Vehicles and any materials being brought onto site will therefore need to checked for the presence of alien or invasive species prior to arriving on site to ensure none are introduced into habitats within and adjacent to the Project site. If alien or invasive species are found to be present within the Project area during the construction and operational phases of the development then these will be eradicated using appropriate methods.

There will be no collecting of plant species within the Project site and this will be enforced by the Project team. The remaining shelter belt trees will also be protected from felling and or collection of fire wood by construction workers. Additionally, it will not be permissible to set fire to trees and/or steppe and meadow habitats during the construction and operation phases of the Project.

The site will maintain excellent housekeeping practices to ensure that all refuse and other waste materials are disposed of correctly as well as ensuring high levels of recycling is completed.

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3 BATS

3.1 General

Bat surveys across the Project site were previously completed as part of the original ESIA work undertaken by Melitopol State Pedagogical University with the results and assessment summarised in the 2018 Wood ESIA.

Previous surveys were completed during 2012, 2013, 2015 and 2017, although not all of the surveys were specific to the Project site as the extent of the wind farm was not established until the 2015 surveys.

Surveys were completed in the majority of the bat active seasons, including during the bat migration seasons (March and September / October) but not during the peak maternity period. A total of 14 bat species utilising habitats within and adjacent to the wind farm were identified, although most notable species were recorded during the 2012 and 2013 and in areas outside of the current Project site boundary.

The most frequently recorded bats were Common Noctule, Kuhl’s Pipistrelle, Nathusius’ Pipistrelle and Parti-colored bats with generally increased activity of Common Noctule in Spring 2017 and greater frequency of the Pipistrelle species in the autumn 2017 surveys. Recorded bat activity is described in the University species reports as being low across the Project area and no areas of high activity were noted (e.g. habitat features / roosts).

No previous surveys were completed during the peak maternity period (June to August inclusive) so the main purpose of the 2018 survey effort was to establish whether any maternity roosts are present within or adjacent to the Project site and/or levels of bat foraging and commuting activity over the Project site.

Bat survey and data collection undertaken in 2018 involved the following techniques: • Roost search; • Transect surveys; and • Static detector surveys.

Bat surveys in 2018 were planned and setup by Turnstone Ecology with the surveyor team led by Andriy-Taras Bashta, a Senior Research Scientist at the Institute of Ecology of the Carpathians with extensive experience in bat surveying and ecology within Ukraine and Eastern Europe.

3.2 Evaluation

3.2.1 Roosting Bats

Roost search surveys confirmed just a single roosting location within a large crack on the eastern aspect of a concrete bridge over the drainage channel approximately 180m west of WTG 54. A small number (3) of small bat droppings (characteristic of a pipistrelle species) were present in the entrance to the

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crack. No bats could be seen within the crack and no bats were recorded during further survey effort (emergence / re-entry surveys completed as part of transect surveys).

Other concrete bridges are present along the drainage channels but searches of these found no evidence of bats, although features such as cracks and holes in the concrete were present in the majority of bridges and are suitable for roosting bats so roosts cannot be entirely ruled out over the course of the project.

No features suitable for roosting bats were found to be present in the trees scattered within and adjacent to the Project site and although scattered farm buildings and existing wind farm buildings do have features suitable for roosting bats no roosting bats or evidence of bats was found during searches or additional activity survey effort.

3.2.2 Bat Activity

Transect surveys have shown the species most frequently recorded was Pipistrellus kuhlii/P. nathusii, which accounted for approximately a third of all recordings. These bats were most frequently encountered on Transects 1 and 5, which is as would be expected based on habitat types present within these areas. Assessment by transect point has shown that areas near to freshwater wetlands and villages were used more than those in saline habitats and arable farmland locations.

Recorded bat activity on transects was highest in August, with approximately double the recordings when compared with June. Increases in activity during this month could be accounted for with the emergence of young bats from nursery colonies, as well as the early movements of migrating species - highlighted in particular by the increase in numbers of Nyctalus species and Vespertillio murinus, which are known to migrate between breeding and hibernation sites in this region. This correlates with the results from previous surveys at the site that also showed higher levels of activity in August than in other months.

At risk species were encountered on average between 9.05 times and 17.8 times per transect per visit. This represents what would be considered a typical level of activity for a site with the habitat types present. The species most frequently recorded during the static detector surveys were Pipistrellus kuhlii (596 passes) and Nyctalus noctula (546 passes), which account for 27% and 25% respectively of all recorded passes, or 52% of passes when combined. The months with highest activity were May and June however equipment failure in July and August limited the amount of data collected over these two months meaning direct comparison between transect and static results is not possible.

The results of the 2018 bat surveys are in line with the results of previous surveys completed for the Project with levels of bat activity within the Project area generally low with a slight increase in numbers during August. Species specific predicted impacts are therefore as stated within the EsIA and repeated below.

Construction - High sensitivity bat species could be indirectly affected through noise disturbance and or lighting impacts along commuting routes and or of foraging areas. Indirect negative impacts on bats are considered to be of moderate to high significance.

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3.3 Mitigation

In line with recommendations set out in Eurobats Publication Series no. 6 WTGs should be located away from sensitive areas shown to be used more frequently by bats. The majority of WTGs are located at least 200m from areas of freshwater and village outskirts, where most bat activity has been recorded and WTG micrositing has further increased distances from freshwater habitats. Some WTGs will be within 200m of freshwater, at the western and eastern ends of the Project site, but extensive suitable habitat will be unaffected by WTGs and main foraging and commuting routes between village roost sites and freshwater will be retained and unsevered.

During construction, it will be ensured that main foraging and/or commuting habitats remain unlit by artificial lighting associated with works areas. This includes lighting associated with compound and storage areas.

Any suitable roosting features in close proximity (approximately 200m) to turbine construction areas will be searched by the bat surveyors prior to the start of works. If roosting bats are found to be present in a feature, are considered to be breeding or hibernating, and are at risk of disturbance during works, then works will be postponed until breeding has finished or the bat/s become active.

Additional bat surveys will be completed during 2019 in order to develop continued mitigation packages to further reduce impacts on receptors of high sensitivity. These surveys will include the continuation of bat activity surveys (transects and static detectors) throughout construction. Survey visits to be completed monthly during the main bat active season (April to October) and patterns in activity analysed and mapped to allow amendments to the overall mitigation strategy to be made. A detailed survey methodology and programme has been developed and will be presented to the bat surveyors during the April site visit.

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4 OTTER

4.1 General

Information regarding terrestrial mammals was not provided within the baseline documents provided by the University, however it was assumed for the purposes of the Wood. ESIA that Eurasian Otter could be present within and or adjacent to Project site based upon species range and habitats present. Eurasian Otter are listed as Vulnerable in the National Red Data Book, Near Threatened by the IUCN and are also included on Annex II of the EU Habitats Directive.

The freshwater wetland habitats do appear suitable for Otter with the lakes at the western and eastern ends of the Project site supporting fish but the saline habitats are unsuitable for Otter and as the drainage channels and watercourses are dry for large periods during the year, the area is isolated from larger and more permanent watercourses.

4.2 Evaluation

To confirm presence or likely absence of Otter within and adjacent to the proposed Project site, Otter surveys were completed by Turnstone Ecology during a site visit in May 2018. No evidence of Otter was found within or adjacent to the Project site.

Based on the results of the 2018 surveys and further assessment of suitable habitats on and adjacent to the Project site and connectivity to other suitable aquatic habitat in the surrounding area, it is considered that the presence of otter within the Project site is very unlikely.

4.3 Mitigation

Specific mitigation measures for Otter are not required as part of the proposals but in the unlikely event of Otter occurring within the vicinity of proposed works the required mitigation measures to ensure there will be no negative impacts on the freshwater wetland habitats will also ensure there will be no negative impacts on Otters.

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5 BIRDS

5.1 General

Ornithological surveys were previously completed on and around the proposed project area prior to 2018, however, no specific Vantage Point surveys had been undertaken. Additional spring and autumn migration Vantage Point surveys as well as breeding and peak count surveys were therefore undertaken during 2018 to; • quantify the impact of the project on key avian species; • inform final turbine layout; • develop additional mitigation (e.g. turbine shut down, habitat/species management plan); and form the baseline for any future required supplementary surveys and operational monitoring.

Vantage Point (VP) surveys are designed to quantify the level of flight activity and its distribution over the survey area. Its primary purpose is to provide input data for the Collision Risk Model, which predicts mortalities from collision with turbines. Data can also be used to provide an overview of bird usage of the site, which helps to inform an overview of potential disturbance and displacement. The protocol for surveys at VPs was based on the methodology developed by Scottish Natural Heritage “Survey Methods for Use in Assessing the Impacts of Onshore Wind farms on Bird Communities” (2005, and most recently updated in 2014).

Peak bird counts (including important species and significant numbers of feeding, roosting and/or non- breeding flocks of any species) were recorded during the VP survey period, which will have included late overwintering, passage migrant and early breeding species. Counts were made from VP locations (before or after a VP session) as part of the VP survey effort as well as peak count visits outside of the VP survey times (typically prior to or following surveys) and targeted on locations where habitats within and adjacent to the wind farm were considered likely to support notable species and/or assemblages of birds. Any relevant behaviour such as regular movements between roosting and feeding grounds, preferred roosting and breeding locations and nest sites were also noted.

During the spring migration surveys, that continued until the end of May 2018, information relating to breeding birds within each VP viewshed was collected. Further information on the breeding bird activity was obtained during a site visit in July 2018. Breeding status was defined using criteria devised by the European Ornithological Atlas Committee (EOAC).

5.2 Evaluation

5.2.1 Spring Migration

A total of 77 bird species were recorded during the 2018 spring VP surveys with five species (Black- tailed Godwit, Common Pochard, Northern Lapwing, Red-breasted Goose and Red-footed Falcon) listed as Near Threatened or Vulnerable on the IUCN Red List and 29 species in the Ukraine Red Book of threatened species.

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A total of 88 species were recorded during peak count surveys. This include seven IUCN Red List species and adds two Near Threatened IUCN Red List species (Curlew Sandpiper and Ferruginous Duck) to the five recorded during VP counts. This also includes 26 Ukraine Red Book species and adds five Ukraine Red Book species (Black Stork, Gadwall, Glossy Ibis, Kentish Plover and Squacco Heron) to the list of 29 recorded during vantage point surveys.

No species were recorded migrating over site in internationally or nationally significant numbers and compared to species and overall numbers of birds found within the three IBAs in vicinity of the proposed wind farm, numbers were not of regional significance.

5.2.2 Breeding

136 species were considered as confirmed (46), probably (36) or possibly (54) breeding on or in the vicinity of site during 2018. Species include six IUCN Red List species (Common Pochard, Ferruginous Duck, Meadow Pipit, Northern Lapwing, Red-footed Falcon and Turtle Dove) and 26 Ukraine Red Book species (Black-headed Bunting, Black-winged Stilt, Caspian Tern, Collared Pratincole, Gadwall, Glossy Ibis, Great Black-headed Gull, Kentish Plover, Lesser Short-toed Lark, Long-legged Buzzard, Montagu's Harrier, Oystercatcher, Red-crested Pochard, Roller, Ruddy Shelduck, Slender-billed Gull and Stock Dove).

Although there is a high variety of breeding or potentially breeding birds within and in the vicinity of the proposed wind farm site, only Calandra Lark can be considered as being abundant on site. None of the breeding or potentially breeding birds of conservation concern are present in significant numbers and the habitats used by the majority of the species are common all along the Syvash coast, to the west of site and into Crimea.

5.2.3 Autumn Migration

A total of 77 bird species were recorded during the 2018 autumn VP surveys with; one species listed as IUCN Red List Endangered (Saker Falcon); eight species (Black-tailed Godwit, Common Pochard, Eurasian Curlew, Northern Lapwing, Pallid Harrier, Red-breasted Goose, Red-footed Falcon and Turtle Dove) listed as Near Threatened or Vulnerable on the IUCN Red List and 29 species in the Ukraine Red Book of threatened species. Regular movements of flocks of up to 2160 Common Crane (a Ukraine Red Book species) were recorded flying over site in the early morning and late afternoons during October and early November and Mediterranean Gull, Mallard, Caspian Gull, Ruff, Greater White- fronted Goose, Northern Lapwing (IUCN Near Threatened) and Eurasian Teal have predicted collisions of over one bird per annum.

A total of 189 bird species were recorded during the autumn peak count surveys. 121 of these are considered to be target species and this included one IUCN Red List Endangered species (Saker Falcon), nine IUCN Red List Status Near Threatened or Vulnerable species (Black-tailed Godwit, Common Pochard, Curlew Sandpiper, Ferruginous Duck, Great Snipe, Meadow Pipit, Northern Lapwing, Red- footed Falcon and Turtle Dove) and 28 Ukraine Red Book species (Avocet, Black Kite, Black-headed

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Bunting, Black-winged Stilt, Caspian Tern, Collared Pratincole, Common Crane, Demoiselle Crane, Eurasian Curlew, Ferruginous Duck, Gadwall, Glossy Ibis, Great Snipe, Hen Harrier, Kentish Plover, Lesser Short-toed Lark, Long-legged Buzzard, Montagu’s Harrier, Oystercatcher, Red Crested Pochard, Ringed Plover, Roller, Ruddy Shelduck, Saker Falcon, Short-toed Eagle, Slender-billed Gull, Stock Dove and White-tailed Eagle). Large gatherings of passerine species, such as Barn Swallow, Sand Martin, Starlings, wagtails, pipits and larks, were recorded on site during the surveys and these attracted a variety of raptor species in higher numbers than previously recorded. A possible roost location of Common Crane within the VP1 / VP2 viewsheds has also been identified by the Ukraine Society for the Protection of Birds (USPB).

No species were recorded migrating over site in internationally or nationally significant numbers, although the regular movements of flocks of Common Crane, Mediterranean Gull, Mallard, Caspian Gull, Ruff, Greater White-fronted Goose, Northern Lapwing and Eurasian Teal over site have resulted in predicted collisions of over one bird per annum. Compared to species and overall numbers of birds found within the three IBAs in vicinity of the proposed wind farm, numbers were not of regional significance.

5.2.4 Winter

No specific winter bird surveys were completed in 2018 but wintering bird activity was recorded during the spring migration setup visit completed in March 2018 and previous survey work on and around the project site had been completed during the winter. The potential impacts on wintering birds has been assessed using this information with additional bird survey effort proposed for winter 2019/20 used to update appropriate end of construction and operational phase mitigation and monitoring.

Based on existing data, no significant negative impacts on wintering birds as a result of the project have been identified. Large numbers of wintering birds do occur in the region, particularly geese and waders, and sizeable flocks of Great White-fronted Goose and Ruff have been noted on and over site. The IUCN Vulnerable Red-breasted Goose has also been recorded over site during the winter months and internationally important numbers occur within IBAs in the vicinity of site.

5.3 Mitigation

Surveys have shown that migrating birds, including sizeable flocks of Common Crane, Greater White- fronted Goose and Ruff, occur over all parts of the proposed wind farm site but in general the highest numbers of birds and species are associated with wetland areas, such as the lakes within the VP6 and VP5 viewsheds and marshes and reedbeds within the VP1 and VP2 viewsheds. The marshes and reedbeds are also of highest importance for breeding birds, including nesting waders within the marshes in VP1 and VP2 viewsheds and harriers and herons within the reedbeds. Notable colonies of nesting terns and gulls also occur on islands in the bay but these locations are not in close proximity to proposed turbines and unlikely to be disturbed.

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Construction impacts will include habitat loss and possible nest destruction for passerine and ground nesting bird species as well as disturbance impacts in the Project and adjacent areas. The majority of turbines will be sited outside of habitats of local ornithological importance (such as freshwater and saline areas, wet grassland and field margins) and extensive suitable habitat for breeding, feeding and roosting birds will remain undisturbed and available for birds during the construction period.

Although no significant impacts of construction activities on birds are predicted, the following mitigation measures will be put in place during the construction period: • Habitats suitable for nesting birds that are being lost to construction activity should be removed outside of the breeding bird season (March to August) and if this is not possible this should be removed after a check has been completed by the on-site ecologist to ensure that breeding birds are not directly affected by construction. Suitable habitats include trees and scrub, dense wet grassland and field margin vegetation and also arable fields where ground-nesting species such as Calandra Lark occur. • Appropriate measures will also need to be put in place to ensure actively nesting birds aren’t disturbed significantly enough to cause nests to be abandoned. The main areas where particularly sensitive nesting species (such as ground nesting waders) are likely to occur include the marshes, edges of reedbeds and wet grassland. Ideally, turbine and access construction works should not occur between April and August inclusive within or immediately adjacent to habitats that support sensitive nesting species. Areas of works that could cause significant disturbance will be highlighted/confirmed during the April site visit and from further monitoring by the Project Ecologist but are likely to include WTGs 9, 11, 16, 17, 21, 23, 25 and turbines and access tracks around freshwater lakes within VP6 viewshed. • Where appropriate, screening fencing can be erected around works areas to prevent disturbance to the main areas of breeding, feeding or roosting birds from human and machine movements. • Mitigation to reduce the magnitude of indirect construction impacts (e.g. pollution) are fully detailed in the Habitats section above and will prevent significant impacts on wetland areas and the bird populations they support.

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6 HERPETOFAUNA

6.1 General

Reptile and amphibian walkover surveys were completed as part of the University study in 2017 and as well as incidental sightings during other ecological surveys they registered three species of amphibian and seven species of reptile. Single observations of Caspian Whipsnake and Eastern Steppe Viper were recorded and both these species are included in the Ukraine Red Data Book.

Three other species of reptiles were assessed as part of the University ESIA as although they weren’t recorded, survey effort was not sufficient enough to rule out their presence on site given that they are known to occur in the biogeographical area of Project and therefore could be affected by the Project. Two of the reptile species that weren’t recorded during survey but could occur on site, Blotched Snake and Smooth Snake, are included in the Ukraine Red Data Book.

No specific additional herpetofauna surveys were completed during 2018 but incidental sightings were noted during Turnstone Ecology site visits in May and July 2018 and by surveyors completing bird and bat surveys within the Project site. Further assessment of habitats and their suitability to support snake species of conservation concern has also been completed.

Eastern Steppe Vipers have been recorded on a number of occasions by the bird surveyors completing spring migration surveys in April and May 2018. A minimum of three observations were made with two records in meadow habitat at the far western end of the Project site and one in meadow habitat adjacent to VP2. No other reptiles have been recorded during 2018 but amphibians (European Common Spadefoot and Marsh Frog) were common in freshwater wetland habitats.

6.2 Evaluation

Although no additional reptile and amphibian surveys have been completed during 2018, the results of the 2017 surveys and incidental sightings obtained during other ecological surveys undertaken in 2018 suggest that the Project site only supports small numbers of species of conservation concern.

The majority of proposed WTGs and access routes will affect cultivated arable fields or heavily grazed and disturbed meadow and steppe habitats, which are of limited suitability for amphibians and reptiles. Actual habitat loss will be also be minimal with extensive areas of meadow and steppe habitat remaining unaffected and suitable for reptiles and freshwater wetlands remaining suitable for amphibians.

6.3 Mitigation

Habitat assessment and incidental sighting of herpetofauna completed during 2018 have confirmed that terrestrial habitat directly impacted by construction are considered to be of low conservation value and populations of notable reptile and amphibian species are low. However, it is possible that herpetofauna

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of conservation significance could occur within and or commute across areas affected by the Project and includes four species of snake (high sensitivity) as well as lizards and three species of amphibians (moderate sensitivity). Taking in to consideration the extent of the proposed works, unmitigated impacts are considered to be of a moderate magnitude which would result in a high to moderate negative impact on herpetofauna.

The final locations of WTG and associated access routes will mainly avoid habitats that have been identified as being of highest sensitivity for fauna species. This includes freshwater wetlands, wet meadows and less disturbed uncultivated areas of meadow and steppe vegetation. Habitat supporting species of conservation concern, such as Eastern Steppe Viper, will be largely avoided with extensive suitable habitat remaining unaffected. This will ensure that negative impacts on herpetofauna are kept to a minimum and of low significance.

Pre-construction mitigation works to avoid and/or minimise the loss, death or injury to sensitive species of herpetofauna will be completed. This will include: • pre-works identification of habitats/areas where herpetofauna could be present and affected by proposals and subsequent surveys by a Project Ecologist for notable species; • watching briefs of excavation works in areas deemed suitable for sensitive species of fauna; and • where appropriate the translocation of species and/or re-creation of habitats completed.

Construction is timed to start in early 2019 / during the winter period and as such areas that could support hibernating herpetofauna, including Steppe Viper, will need to be avoided until a period of mild weather likely to be early Spring 2019, or if this is not possible completion of pre-construction walk-over checks should be carried out. A pre-construction walk-over survey will be completed by the Project Ecologist in all winter 2018 – 2019 construction zones and habitats or habitat features identified by the Ecologist that could be suitable for hibernating herpetofauna will be clearly marked and will be protected from construction activities until animals are likely to be active. The tracks around site and agricultural fields affected by the proposals are unlikely to support hibernating herpetofauna but habitats where they could occur includes rocky outcrops, stone piles and former small animal burrows or holes. Habitats identified as being suitable hibernation habitats will be removed under supervision of the Project Ecologist when herpetofauna are likely to be active.

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7 INVERTEBRATES

7.1 General

No specific invertebrate surveys have been completed during any of ecological work undertaken as part of the proposed project. Impacts on invertebrates as a result of the construction and operation of wind farms are not usually considered significant due to the relatively small areas of habitat loss and disturbance.

Incidental observations of general invertebrate diversity and abundance was noted during site visits completed by Turnstone Ecology in May and July 2018.

7.2 Evaluation

The proposed WTG locations and associated access routes will mainly affect cultivated arable habitats and heavily grazed and disturbed meadow and steppe. Less disturbed areas of meadow and steppe, including vegetated strips around the margins of arable fields and adjacent to existing tracks, do support an abundance of invertebrates, although a high species diversity was not observed during 2018 surveys.

Based on geographical range and habitats present on site there is the potential for the IUCN Endangered Crimean Stone Grasshopper (Asiotmethis tauricus) to be present within the Project site. This species is found in steppe habitats and although this habitat is limited and fragmented on site it may be present. The Endangered Thick Grasshopper (Platypygius crassus) inhabits saltings on wet bare ground with scarce halophytic vegetation along sea coasts and therefore could occur in saline habitats adjacent to the Project site.

7.3 Mitigation

Overall habitat loss as a result of the proposed WTGs and associated access routes will be minimal with extensive areas of meadow and steppe habitat remaining unaffected and suitable for a variety of invertebrates. It is also possible that invertebrates of conservation significance could occur within habitats affected by the proposals. Taking in to consideration the extent of the proposed works, unmitigated impacts are considered to be of a moderate magnitude which would result in a moderate negative impact on invertebrates.

The final locations of WTG and associated access routes will mainly avoid habitats that have been identified as being of highest sensitivity for invertebrates. This includes freshwater wetlands, wet meadows and less disturbed uncultivated areas of meadow and steppe vegetation. Habitat supporting species of conservation concern, such as Crimean Stone Grasshopper, will be largely avoided with extensive suitable habitat remaining unaffected. This will ensure that negative impacts on herpetofauna are kept to a minimum and of low significance.

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Pre-construction mitigation works to avoid and/or minimise the loss, death or injury to sensitive species of herpetofauna will be completed. This will include: • pre-works identification of habitats/areas where notable invertebrate species could be present and affected by proposals and subsequent surveys by a Project Ecologist for notable species; • watching briefs of excavation works in areas deemed suitable for sensitive species of invertebrates; and • where appropriate the translocation of species and/or re-creation of habitats completed.

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8 MITIGATION AND MONITORING TIMINGS

8.1 Summary of Mitigation and Monitoring

The table below summarises what pre and during construction mitigation and monitoring is required and when.

Table 1. Summary of proposed mitigation and monitoring and timings

Mitigation and Monitoring Timings / Responsibility Habitats / All areas of sensitive habitats and/or where Setup visit late March/early Flora notable species occur that are not being affected April 2019 with TE by construction activities will be clearly marked Ecologist and Project on the construction plans and will be marked on Ecologist confirming site to prevent construction activities in these locations of sensitive areas. areas. Project Ecologist to mark out areas / confirm sensitive locations with construction team Supervision of any works that are required in close Project Ecologist at relevant proximity to these sensitive habitats. times throughout construction period Pre-works surveys will be targeted to specific Setup visit late March/early areas where sensitive species are known to be April 2019 with TE present based on existing survey data and Ecologist and Project mapping. Certain plants could be difficult to Ecologist confirming detect during the winter months so where data and locations of sensitive species. mapping suggests sensitive plants species could be Project Ecologist to complete present, they will be presumed present and further detailed pre-works translocation and/or recreation of wider areas survey and mark out areas / completed where necessary. confirm locations of sensitive Pre-construction mitigation works to avoid and/or species with construction minimise the loss of sensitive species of flora will team. be completed. This will include: Methods / locations of • Pre-works surveys for sensitive plant translocation to be confirmed species that could be present in areas during setup visit. affected by construction works associated with WTGs and access roads during construction • Where appropriate, the translocation of species and/or recreation of habitats completed.

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Mitigation and Monitoring Timings / Responsibility Enforcement of pollution control measures to Setup visit late March/early protect habitats, notably wetland areas: April 2019 with TE • All fuel and lubricants will be stored in Ecologist and Project double bunded storage containers and Ecologist confirming areas at dedicated re-fuelling areas will be significant risk from maintained. pollution. • Spill kits will be available at all storage Construction team to adhere and re-fuelling sites and all spillages will to their pollution control be cleaned up immediately. measures with Project • Any incidents will be reported and Ecologist ensuring measures investigated, and additional control are in place and used / measures implemented as necessary. working during construction • All vehicles being used on the site will be period. well maintained and subject to regular service and maintenance. Alien and/or invasive plant species are not Responsibility of currently frequent in habitats within or adjacent to construction team with the Project site. Vehicles and any materials being monitoring of procedures and brought onto site will therefore need to checked works areas by Project for the presence of alien or invasive species prior Ecologist during construction to arriving on site to ensure none are introduced period. into habitats within and adjacent to the Project site. If alien or invasive species are found to be present within the Project area during the construction and operational phases of the development then these will be eradicated using appropriate methods. There will be no collecting of plant species within Project Ecologist to monitor the Project site and the remaining shelter belt trees site during the construction protected from felling and/or collection of fire phase and immediately report wood by construction workers. any unauthorised actions It will not be permissible to set fire to trees and/or negatively affecting habitats. steppe and meadow habitats during the construction and operation phases of the Project. The site will maintain excellent housekeeping Responsibility of practices to ensure that all refuse and other waste construction team with materials are disposed of correctly as well as monitoring of procedures and ensuring high levels of recycling is completed. works areas by Project Ecologist during construction period.

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Mitigation and Monitoring Timings / Responsibility Bats During construction, it will be ensured that main Project Manager/construction foraging and/or commuting habitats remain unlit team to confirm types and by artificial lighting associated with works areas. locations of lighting prior to This includes lighting associated with compound works. and storage areas. Project Ecologist to check on lighting during construction phase and instruct on modifications when necessary. Any suitable roosting features in close proximity Pre-works surveys completed (approx. 200m) to turbine construction areas will during visits by Bat be searched by the bat surveyors prior to the start Surveyors. of works. If roosting bats are found to be present Any locations of roosting in a feature, considered to be breeding or confirmed with Project hibernating and at risk of disturbance during Ecologist and TE and where works, then works will be postponed until appropriate construction breeding has finished or the bat/s become active. team instructed to avoid works in certain areas. 2019 bat surveys to be completed April to October Bat surveyors will issue with monthly summaries of results to be provided monthly summaries to TE. If by bat surveyors. any notable changes in bat activity are apparent (such as high numbers using particular flight paths/foraging areas) then additional appropriate construction phase mitigation measures will be passed on to construction team to avoid significant disturbance. Otter Specific mitigation measures for Otter are not Setup visit late March/early required as part of the proposals but in the unlikely April 2019 with TE event of Otter occurring within the vicinity of Ecologist and Project proposed works the required mitigation measures Ecologist confirming to ensure there will be no negative impacts on the locations where Otters could freshwater wetland habitats will also ensure there occur. will be no negative impacts on Otters Project Ecologist to monitor pollution control measures put in place by construction team to ensure no negative impacts on suitable Otter habitat.

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Mitigation and Monitoring Timings / Responsibility Birds Habitats suitable for nesting birds that are being Main nesting bird habitats lost to construction activity should be removed identified/confirmed during outside of the breeding bird season (March to April site visit with August) and if this is not possible this should be additional breeding bird removed after a check has been completed by the surveys and assessment on-site ecologist to ensure that breeding birds are completed by Project not directly affected by construction. Suitable Ecologist. habitats include trees and scrub, dense wet Where appropriate, fencing grassland and field margin vegetation and also or tape used by Project arable fields where ground-nesting species such as Ecologist to mark out Calandra Lark occur. construction-free buffers around active nests. Appropriate measures put in place to ensure Areas of works that could actively nesting birds aren’t disturbed significantly cause significant disturbance enough to cause nests to be abandoned. Ideally, will be highlighted / turbine and access construction works should not confirmed during the April occur between April and August inclusive within site visit and from further or immediately adjacent to habitats that support monitoring by the Project sensitive nesting species, such as WTGs 9, 11, 16, Ecologist 17, 21, 23, 25 and turbines and access tracks around freshwater lakes within VP6 viewshed Where appropriate, screening fencing can be TE and Project Ecologist to erected around works areas to prevent disturbance highlight / confirm to to the main areas of breeding, feeding or roosting construction team areas birds from human and machine movements. where screening would be appropriate. Herpetofauna Pre-construction mitigation works to avoid and/or Setup visit late March/early minimise the loss, death or injury to sensitive April 2019 with TE species of herpetofauna will be completed. This Ecologist and Project will include: Ecologist confirming • Pre-works identification of habitats/areas locations where herpetofauna where herpetofauna could be present and species could occur, affected by proposals and subsequent particularly the notable surveys by a Project Ecologist for notable species. species. Project Ecologist to mark out • Avoidance of features/areas suitable for areas / confirm hibernation / hibernating species. sensitive locations with • Watching briefs of excavation works in construction team and areas deemed suitable for sensitive species complete watching briefs of of fauna. works when appropriate. Project Ecologist to complete translocation of any species

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Mitigation and Monitoring Timings / Responsibility • Where appropriate, the translocation of to suitable habitat away from species and/or re-creation of habitats works when necessary. completed. Habitat re-creation / enhancement to be confirmed on completion of construction works. Invertebrates Pre-construction mitigation works to avoid and/or Setup visit late March/early minimise the loss, death or injury to sensitive April 2019 with TE species of herpetofauna will be completed. This Ecologist and Project will include: Ecologist confirming • Pre-works identification of habitats/areas potential locations of notable where notable invertebrate species could species. be present and affected by proposals and Project Ecologist to complete subsequent surveys by a Project Ecologist additional surveys to confirm for notable species. presence / absence of notable • Watching briefs of excavation works in species and undertake areas deemed suitable for sensitive species watching briefs of works of invertebrates. where necessary. • Where appropriate, the translocation of Project Ecologist to complete species and/or re-creation of habitats translocation of any species completed to suitable habitat away from works when necessary.

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Syvash Wind Farm - Environmental and Social Management Plan

Bat Survey Protocol

6.18.09074.GLA.R.002 Revision B6 Page 81 of 81 Certified to ISO 9001, ISO 14001, OHSAS 18001 and ISO17025

2019 Bat Survey Protocol Syvash Wind Farm

Prepared for Wood.

March 2019

2019 BAT SURVEY PROTOCOL

TURNSTONE ECOLOGY

Project Number TT2386

Title Syvash Wind Farm, Ukraine

Document Number TT2386-R05-2019 Bat Survey Protocol-Rev00

Client Wood.

Issue Date March 2019

Prepared by: Tristan Evans Director 13/03/2019

Checked and Approved For Issue by: Stephen Wilson Director 13/03/2019

This report has been prepared by Turnstone Ecology Limited, with all reasonable skill, care and diligence within the terms of the Contract with the client.

We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above.

This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their own risk.

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Table of Contents

1 Introduction ...... 4 1.1 General ...... 4 1.2 Previous Surveys ...... 4 1.3 Predicted Impacts ...... 5 1.4 Proposed Mitigation ...... 5 2 Bat Survey Methods - 2019 ...... 7 2.1 General ...... 7 2.2 Transect surveys ...... 7 2.3 Static Detector Surveys ...... 9 2.4 Roost Search ...... 9 3 Data management and Analysis...... 10 3.1 Data Management ...... 10 3.2 Data Analysis ...... 10 4 Appendix A – Transect Maps and Static Locations ...... 12

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1 INTRODUCTION

1.1 General

The purpose of this document is to outline the methods proposed for during-construction bat surveys at the proposed Syvash Wind Farm, Kherson Oblast, Ukraine.

Previous bat surveys have not been completed during an entire bat active season (April to September inclusive) so the main aim of the 2019 surveys is to achieve this survey effort. Surveys will include transect surveys following similar protocol to those completed in 2018 and the use of static bat detectors that will be deployed in a higher number of locations than in 2018.

The data collected during 2019 will be analised and assessed and used to further inform and confirm mitigation and monitoring during the operational phase of the proposed wind farm (WF).

1.2 Previous Surveys

Bats do regularly occur within the project area, with up to 13 species of bat recorded commuting and foraging over the three months of 2018 transect surveys and four months of static detector surveys. Minimal roosting activity was recorded and potential roosting sites are limited to a very small number of structures.

Transect surveys have shown the species most frequently recorded was Pipistrellus kuhlii/P. nathusii, which accounted for approximately a third of all recordings. These bats were most frequently encountered on Transects 1 and 5, which is as would be expected based on habitat types present within these areas. Assessment by transect point has shown that areas near to freshwater wetlands and villages were used more than those in saline habitats and arable farmland locations.

Recorded bat activity on transects was highest in August, with approximately double the recordings when compared with June. Increases in activity during this month could be accounted for with the emergence of young bats from nursery colonies, as well as the early movements of migrating species - highlighted in particular by the increase in numbers of Nyctalus species and Vespertillio murinus which are known to migrate between breeding and hibernation sites in this region. This correlates with the results from previous surveys at the site which also showed higher levels of activity in August than in other months.

At risk species were encountered on average between 9.05 times and 17.8 times per transect per visit. This represents what would be considered a typical level of activity for a site with the habitat types present.

The species most frequently recorded during the static detector surveys were Pipistrellus kuhlii (596 passes) and Nyctalus noctula (546 passes), which account for 27% and 25% respectively of all recorded

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2019 BAT SURVEY PROTOCOL passes, or 52% of passes when combined. The months with highest activity were May and June however equipment failure in July and August limited the amount of data collected over these two months meaning direct comparison between transect and static results across the whole season is not possible.

1.3 Predicted Impacts

The results of the 2018 bat surveys are in line with the results of previous surveys completed for the Project with levels of bat activity within the Project area generally low with a slight increase in numbers during August. Species specific predicted impacts are therefore as stated within the EsIA and repeated below.

Construction - High sensitivity bat species could be indirectly affected through noise disturbance and or lighting impacts along commuting routes and or of foraging areas. Indirect negative impacts on bats are considered to be of moderate to high significance.

Operation - The WTGs will be constructed in areas of habitat that are considered sub-optimal for foraging and commuting however it is still possible that bats could be negatively affected by the operational WTGs within 200m of optimal habitats, resulting in low to moderate magnitude impacts on receptors of moderate to high sensitivity. Unmitigated this would result in negative impacts of moderate to high significance.

1.4 Proposed Mitigation

In line with recommendations set out in Eurobats Publication Series no. 6 WTGs should be located away from sensitive areas shown to be used more frequently by bats. The majority of WTGs are located at least 200m from areas of freshwater and village outskirts, where most bat activity has been recorded and WTG micrositing has further increased distances from freshwater habitats. Some WTGs will be within 200m of freshwater, at the western and eastern ends of the Project site, but extensive suitable habitat will be unaffected by WTGs and main foraging and commuting routes between village roost sites and freshwater will be retained and unsevered.

Mortality of bats with the operational WTGs will be reduced as a result of locating the majority of WTGs away from habitat features that could support foraging and commuting and retaining extensive suitable habitat that will be unaffected by WTGs.

Additional (2019) bat surveys to be completed in order to develop continued mitigation packages to further reduce impacts on receptors of high sensitivity. The additional surveys will include the continuation of bat activity surveys (transects and static detectors) throughout construction. Survey visits will be completed monthly during the main bat active season (April to September inclusive) and patterns in activity analysed and mapped to allow amendments to the overall mitigation strategy to be made, including a carcass searching programme.

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This document provides full details of the proposed 2019 survey methodology and analysis.

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2 BAT SURVEY METHODS - 2019

2.1 General

2019 bat surveys and data collection will use: • Bat transect surveys • Static detector surveys • Roost searches

Surveyors to be engaged will be bat experts with good experience in field work and bat surveys for wind farms in particular. Ideally, they will also have been involved in previous surveys for the Syvash WF.

2.2 Transect surveys

Transect Surveys will attempt to identify the potential ecological function of the WF area for foraging/commuting/migrating bats and highlight any important habitats types, such as typical linear landscape features including shelter belts, areas with more vegetation, wet areas and streams/ditches.

Five transects were selected and surveyed during the 2018 bat breeding season (June to August inclusive). Difficulties with access, weather conditions and length of some of the transects meant the original recommendation of completing four surveys of each transect during a 10 day trip was not achievable so two surveys of each transect were completed during each trip.

Surveys during 2019 will cover the entire main bat active season (April to September (inclusive) and based on the results of previous survey effort and survey constraints the 2019 surveys will follow the methods detailed below. • Transect survey trips will be completed once a month from early April to late September • During every monthly trip, each transect route will be subject to the following: o a dusk survey (from sunset until the completion of the transect in one direction) o midnight survey (completed immediately after the dusk survey and in the opposite direction, lasting until the completion of the transect in that direction) o a dawn transect (starting as early as needed to complete the route in one direction by sunrise). • Surveys will be undertaken in weather conditions favouring bat activity: wind speeds below 5 m/s, ideally no rain (although short showers are acceptable) nor fog. If unforecasted unfavourable weather conditions occur during the transects, surveys will be paused and restarted if conditions improve. After an hour of poor weather please check weather forecasts for possible improving conditions prior to cancelling surveys. • Basic weather conditions will be measured or assessed (temperature and wind speed clouds, wind direction, precipitation) and noted during all the surveys along with significant changes in these conditions during the survey, as well as other relevant conditions (e.g. vegetation phenophase, insect abundance, human activity)

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• When conditions allow, the transects will be slowly driven with regular stops of 5 minutes to record bat activity at or close to proposed turbines locations and/or habitats of potential importance to bats. • If conditions prevent driving along some of the tracks, then these will be walked with 5 minutes stops omitted and if there’s no time to complete full transects then surveys will concentrate on transect sections of highest importance for bats i.e. adjacent to waterbodies and/or tree-lines. • Stop locations to be numbered according to adjacent turbine numbers. • Recommended additional stops away from turbine locations are shown as coloured dots along the transects. These should be numbered using the nearest turbine number as a reference, i.e. 13b if the stop is closest to Turbine 13, shown on survey maps and used for all survey trips. • Some sections of the transects will likely need to be walked due to ground conditions and these are shown as the darker lines on the maps. • All constraints associated with survey methods must be fully reported at the end of each trip.

• Bat activity along transects will be registered by acoustic detection of their ultrasound signals (echolocation and social calls) using a hand-held detector (e.g. Pettersson D240x - with time expansion and heterodyne systems), aided by visual observation using a hand-held lamp to improve species identification and counts (RODRIGUES et al. 2015, HUNDT ed. 2012). • Preliminary species identification, the number of individuals, time, duration, location, flight height and direction (when possible) and observed behaviour will be recorded for each detected bat pass (contact). • The entire bat activity during where it will not definitely leave the audio-visual range of the surveyor will be regarded as a single pass/contact so that the number of contacts would represent the number of the individuals present as realistically as possible, at least in a shorter time interval. • The flight height will not be systematically recorded (only in those cases in which it will be deemed important) because it would merely represent the limited audio-visual range of the surveyor and the specifics of certain species' ultrasound signals and not the actual heights at which the individuals of those species fly. While assessing the possible impacts of the wind farm developments on bats, survey data on flight heights gathered visually along the transect, is best used in conjunction with the relevant findings on flight heights and flight characteristics of specific bat species gathered through systematic research. • The registered bat ultrasound signals will be recorded using a digital audio recorder and later analysed using a specialized software BatSound 4.03 (© Pettersson Elektronik AB), appropriate literature (RUSSO & JONES 2002, PFALZER & KUSCH 2003, OBRIST et al. 2004, PAPADATOU et al. 2008, BOONMAN et al. 2009, LIMPENS 2010 etc.) and the comparative collection of recordings owned by the Consultant. Automated identification of bat echolocation calls (i.e. software classifiers) will not be extensively used due to available program's inherent shortcomings and their lack of samples from this region but may be used to filter out some common species that are known to occur and samples are available.

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Transect routes have been identified based on current turbine layout, access for driven and walked transect and known habitats of possible importance for bats with transect maps shown in Appendix A.

2.3 Static Detector Surveys

Two static bat detectors will be made available for the entire survey period, setup ready for recording during the April site visit and regularly moved around site until October. The methodology for methods for deployment and data management is detailed below. • Eight safe locations have been identified where static detectors can be left (see maps in Appendix A). Six of these safe locations will be selected to be used during the survey period. • If additional/improved safe locations are identified during the April setup visit, ideally as close to the main turbine areas as possible, then these will be confirmed with the surveyors and maps amended accordingly. • Static detector locations will be within or very close to proposed turbine areas and/or close to habitats of potential importance for foraging bats. • At the start and end of each bat Survey site visit, data will be downloaded off memory cards in static detectors and batteries replaced (4 D cell batteries). • Following downloading of data and battery replacement, static detectors will then moved to another location and left in place. • • By using the two static detectors and the changing locations at the start and end of the monthly site visits it will mean that a detector will be deployed at each static location four times during the survey period for an appropriate length of time on each deployment.

2.4 Roost Search

Roost searches of suitable roosting features within and adjacent to site during the 2018 surveys with bat roosting confirmed within a bridge over the water channel in the vicinity of VP4 and presumed roosting in and around the nearby villages. Additional roost searches will be completed in 2019 and involve checks of the bridges over the channel that runs along the southern edges of VP3, VP4, VP5 and VP6 viewsheds. • The survey area of the Roost Search is defined as the area within and up to 200 m from the area of wind turbines. • All structures and features having potential to support roosting bats shall be identified and assessed with a detailed visual daytime inspection of potential roost sites for evidence of roosting completed. • If high potential roost sites cannot be fully inspected (due to the inaccessibility of the potentially suitable spaces, e.g. cracks, cervices, holes) and presence/absence of roosting bats not confirmed during the Roost Search, emergence and/or re-entry surveys should be undertaken.

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3 DATA MANAGEMENT AND ANALYSIS

3.1 Data Management

Transect survey data will be analised and assessed by the field surveyors after each monthly survey visit with a summary of results issued to Turnstone Ecology prior to the next months survey visit. Any issues with survey methods will also be reported prior to the next survey visit.

Static data from both of the static bat detectors will be downloaded by the field surveyors during every monthly visit and then issued to Turnstone Ecology on a monthly basis. Details of the best methods of transferring the data will be confirmed on the survey setup visit in April.

Any information on new and/or confirmed bat roosting locations will be provided with the monthly issuing of the transect survey data/summary of results.

3.2 Data Analysis

On completion of the surveys, all transect and static data and monthly result summaries will be analised and assessed by Turnstone Ecology. This analysis and assessment will then be used to further inform and confirm operational mitigation and monitoring.

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4 APPENDIX A – TRANSECT MAPS AND STATIC LOCATIONS

Transect 1 – Red route

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Transect 2 – Blue Route

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Transect 3 – Black Route

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Transect 4 – Green Route

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Transect 5a – Orange Route

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Transect 5b – Red Route

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