ERM Environmental Resources Management SRL ESIA REPORT

Bucharest 21 Constantin Daniel Street, Building A, Sector 1, 010631 Wind Farm Bucharest Constanta County, Romania T: +40 (0) 31 405 1680 F: +40 (0) 31 405 1681 E: [email protected] http://www.erm.com Environmental and Social

Impact Assessment Report for:

Chirnogeni Wind Farm 80 MW

August 2011

Administrators/Board Peter Temesvary Prepared for: Dr. Walter Heinz Martin Gundert

EP WIND PROJECT (ROM) SIX SRL 16 Albinelor Street, Chirnogeni Commune Nr. de ordine în registrul comertului: Constanţa County J40/11533/14.06.2007

Romania Codul de Înregistrare Fiscală (C.I.F.) RO21931265

Please remit to UniCredit Ţiriac Bank, Branch Rosetti, Bucuresti RON account: IBAN RO14 BACX 0000 0001 3825 3001 EUR account: IBAN RO84 BACX 0000 0001 3825 3002 SWIFT: BACXROBU

PROJECT NO. 0093210 Member of the Environmental Resources Management Group

ERM Environmental Resources Management SRL

This report has been prepared by ERM Environmental Resources Management S.R.L. (ERM) with all reasonable skill, care and diligence within the terms of the Contract with the client, incorporating Environmental Resources Management’s General Terms and Conditions of Business and taking account of the manpower and resources devoted to it by agreement with the client.

ERM Environmental Resources Management S.R.L. Bucharest, August 2011

Peter Temesvary Dana Afrenie Managing Partner Senior Consultant

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CONTENTS

CONTENTS 3

1 GENERAL INFORMATION 18

1.1 INTRODUCTION. PURPOSE AND APPROACH 18 1.1.1 Introduction 18 1.1.2 Purpose of this document 18 1.1.3 Scope and approach 19 1.1.4 Evaluation of Significance 20 1.1.5 Cumulative Impacts 22

1.2 INTERNATIONAL AND NATIONAL AGREEMENTS ON CLIMATE CHANGE 22 1.2.1 Kyoto Protocol 22 1.2.2 European Climate Change Programme (ECCP) 23 1.2.3 EU Renewable Energy Directive 23 1.2.4 Romania Renewable Energy Targets 23 1.2.5 Romania Action Plan for Climate Change 24

1.3 NATIONAL LEGISLATION ON ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT 25

1.4 INTERNATIONAL BEST PRACTICE 39

1.5 SCOPING AND CONSULTATION 41 1.5.1 Introduction 41 1.5.2 Technical Scope 43 1.5.3 Temporal Scope 43 1.5.4 Spatial Scope of the ESIA 44 1.5.5 Mitigation and Management 44 1.5.6 Public Consultation and Disclosure 45

1.6 STRUCTURE OF THE ENVIRONMENTAL REPORT 46

1.7 INFORMATION ON THE PROJECT DEVELOPER 48

1.8 INFORMATION ON THE CERTIFIED AUTHOR OF THE ESIA REPORT 49

1.9 PROJECT NAME 50

1.10 PROJECT DESCRIPTION 50

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1.10.1 Information on production 51 1.10.2 Information on the raw materials, chemical substances or compounds 51 1.10.3 Information on the physical and biological pollution resulting from the activity 51

1.11 SCHEDULE FOR CONSTRUCTION AND OPERATION 51

1.12 DESCRIPTION OF THE MAIN ALTERNATIVES STUDIED BY THE DEVELOPER 52

1.13 DESCRIPTION OF THE SITE 54 1.13.1 Identification and address, local topography 54 1.13.2 Information on the existing documents / regulations regarding the land planning / land use in the area of the project site 56 1.13.3 History of the site 57 1.13.4 Information on the proposed means of connection to existing infrastructure 57

2 TECHNOLOGICAL PROCESSES 58

2.1 TECHNOLOGICAL PRODUCTION PROCESSES 58 2.1.1 Overview of the Project Components 58 2.1.2 Access Roads 58 2.1.3 Turbines 59 2.1.4 Foundations 61 2.1.5 80 MW Project Substation 20/110 kV 61 2.1.6 Existing Chirnogeni Substation 110/20 kV 63 2.1.7 Underground Electrical Cables 63 2.1.8 Underground Transmission Lines 64 2.1.9 Construction Management 64

2.2 DECOMMISSIONING ACTIVITIES 68

3 WASTE AND CHEMICALS 70

3.1 WASTE 70 3.1.1 Waste generation 70 3.1.2 Waste management 70

3.2 TOXIC AND DANGEROUS CHEMICALS 71

4 SOILS, GEOLOGY AND WATER RESOURCES 73

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4.1 INTRODUCTION AND SCOPE 73

4.2 METHODOLOGY 73

4.3 BASELINE ENVIRONMENT 74 4.3.1 Topography 74 4.3.2 Soils 74 4.3.3 Geology 75 4.3.4 Seismicity 78 4.3.5 Groundwater 79 4.3.6 Surface Water 81

4.4 CONSTRUCTION IMPACTS 82 4.4.1 Assessment of Impacts to Soils 82 4.4.2 Assessment of Impacts to Groundwater 84 4.4.3 Assessment of Impacts to Surface Water and Drainage Patterns 85

4.5 OPERATIONAL IMPACTS 86 4.5.1 Assessment of Impacts to Soils 86 4.5.2 Assessment of Impacts to Groundwater 86 4.5.3 Assessment of Impacts to Run-Off Rates and Drainage Patterns 87 4.5.4 Assessment associated with Natural Hazards 88 4.5.5 Assessment of geotechnical aspects 89

5 AIR QUALITY 91

5.1 INTRODUCTION AND SCOPE 91

5.2 SOURCES OF INFORMATION 91

5.3 METHODOLOGY 91 5.3.1 Assessment Methodology 91

5.4 BASELINE ENVIRONMENT 92 5.4.1 Surrounding Environment 92 5.4.2 Climate 92 5.4.3 Ambient Air Quality 95

5.5 CONSTRUCTION IMPACTS 97 5.5.1 Introduction 97

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5.5.2 Dust from Construction Traffic 97 5.5.3 Combustion Emissions from Traffic 99 5.5.4 Dust Mitigation 100

5.6 OPERATIONAL IMPACTS 100 5.6.1 Potential Impacts 100 5.6.2 Mitigation 101

5.7 REDUCING THE IMPACTS OF OTHER ENERGY PRODUCTION 101 5.7.1 Avoidance of Emissions 101 5.7.2 Impact Assessment 102

6 NOISE AND VIBRATION 103

6.1 INTRODUCTION AND SCOPE 103

6.2 METHODOLOGY 103 6.2.1 Noise Standards 103 6.2.2 Evaluation of Impact Significance 104 6.2.3 Operational Noise Prediction Model 109

6.3 BASELINE ENVIRONMENT 110

6.4 CONSTRUCTION IMPACTS 112 6.4.1 Potential Impacts 112

6.5 OPERATIONAL IMPACTS 113 6.5.1 Potential Impacts from Wind Turbine Noise 113 6.5.2 Results of Wind Turbine Noise Predictions 115 6.5.3 Operational Vibration and Low Frequency Noise / Infrasound 119 6.5.4 Results of Road Traffic Noise Assessment 120

6.6 MITIGATION 120 6.6.1 Mitigation during Construction 120

6.7 ASSESSMENT OF RESIDUAL IMPACTS 120

6.8 SUMMARY 121

7 TRAFFIC AND TRANSPORT 122

7.1 INTRODUCTION AND SCOPE 122

7.2 METHODOLOGY 122

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7.2.1 Sources of Information 122 7.2.2 Assessment Methodology 122

7.3 CONSTRUCTION ACCESS ROUTE 124 7.3.1 Introduction 124 7.3.2 Baseline Traffic Flows 125

7.4 CONSTRUCTION IMPACTS 127 7.4.1 Introduction 127 7.4.2 Potential Impacts 129 7.4.3 Mitigation 130 7.4.4 Residual Impacts 132

7.5 OPERATIONAL IMPACTS 132

8 ECOLOGY AND NATURE CONSERVATION 133

8.1 INTRODUCTION AND SCOPE 133

8.2 METHODOLOGY 134 8.2.1 Sources of Information 134 8.2.2 Assessment Methodology 136

8.3 ECOLOGICAL BASELINE ENVIRONMENT 138 8.3.1 Protected Areas 138 8.3.2 Habitat Context 141 8.3.3 Flora 144 8.3.4 Terrestrial Fauna within the Project Footprint 150 8.3.5 Bats 153 8.3.6 Birds 156 8.3.7 Further Survey 161

8.4 CONSTRUCTION IMPACTS 162 8.4.1 Introduction 162 8.4.2 Habitats 162 8.4.3 Flora 162 8.4.4 Fauna 163

8.5 PERMANENT AND OPERATIONAL IMPACTS 164

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8.5.1 Introduction 164 8.5.2 Habitat 164 8.5.3 .Fauna 165

9 LANDSCAPE AND VISUAL IMPACTS 170

9.1 LANDSCAPE AND VISUAL IMPACTS 170 9.1.1 Introduction 170 9.1.2 Policy Context 173 9.1.3 Assessment Methodology and Significance Criteria 173 9.1.4 ZVI and Photomontage Methods 175 9.1.5 Prediction and Evaluation of Landscape and Visual Impacts 177 9.1.6 Baseline – Visual Amenity 184 9.1.7 Baseline - Existing Landscape Character and Landscape Designations 185 9.1.8 Potential Significant Impacts 191 9.1.9 Mitigation Measures 191 9.1.10 Measures to Mitigate Impacts during Construction and Decommissioning 192 9.1.11 Assessment of Residual Construction and Other Short Term Impacts 193 9.1.12 Sources of Impact 193 9.1.13 Residual Impacts during Construction 193 9.1.14 Other Short Term Residual Impacts During Operation 194 9.1.15 Long Term Impacts on the Landscape 194 9.1.16 Long Term Visual Impacts 197 9.1.17 Impacts during decommissioning 204

9.1.18 Special requirements of RCAA() 204

10 SOCIAL AND ECONOMIC ENVIRONMENT 207

10.1 INTRODUCTION AND SCOPE 207

10.2 SOURCES OF INFORMATION 207

10.3 AREA OF INFLUENCE AND BOUNDARIES 209

10.4 SOCIOECONOMIC BASELINE 210 10.4.1 Local Context 210 10.4.2 Demography 211

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10.4.3 Religion 212 10.4.4 Languages 212 10.4.5 Housing 213 10.4.6 Infrastructure 215 10.4.7 Education 216 10.4.8 Employment 217 10.4.9 Unemployment 220 10.4.10 Poverty 221 10.4.11 Health 222 10.4.12 Land Use and Property 225 10.4.13 Recreation and Community Facilities 229 10.4.14 Archaeology and Cultural Heritage 229

10.5 IMPACT METHODOLOGY 236 10.5.1 Evaluation of Significance 237 10.5.2 Mitigation and Management 239

10.6 CONSTRUCTION IMPACTS 239 10.6.1 Introduction 239 10.6.2 Impacts to Land Use 239 10.6.3 Employment: Direct, Indirect and Induced 242 10.6.4 Impacts on Housing 246 10.6.5 Impact on Livelihoods 248 10.6.6 Impacts on Health 250 10.6.7 Impacts on Infrastructure 253 10.6.8 Impacts on Archaeology and Cultural Practices 256

10.7 OPERATIONAL IMPACTS 258 10.7.1 Introduction 258 10.7.2 Impacts on Land Use 258 10.7.3 Revenue Generation for Local Government 260 10.7.4 Operational Employment 262 10.7.5 Impacts on Livelihoods 264 10.7.6 Impacts on Health 266

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10.7.7 Impacts on Infrastructure 268 10.7.8 Impacts on Archaeology and Cultural Practices 268

11 OTHER OPERATIONAL IMPACTS 270

11.1 INTRODUCTION AND SCOPE 270

11.2 ELECTROMAGNETIC INTERFERENCE (EMI) 270 11.2.1 Introduction 270 11.2.2 Assessment of Impacts 272

11.3 SHADOW FLICKER 274 11.3.1 Introduction 274 11.3.2 Assessment of Impacts 275

11.4 ICE THROW 276 11.4.1 Introduction 276 11.4.2 Assessment of Impacts 276

12 CUMULATIVE IMPACT ASSESSMENT 278

12.1 CUMULATIVE LANDSCAPE AND VISUAL IMPACTS 278 12.1.1 Introduction 278 12.1.2 Residual cumulative effects on landscape character 280 12.1.3 Residual Cumulative Effects on Views and Visual Amenity 283 12.1.4 Assessment of Residual Combined and Successive Visual Impacts 284

12.2 ASSESSMENT OF CUMULATIVE IMPACTS ON FLORA AND FAUNA 287 12.2.1 Introduction 287 12.2.2 Description of Projects considered for the scope of the cumulative assessment 288 12.2.3 Cumulative Impacts on Bats 290 12.2.4 Cumulative Impacts on Migratory Birds 292 12.2.5 Cumulative Impacts on Protected Areas 293 12.2.6 Conclusion 294

13 ENVIRONMENTAL AND SOCIAL MITIGATION PLAN (ESMP) 295

13.1 INTRODUCTION 295

13.2 EP GLOBAL ENERGY 295

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13.3 PURPOSE OF THE ENVIRONMENTAL AND SOCIAL MITIGATION PLAN (ESMP) 297

13.4 ROLES, RESPONSIBILITIES AND REPORTING 297 13.4.1 EPGE’s role during construction and operation 297 13.4.2 Contractors’ role during construction and operation 298

13.5 TRAINING 298

13.6 INSPECTION AND AUDITING 299

13.7 CONTINGENCY PLANNING FOR EMERGENCIES AND ENVIRONMENTAL INCIDENTS 299

13.8 ONGOING STAKEHOLDER ENGAGEMENT 300

13.9 GRIEVANCE PROCEDURE 301

13.10 ENVIRONMENTAL AND SOCIAL MITIGATION PLAN 301

13.11 OUTSTANDING ACTIONS 313

14 REQUIREMENTS STIPULATED BY OTHER REGULATORY ACTS 314

14.1 SITE APPROVALS BY ENEL 315

14.2 APPROVAL OF THE ZONING URBAN PLAN BY THE ROMANIAN NATIONAL LAND IMPROVEMENT ADMINISTRATION 316

14.3 APPROVAL OF THE ZONING URBAN PLAN BY THE ROMANIAN MINISTRY OF NATIONAL DEFENCE 317

14.4 APPROVAL FROM THE COUNTY WATER SUPPLY OPERATOR REGIA AUTONOMA JUDETEANA DE APA (RAJA) – AREAL CENTRE 318

14.5 APPROVAL FROM THE TELECOMMUNICATION OPERATOR ROMTELECOM 318

14.6 APPROVAL FROM THE ROMANIAN NATIONAL GAS TRANSPORT COMPANY TRANSGAZ 319

14.7 ADDITIONAL AUTHORITIES APPROACHED DURING THE ZONING URBAN PLAN APPROVAL PROCESS 320

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Correlation of the chapters included in this ESIA with the standard content of the EIA Report as stipulated in the Ministerial Order 863/2002 on the approval of the methodological guidelines for the stages of the EIA framework procedure

Standard content of the EIA Report Reference to the chapters in this ESIA according to Romanian legislation (O.M. (according to Equator Principles) 863/2002) CHAPTER 1 – GENERAL CHAPTER 1 INFORMATION

Introduction. Purpose and approach Section 1.1

Information on the project developer Section 1.1 and 1.7

Information on the certified author of Section 1.8 EIA Report

Project name Section 1.9

Project description Section 1.10

Information on production Section 1.10.1

Information on the raw materials, chemical Section 1.10.2 substances or compounds

Information on the physical and biological Section 1.10.3 pollution resulting from the activity

Other types of physical or biological Not applicable pollution

Schedule for construction and operation Section 1.11

Description of the main alternatives Section 1.12 studied by the developer

Description of the site Section 1.13

Identification and address, local Section 1.13.1 topography

Information on the existent Section 1.13.2 documents/regulations regarding the land planning/land use in the site area of the project

History of the site Section 1.13.3

Information on the proposed means of Section 1.13.4 connection to existing infrastructure

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Standard content of the EIA Report Reference to the chapters in this ESIA according to Romanian legislation (O.M. (according to Equator Principles) 863/2002) Main access to the site Section 1.13.4 Water supply Section 1.13.4 Electricity supply Section 1.13.4 Gas supply Section 1.13.4

CHAPTER 2 – TECHNOLOGICAL CHAPTER 2 PROCESSES

Production Technological Processes Section 2.1

Description of the proposed technological Sections 2.1.1 to 2.1.8 processes, the necessary techniques and equipment; alternatives considered.

Limit values achieved using the techniques Not applicable proposed by the developer and BATs

Decommissioning Activities Section 2.2

CHAPTER 3 - WASTE AND CHAPTER 3 CHEMICALS

Waste Section 3.1

Waste generation Section 3.1.1

Waste management Section 3.1.2

Waste disposal and recycling Section 3.1.2

Toxic and dangerous chemicals Section 3.2

General data Section 3.2

Chemicals management Section 3.2

Applicability of Seveso Directive Section 3.2

CHAPTER 4 - POTENTIAL IMPACTS, CHAPTER 12 INCLUDING THE TRANSBOUNDARY IMPACT, ON THE ENVIRONMENTAL COMPONENTS AND MEASURES TO REDUCE IT

WATER CHAPTER 4

Hydro-geological conditions of the site Section 4.3.5

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Standard content of the EIA Report Reference to the chapters in this ESIA according to Romanian legislation (O.M. (according to Equator Principles) 863/2002)

Water supply and water use Sections 1.13.4 and 2.1.9

Wastewater management Not applicable

Wastewater sources Not applicable

Wastewater pre-treatment/treatment Not applicable plants

Potential impacts Section 4.4.2, 4.4.3, 4.5.2, 4.5.3 Mitigation measures Section 4.4.2, 4.4.3, 4.5.2, 4.5.3

AIR CHAPTER 5

General data Sections 5.4

Climate and meteorological conditions of Section 5.4.2 the site

Ambient air quality in the site area Section 0

Sources of pollution and pollutants Section 5.5.2, 5.5.3 released

Potential impacts Sections 0, 5.6, 5.7

Mitigation measures Sections 5.6.2, 5.5.4

NOISE AND VIBRATION CHAPTER 6

Sources of noise and vibration Section 6.1

Noise and vibration levels at the site Section 6.3 boundary and the nearest protected receptor

Potential impacts Sections 6.4, 6.5, 6.7

Mitigation measures Section 6.6

SOIL AND SUBSOIL CHAPTER 4

Characterization Section 4.3.1

Soil Section 4.3.2

Soil geology Section 4.3.3

Soil and subsoil pollution sources Section 4.4.1

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Standard content of the EIA Report Reference to the chapters in this ESIA according to Romanian legislation (O.M. (according to Equator Principles) 863/2002)

Potential impacts Section 4.4.1

Mitigation measures Section 4.4.1

BIODIVERSITY CHAPTER 8

Characterization Section 8.3

Information on the local and regional flora Sections 8.3.2, 8.3.3, 8.3.4, 8.3.5, 8.3.6 and fauna

Designated protected areas Section 8.3.1

Potential impacts Sections 0, 8.5

Mitigation measures Section 8.3.7, 0, 8.5

LANDSCAPE CHAPTER 9

Characterization Section 9.1.6

Geomorphological, topographical and Section 9.1.7 hydrological features

Land Use Section 9.1.7, 10.4.12

Land improvement in the area Not applicable

Potential impacts Sections 9.1.8, 9.1.11, 9.1.12, 9.1.13, 9.1.14, 9.1.15, 9.1.16, 9.1.17, 9.1.18

Mitigation measures Sections 9.1.9, 9.1.10, 9.1.18

SOCIAL AND ECONOMIC CHAPTER 10 ENVIRONMENT

Characterization Section 10.4

Demographical data Section 10.4.2

Economical features Sections 10.4.5 - 10.4.11

Cultural and ethnic conditions, cultural Section 10.4.14 heritage

Potential impacts Sections 0, 10.6, 10.7

Mitigation measures Sections 10.6, 10.7

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Standard content of the EIA Report Reference to the chapters in this ESIA according to Romanian legislation (O.M. (according to Equator Principles) 863/2002)

CHAPTER 5 – ANALYSIS OF CHAPTER 1 ALTERNATIVES

Site Selection Section 1.12

Technological alternatives Section 1.12

CHAPTER 6 – MONITORING CHAPTER 13

Monitoring emissions into air Section 13.10

Noise monitoring Section 13.10

Water monitoring Not applicable

Waste monitoring Section 12.4.2

Chemicals monitoring Not applicable

Training of personnel 13.5

CHAPTER 7 – HAZARD SITUATIONS CHAPTER 4

Natural hazards Chapter 4

Seismic risk Section 4.3.4

Flooding risk Section 4.3.6

Geotechnical risk Section 4.5.5

Emergency Response Plan Not applicable

Fire hazard Not applicable

Explosion risk Not applicable

CHAPTER 8 – DESCRIPTION OF NOT APPLICABLE DIFFICULTIES

CHAPTER 9 – NON-TECHNICAL DOCUMENT WITHOUT CHAPTER SUMMARY NUMBER IN THE BEGINNING OF General data THE ESIA REPORT

Technological processes

Potential environmental impacts

Impacts to water

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Standard content of the EIA Report Reference to the chapters in this ESIA according to Romanian legislation (O.M. (according to Equator Principles) 863/2002)

Impacts to air

Impacts to soil and subsoil

Impacts to biodiversity

Impacts to landscape

Impacts to the social and environmental environment

Conclusions of the ESIA

CHAPTER 10 - ANNEXES List of annexes at the end of the Report

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1 GENERAL INFORMATION

1.1 INTRODUCTION. PURPOSE AND APPROACH

1.1.1 Introduction

EP Global Energy (EPGE), the ultimate parent company of EP Wind Project (ROM) SIX SRL (hereafter referred to as EPWP6 - the Project Beneficiary) is proposing to develop a wind farm project with a total capacity of 80 MW called Chirnogeni Wind Farm (80 MW) (“the Project”). It will be located in Movila Verde and Chirnogeni Villages, Commune of Independenţa and Commune of Chinogeni respectively, County of Constanţa, southeast Romania. The site location is provided in Annex 1 – Site Location Map.

The spatial planning documentation for the approval of Zonal Urban Plan has been carried out by SC Arhico Consulting SRL, Constanţa, 141 Mircea cel Batran Street, block MS1, entrance A, apartment 12P.

The estimated value of work is approximately €128 million, of which approximately 1% is reserved for environmental protection works.

1.1.2 Purpose of this document

The purpose of an Environmental and Social Impact Assessment (ESIA) is to identify the environmental and social changes that will or may occur as a result of a project (its impacts and risks), to evaluate their significance (i.e. their importance) and, where significant, adverse impacts are identified, to determine whether there are measures that can be taken to avoid, reduce or compensate for those impacts (mitigation measures). Where the developer is content that mitigation can be incorporated into the proposals this is taken into account in a final assessment of the impacts of the project and these are reported, together with a description of the project and the planned mitigation, in the Environmental and Social Impact Report.

The information in the Environmental and Social Impact Report is then intended to be used by those responsible for making decisions about the project (for example regulatory authorities or lenders), to help decide whether it should go ahead or that finance could be provided for it and, if it is to go ahead, under what conditions.

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1.1.3 Scope and approach

The assessment examines impacts on social and environmental receptors and resources, that is, people (e.g. residents, workers, visitors) and physical, natural and cultural resources (e.g. soils and land, protected habitats and species, and historic sites) arising as a consequence of the development. It will address a variety of different types of impacts including:

• beneficial (positive) and adverse (negative) impacts; • impacts arising permanently as a consequence of the development of the site (e.g. loss of existing land uses), temporarily during the construction period (e.g. noise from earthmoving), and over the long term during the operation of the facility (e.g. visual impacts on nearby residents); • primary and secondary impacts arising as the consequences of sequences of cause and effect in the environment; • impacts arising directly from the project or indirectly as a consequence of other changes stimulated by the project (e.g. from an influx of population); and • impacts arising in combination across the project and cumulatively with other changes taking place in the locality at the same time.

Table 1.1 Types of Environmental and Social Impact

Positive impacts: effects that have a beneficial influence on receptors and resources Negative impacts: effects that have an adverse influence on receptors or resources. Permanent impacts: effects that result from an irreversible change to the baseline environment (e.g. loss of features caused by land take) Temporary or short term impacts: effects that persist for a limited period only, due for example to particular construction activities (e.g. noise from construction plant). The duration of these effects is identified Long term impacts: effects that will continue over a long period, for example during operation of a plant, but that will cease on closure of the plant (e.g. emissions from manufacturing processes) Primary impacts: effects that result immediately from project actions such as emissions, land take, etc Secondary and higher order impacts: effects that occur as a result of primary effects, for example, impacts on ecosystems can be caused by changes in air quality resulting from project emissions Direct impacts: effects that arise from activities that form an integral part of the project Indirect impacts: effects that arise from activities that are not part of the project but which are stimulated by it (e.g. sewage pollution caused by people moving into the area to work on the project)

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Combined impacts: effects that arise from the combination of different effects on specific resource or receptor e.g. noise, dust and traffic congestion all affecting the same group of residents Cumulative impacts: where the project is taking place at the same time as other developments and they have cumulative effects on the same receptors and resources

Impacts are assessed by comparing the baseline conditions (i.e. the situation without the project) with the conditions that will prevail if the project is constructed and operated.

There are therefore four key stages in the assessment:

1. Identifying the baseline conditions without the project and the sensitivity and importance of the receptors and resources at risk. 2. Predicting the magnitude of impact on these receptors and resources, including the nature, scale, extent and duration of change, and in the case of non-routine impacts, their probability or frequency of occurrence. 3. Evaluating the significance of impacts so that decision-makers understand the weight that should be given to them in reaching decisions about the Project. 4. Investigating options for mitigation of significant adverse impacts and agreeing measures to be incorporated into the project proposals with the proponent.

1.1.4 Evaluation of Significance

As noted above, where significant adverse effects are identified by an Environmental and Social Impact Assessment (ESIA), options for mitigation should be considered and if these are feasible, taken into account in identifying the final or residual impacts of the project. The significance of an impact will depend on its predicted magnitude (scale, extent and duration), and on the value or importance of the affected receptors or resources. This is shown in Figure 1.1 below.

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Figure 1.1 Matrix for the Evaluation of Significance

Magnitude of Change Low Medium High

Negligible

Minor

Moderate Importance of Receptor/Resource of Importance

Major High Medium Low

The importance of receptors will depend on the numbers of people affected and their vulnerability, so for example residents will be more vulnerable to noise than employees who are only present during working hours. The importance of environmental resources will depend on their local, national or international value and will take into account any protective designations. An impact will be of major significance if it causes any legal standards to be breached.

The criteria for evaluation of significance take account of local, national and international standards, norms and good practice, and vary according to the type of impact. The details in each case are presented and discussed in the relevant chapters which follow.

Where significant adverse impacts remain after mitigation, these will need to be taken into account alongside other costs and benefits (such as environmental or social improvements, provision of employment or economic development) by decision-makers, in determining whether the project should go ahead and under what conditions.

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1.1.5 Cumulative Impacts

Cumulative effects may result from various types of interaction:

• a combination of different types of effects at a specific location (which may result from different elements of the project); • a combination of effects of the same type at different locations, which are not necessarily significant individually, but which collectively may constitute a significant effect; • the interaction of different effects over time; and • the cumulative interaction between effects from the proposed development and other existing or planned projects in close proximity. Combination effects and the interaction effects from the different project elements are taken into consideration within the technical scope of this ESIA and are reported where appropriate within each topic chapter.

Other existing developments which may have cumulative impacts within the area of influence for this project are considered and their environmental and social impacts are taken into account in defining the baseline for the assessment. The cumulative effects of these projects with those of the proposed development are therefore incorporated into the assessment. We have identified no other currently planned developments in the vicinity of the site with which could have cumulative impacts in the future.

1.2 INTERNATIONAL AND NATIONAL AGREEMENTS ON CLIMATE CHANGE

1.2.1 Kyoto Protocol

The Kyoto Protocol is a treaty intended to achieve ‘stabilization of greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system’. The Romanian Government ratified the Kyoto Protocol in 2001, and this came into force in Romania in 2005. The Protocol establishes legally binding commitments for member countries for the reduction of four greenhouse gases (carbon dioxide, methane, nitrous oxide, sulfur hexafluoride), and two groups of gases (hydrofluorocarbons and perfluorocarbons) produced by industrialized nations.

As part of its commitment to the Kyoto Protocol, Romania is committed to reducing greenhouse gas (GHG) emissions to 8% between 2008-2012

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compared to 1989 statistics. The energy sector in Romania accounted for 71% of the total GHG emissions in 2004(1).

1.2.2 European Climate Change Programme (ECCP)

The EU established the ECCP in 2000 to help member countries to identify the most environmentally effective and most cost-effective policies and measures that can be taken at European level to cut greenhouse gas emissions. The immediate goal is to help ensure that the EU collectively meets its target for reducing emissions under the Kyoto Protocol(2).

1.2.3 EU Renewable Energy Directive

The Renewables Directive (2001/77/EC) requires each member country to commit to specific targets for renewable energy. The Directive follows on from the European Union White Paper, ‘Energy for the Future: Renewable Sources of Energy 1997’. The promotion of electricity from renewable sources of energy is a high priority in the EU for several reasons in addition to that of combating climate change. These include security and diversification of energy supply, environmental protection, and social and economic development.

In accordance with this Directive, member states are required to adopt national targets for renewables that are consistent with reaching the Commission’s target of 22% of electricity from renewables by 2010.

1.2.4 Romania Renewable Energy Targets

In September 2007, the Romanian Government approved an energy strategy for 2007-2020, with a goal to fully cover the domestic electricity and heating

(1) Romania’s Initial Report under the Kyoto Protocol (Assigned Amount Calculation), Ministry of Environment and Sustainable Development, Romania, May 2007

(2) The European Climate Change Programme, EU Action Against Climate Change, European Commission, 2006

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consumption. Approved by the Romanian Government (GD no. 647/2001), the strategy takes into consideration the energy developments in the European Union, focusing on the following:

• increasing energy efficiency; • boosting renewable energy; • diversifying import sources and transport routes; • modernizing existing lines; and • protecting critical infrastructure. The strategy includes a national renewable energy target of 11% of gross energy to be achieved by 2010. Furthermore Romania plans to increase the renewable share up to 33% of overall power consumption by 2010 (this stood at 29% in 2004). This strategy includes a resolution to install wind power with a total capacity of 120 MW by 2010(3).

At the moment of writing this ESIA (February 2010), no information was publicly available with regard to the achievement of the renewable energy targets set for 2010.

Electricity generated by the Chirnogeni Wind Farm will contribute to the Romania Government goals to boost renewable energy and modernize existing electricity lines, strengthening the renewable energy industry in Romania.

1.2.5 Romania Action Plan for Climate Change

In July 2005, the Government of Romania adopted, by Governmental Decision no. 645/2005, the first National Strategy for Climate Change (NSCC). The strategy aims to limit greenhouse gas emissions and implement measures to adapt to the potential impacts of climate change. An Action Plan has been developed under the coordination of the Ministry of the Environment and Water Management (MEWM) which is the main instrument for

(3) Energy Innovative Financial Network, Romanian Renewable Energy Fact Sheet, January 2007

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implementation. The Action Plan includes an action to promote energy production from renewable sources such as by introducing new financing mechanisms for projects.

1.3 NATIONAL LEGISLATION ON ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT

The Romanian laws concerning the evaluation of environmental impacts for a project and their purpose are listed in Table 1.2 below. The ESIA for this project will be undertaken in accordance with these requirements.

Table 1.2 Relevant National EIA Legislation

Guideline and No./Date Purpose/Scope Legislation/Relevant Plans EIA Procedure Environmental Protection Law Government Emergency Sets up the permitting Ordinance (GEO) no. 164/2008 framework (including EIA). amending GEO no. 195/2005 on environmental protection, approved by Law no. 265/2006, with all subsequent amendments and completions Environmental Impact Order no. 135/2010 Regulates application for and Assessment (EIA) Procedure issuing of the Environmental and Environmental Agreement. Agreements Framework regarding the GD no. 445/2009 Transposes the EU Directive Environmental Impact 85/337/EEC and respectively Assessment procedure for 97/11/EC for EIA, as well as certain public and private Directive 2003/35/EC related projects to public participation and respectively Directives 85/337/EEC and 96/61/EC. Guidelines for EIA Order no. 863/2002 Guidelines for the EIA screening and scoping and review, based on EU Directives edited by the DG Environment. EIA procedure in a Order no. 864/ 2002 Establishes the EIA procedures transboundary context in a transboundary context and those of public participation in decision making regarding projects with transboundary impacts, and the list of projects included in Annex No. 1 of the Convention on transboundary EIA ratified by Law No.

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Guideline and No./Date Purpose/Scope Legislation/Relevant Plans 22/2001

Urban Certificates and Construction Permit

Regulating the urban location Annex no. 2 of County Council Establishes the protection- of wind Farms in Constanţa Decision 249/2008 safety area which needs to be taken into consideration for the elaboration of the application documents for issuing of the construction permit. Landscape and visual impact assessment

Approves the National Land Law no. 5/2000 Defines the protected areas as Arrangement Plan – Section III natural or built areas, within – Protected areas geographical and/or topographical boundaries, which comprise values of natural and/or cultural heritage. These protected areas are designated as such in order to achieve the specific heritage conservation objectives. Establishes the bioshpere GD no. 230/2003 amended by reserves, national and natural GD 1529/2006 parks and sets up their administrations Law by which Romania Law 451/2002 The Convention defines the adopts the European principles and guidelines for Landscape Convention landscape conservation.

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Guideline and No./Date Purpose/Scope Legislation/Relevant Plans Ecology Nature Conservation- flora, fauna (bats, ornithology)

Regulating the regime of Law 462/2001 for the approval Transposing the European protected natural areas, of Government Emergency Directive 92/43/EEC, conservation of natural Ordinance no. 236/2001, Annexes II and IV, and habitats, wild flora and fauna amended and completed by Council Directive 79/409/EEC (and establishes the GEO 57/2007 on the Conservation of Birds management categories of the protected areas according to the IUCN(4)). Regulating the protection of Law 90/2000 Ratifying the Agreement on bats species conservation of bats in Europe, adopted in London in 1991 Treaty aiming to conserve Law no. 13/1998 Adopting the Convention on terrestrial, marine and avian Conservation of Migratory migratory species throughout Species of Wild Animals, their range adopted in Bonn in 1979 Regulating the designation of GD no. 1284/ 2007 - special avifaunistic protection areas as integrant part of the European Natura 2000 network in Romania Regulating the designation of Order no. 1964/ 2007 - sites of community importance as protected natural areas forming an integrant part of the European Natura 2000 network in Romania Approving the content for the Order no. 207/ 2006 - Natura 2000 Standard Form and the guidelines for its completion Archaeology

Regulating the protection of Government Ordinance (GO) - the archaeological heritage no. 43/2000 approved by Law and designation of certain no. 378/ 2001, republished in archaeological sites as areas of the Official Journal dated 24

(4) International Union for Conservation of Nature

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Guideline and No./Date Purpose/Scope Legislation/Relevant Plans national interest, republished; Nov. 2006

Approving the List of areas Order of the Culture Ministry - having a prioritary no. 2483/2006 archaeologic interest Regulating the protection of Law no. 150/1997 Ratifying the European archaeological heritage Convention on the protection of archaeological heritage, adopted at La Valetta on 16 January 1992 Air emission; Noise

Guideline regarding the Order no. 678/ 2006 Establishes the methods for methods of calculation of the performing the calculation of noise indicators from the noise indicators from industrial activities industrial activities. Guideline for adoption of limit Order no. 152/ 2008 Established the Guideline values and how to implement regarding the adoption of limit them when prepare action values and how to implement plans for indicators L_den and them when prepare action L_night plans for indicators L_den and L_night, where the noise of traffic on major roads and congestion, rail traffic on major railways and in congestion, traffic Air airports large and/or urban and noise in areas of congestion where industrial activities listed in Annex. 1 to Government Emergency Ordinance no. 152/2005 on integrated prevention and control of pollution, approved with amendments and completions by Law no. 84/2006 Amends and completes GD Government Decision no. 674/ Establishes the general no. 321/2005 on the 2007 framework for the assessment and management development of measures to of the environmental noise reduce noise emitted by major sources of noise, especially road vehicles, rail and infrastructure, the aircraft, industrial equipment, equipment intended for use outside buildings and mobile industrial machinery.

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Guideline and No./Date Purpose/Scope Legislation/Relevant Plans Regulations for the noise limit Standard 10009-88 Establishes the limit values of values the environmental noise.

Soil and groundwater protection

Regulations for the approval Law 575/ 2001 Establishes the natural hazard of the national spatial plan- zones which are defined as natural risk zones geographic areas within which there is a potential production of destructive natural phenomena, which may affect the population, human activities, natural environment and built and can cause damage and human casualties Norms and standards to be taken into account for constructing the wind farm

Wind Turbines Design SR EN 61400-2:2006 Specifications

Amends and completes the Order no. 49/ 2007 issued by Establishes the protection and Technical standard on the the National Energy safety area for related delimitation of the protection Regulatory Authority components of the wind farm and security areas for the and designated distance to the power/ electrical plants or neighbours. units Traffic and transport

Amends and completes the Ordonance no. 79/ 2001 Establishes the types of the Ordinance no. 43/1997 on the vehicles which can travel on regime of roads public roads. Regulating the types of Order no. 355/ 2010 Establishes the categories of vehicles allowed on public roads on which heavy duty roads transport vehicles are allowed to travel. Approves the lists of public roads including the maximum admitted mass and sizes for heavy duty vehicles

Table 1.3 and Figure 1.2 below describe the main regulatory steps of the Romanian EIA Procedure. This ESIA Report will be submitted to banks and financial institutions which the developer will approach to obtain necessary funding for the project. A separate EIA Report conducted to Romanian standards and legislation has been prepared by S.C. AS ORIMEX NEW S.R.L. and submitted to the LEPA Constanta (the competent authority to sustain the EIA legal procedure) on July 27, 2011.

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ERM reviewed this EIA report in July 2011 and concluded:

• caution regarding the robustness of this assessment is required taking into account that no information was available on the methodology used; • the assessment did not lead to additional conclusions compared to the ESIA prepared by ERM; • monitoring of dust and noise during construction as well as air humidity and noise during the operation of the wind farm was recommended; • further survey work was recommended to monitor bird collision during the operation of the wind farm; • no mitigation measures were identified as necessary to be enforced. LEPA Constanta will analyse the documentation and will make a decision based on the findings and assessments of the EIA Report. This procedure is aimed to obtain the Environmental Agreement for the project and is detailed within the Stakeholder Engagement Plan (SEP).

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Figure 1.2 Regulatory steps of the Romanian EIA procedure

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Table 1.3 Steps of the Romanian EIA Procedure for obtaining the Environmental Agreement

Step Description Timeline for Estimated Competent time (for Authority as steps not defined in defined in legislation legislation)

Preparation and Submittal of Preparation and submittal of the Notification and Urban Certificate for 15 working Application file and initial assessment Construction. Time frame based on the assumption that Urban Certificate days by Local Environmental Protection for Construction, landownership certificate or the right to use the land Agency (LEPA) document and Basic Design of the project development have been obtained. To be submitted by the Project Developer Note: 1. The land ownership certificate is listed as a document required for the issuance of the Environmental Agreement pursuant to the applicable legislation (GD no. 445/2009 and MO no. 135/2010). However, the relevant legislation does not expressly require for the applicant to be the owner of the land on which the project shall be developed. Nonetheless, the developer has to prove its right to use the plot of land on which the project shall be developed. 2. The Urban Certificate for Construction defines all approvals needed to obtain the Construction Permit. The EIA Procedure can be initiated only after the Urban Certificate (for Construction) is issued since it is needed for

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Step Description Timeline for Estimated Competent time (for Authority as steps not defined in defined in legislation legislation)

the above mentioned application. Initial assessment by LEPA and site visit; 10 days after receiving the Decision regarding the start of the EIA procedure including the Notification appropriate assessment procedure;

Preparation and submittal of the Presentation Memorandum (PM); No timeline 30 days defined in Public announcement on the application submittal by the Developer legislation (announcement prepared by LEPA). Screening stage performed by LEPA LEPA will undertake the following actions: within 15 days from reviewing • detailed assessment of all submitted documents; the PM • defining the members of the Technical Analysis Committee (TAC);

• assessment of the potential transboundary impact according to Law

22/2001;

• prepare the checklist for screening, public announcement on website regarding the submittal of the documents for issuing of the environmental agreement;

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Step Description Timeline for Estimated Competent time (for Authority as steps not defined in defined in legislation legislation)

• sending the public announcement template to the Developer

• submittal of the PM to TAC members and communicate the date of the TAC meeting;

• call for First TAC Meeting: present the check list, present the project Within 10 days and take the screening decision. after receiving The developer shall publish the announcement regarding the submittal of the template of the PM. the announcement LEPA and the developer will make the public announcement regarding Within 3 days the screening decision; after the TAC meeting Waiting for public comment to the screening decision 5 days after publishing the announcement LEPA calls the second TAC meeting, assesses public comments and Within 10 days prepares the final screening decision after receiving public comments

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Step Description Timeline for Estimated Competent time (for Authority as steps not defined in defined in legislation legislation)

Scoping stage performed by LEPA LEPA will perform the following actions: within 10 days from • complete the scoping check list and send it to the TAC members; communication of the final • call the third TAC meeting and present the scoping check list; screening • prepare and submit the guideline for the EIA Report to the Developer; decision

• publish the EIA guideline on the website. Preparation and submittal of the EIA Preparation of the EIA according to the defined EIA scope by LEPA and No timeline 70 working by the Developer followed by Consultant accredited by the Ministry of Environment to defined in the days perform the EIA in the respective field of activity. legislation Submittal of the EIA by the Project Developer to the LEPA.

Public consultation procedure initiated After receiving the EIA report, LEPA analyses the document and Within 5 days by the LEPA Constanta establishes the details of the public debate (date and venue) with the after submittal developer. of the EIA report LEPA publishes the EIA report on its official website and provides the template of the public announcement to the developer

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Step Description Timeline for Estimated Competent time (for Authority as steps not defined in defined in legislation legislation)

LEPA and the developer publish the announcement on the public debate At least 20 (date and venue) in the newspaper/own official website. days before the public debate Public debate Following the public debate, LEPA assesses public comments and requests Within 20 days the developer additional information, if applicable. Additionally, LEPA after the public prepares the check list for the EIA report. debate Issue of the Environmental Agreement If applicable, LEPA provides the supplementary information to the TAC Within 10 days by LEPA members and finalizes the check list for the EIA report. after receiving the LEPA calls the forth TAC meeting to make the final decision regarding the supplementary issuing of the Environmental Agreement. information from the developer LEPA undertakes the following actions: Within 15 days after the forth • inform the applicant on the decision made after the forth TAC TAC meeting meeting;

• provide the developer with the template of the public announcement; and

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Step Description Timeline for Estimated Competent time (for Authority as steps not defined in defined in legislation legislation)

• publish the announcement of the decision to issue the Environmental Agreement and provides the draft of this regulatory act. The developer publishes the decision of the LEPA to issue the Within 3 days Environmental Agreement in the newspaper and on its own website. after receiving the template of the public announcement Waiting for public comments on the LEPA decision to issue the Within 5 days Environmental Agreement after the public announcement in the newspaper LEPA issues the Environmental Agreement Within 5 days after the end of the period allocated for public comments

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Step Description Timeline for Estimated Competent time (for Authority as steps not defined in defined in legislation legislation)

LEPA publishes the supplemented EIA report, if applicable, on its own For a period of website for public information 15 days Overall timeline for obtaining the The overall duration of the EIA procedure, including fixed periods defined Environmental Agreement by law and estimated periods (not defined in law) is estimated to be approximately 10 months.

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1.4 INTERNATIONAL BEST PRACTICE

This ESIA is being carried out in accordance with international standards, as reflected in the policies, safeguard procedures, and guidance of the World Bank Group (specifically the IFC Performance Standards which underpin the Equator Principles and the World Bank safeguard policies).

Equator Principles are standards developed by the international finance community for application to the approval of lending for development. They are based on performance standards established by the International Finance Corporation of the World Bank and set rigorous requirements for the approach to and conduct of Environmental and Social Impact Assessments (ESIA). A brief summary of the Equator Principles is presented below.

Table 1.4 The Equator Principles July 2006 – A Summary

Principle 1: Review and Categorisation Projects will be categorised based on the magnitude of potential impacts and risks in accordance with the environmental and social screening criteria of the IFC as:

• Category A – Projects with potential significant adverse social or environmental impacts that are diverse, irreversible or unprecedented;

• Category B – Projects with potential limited adverse social or environmental impacts that are few in number, generally site-specific, largely reversible and readily addressed through mitigation measures; and

• Category C – Projects with minimal or no social or environmental impacts. Principle 2: Social and Environmental Assessment A social and environmental assessment must be carried out for Category A and B projects to address social and environmental impacts and risks and propose mitigation and management measures. Social and Environmental Assessment is defined as “a process that determines the social and environmental impacts and risks (including labour, health and safety) of a proposed project in its area of influence ….[comprising] an adequate, accurate and objective evaluation and presentation of the issues”. Principle 3: Applicable Standards The assessment will refer to IFC Performance Standards and Industry Specific EHS Guidelines and establish overall compliance or justified deviations from these and with host country laws and permits. IFC Performance Standards cover:

• Social and Environmental Assessment and Management Systems

• Labour and Working Conditions

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• Pollution Prevention and Abatement

• Community Health, Safety and Security

• Land Acquisition and Involuntary Resettlement

• Biodiversity Conservation and Sustainable Natural Resource Management

• Indigenous Peoples

• Cultural Heritage. Principle 4: Action Plan and Management System The developer must prepare an Action Plan describing and prioritising actions and monitoring needed to manage impacts and risks and must establish a Social and Environmental Management System to ensure compliance with standards (see Principle 3). Principle 5: Consultation and Disclosure Project-affected communities must be consulted in a structured and culturally appropriate manner to ensure free, prior and informed consultation and facilitate informed participation so that the project adequately incorporates affected communities’ concerns. The assessment documentation must be made available to the public for a reasonable minimum period in the relevant local language and in a culturally appropriate manner and the developer must take account of and document the process and results including any actions agreed resulting from the consultation. For projects with significant adverse impacts this must take place early in the assessment process and in any event before the project construction starts and on an ongoing basis. Principle 6: Grievance Mechanism The developer must establish a readily accessible grievance mechanism, to continue through construction and operation, so that concerns and grievances can be raised by individuals and groups and are adequately, promptly and transparently addressed. Principle 7: Independent Review An Equator Principles lender must undertake an independent review to assess compliance with these principles. Principle 8: Covenants The developer must covenant with an Equator Principles lender:

• to comply with relevant standards and with the Action Plan

• to report regularly on compliance

• to decommission the facilities where appropriate in accordance with an agreed plan. Where non-compliance occurs the lender may exercise remedies to ensure compliance.

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Principle 9: Independent Monitoring and Reporting An independent monitor must be appointed to undertake ongoing monitoring during the life of the project and report on compliance.

This document is the Environmental and Social Impact Report for the project and reports the findings of an ESIA undertaken by ERM in accordance with the Equator Principles.

Key aspects of the Principles relevant to this assessment are:

• The requirements to undertake social as well as environmental impact assessment– this assessment includes all aspects covered by the IFC Performance Standards referenced in Principle 3. • The requirement to comply with Industry-Specific Guidelines– the relevant guidelines are the IFC Environmental, Health and Safety Guidelines for Wind Energy. • The requirement to prepare an Action Plan and Management System – this Environmental and Social Impact Report includes an Environmental and Social Action Plan setting out all planned mitigation. • The requirement for early consultation and disclosure and ongoing provision for management of grievances – the public and relevant agencies have been consulted during scoping (see Section 1.5) and during the assessment studies. The Environmental and Social Impact Report will be published and an opportunity provided for comment. All comments would be taken into account in further developing and implementing the management system and finalising the Action Plan; and the Management System will include a Grievance Process accessible to all.

1.5 SCOPING AND CONSULTATION

1.5.1 Introduction

The range of impacts to be addressed in an ESIA is determined by Scoping. Scoping involves the systematic consideration of the activities involved in the project and the features of its surrounding environment, in order to identify where impacts may occur. It is key to planning and providing focus for the ESIA.

Effective scoping requires enough information about the project and its baseline environment to identify where interactions may occur. It is also good

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practice to consult with interested parties so that their concerns regarding the impacts of the project are identified and addressed in this ESIA. These may include regulators and other interested agencies, the local community, other potentially affected parties such as land owners and businesses, and non- governmental organisations with an interest in the environment and society.

The environmental assessor started the scoping for this ESIA in February 2009 and a Technical Memorandum (dated July 2009) was produced and agreed with LEPA Constanta according to the legislation in force at that time, to inform the developer about the results of the project screening phase (see Annex 25 – Technical Memorandum). This document includes the project details valid at the moment it was prepared. This incorporated the findings of an initial public consultation. In preparing the Technical Memorandum reference was made to:

• the IFC Performance Standards on Social and Environmental Sustainability which underpin the Equator Principles(5); • the European Commission’s Guidance on EIA Scoping(6); • Ministerial Order (M.O.) no. 860/2002, amended and completed by M.O. 210/2004 and M.O. 1037/2005 regulating the application for and issue of the environmental agreement; and • M.O. no. 863/2002 establishing the guidelines for the EIA screening, scoping and review based on EU Directives edited by Directorate General Environment. Two changes have occurred in the project layout in relation to this Technical Memorandum produced in 2009 namely: • the 110 kV transmission line from the Project Substation to the (existing) Chirnogeni Substation 110/20 kV will be underground instead of overhead. The reasons for choosing the underground transmission line are

(5) http://www.ifc.org/ifcext/enviro.nsf/AttachmentsByTitle/pol_PerformanceStandards2006_full/$FILE/IFC+Performanc e+Standards.pdf

(6) http://ec.europa.eu/environment/eia/eia-guidelines/g-scoping-full-text.pdf

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listed in Section 1.12 - Description Of The Main Alternatives Studied By The Developer. • the access road to the Project site was shifted to the south (approximately 1,200 m at the western end and 600 m at its eastern end) and will no longer follow the route 110 kV underground transmission line; • based on the above-mentioned changes, the total area rezoned from agricultural to ‘industrial use’ is 0.124 km2, instead of 0.085 km2. These two changes have been presented and assessed within this ESIA. The collection process of the baseline sets of data occurred in 2009, when the first version of the ESIA was produced. Taking into account that no such recent data were available, the preparation of this revised version of the ESIA considered the 2009 baseline. However, no significant changes to the baseline data are considered to have occurred in the meantime in order to affect the assessment.

1.5.2 Technical Scope

As a result the scope of the ESIA includes impacts on:

• soil, subsoil and water resources; • air quality; • noise and vibration; • traffic and transport; • ecology and nature conservation; • landscape and visual; • social and economic environment; • electromagnetic interference; • shadow flicker; • ice throw; • cumulative landscape and visual impacts; and • cumulative impacts biodiversity and Narure Conservation.

1.5.3 Temporal Scope

As noted above the assessment covers impacts during construction and operation of the wind farm. It considers permanent impacts arising from development of the project (e.g. loss of environmental resources), short term

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temporary impacts that will occur during construction (e.g. noise and traffic), and long term impacts that will arise during the operation of the facility (e.g. landscape and visual impacts, noise from the turbines etc).

The wind farm is expected to have an operating lifetime of at least 20 years and there are currently no specific plans for its closure or decommissioning.

1.5.4 Spatial Scope of the ESIA

The geographical coverage of the ESIA takes into account the following factors:

• the physical extent of the works to be undertaken within the project site boundary; and • the nature of the baseline environment and the manner in which impacts are likely to be propagated beyond the site boundary. The latter depends on the type of impact: so for example, effects on buried archaeology are likely to be confined to those areas physically disturbed by construction works, whilst effects of noise could extend to neighbours outside the site boundary and visual impacts to residents could impact over long distances. The study area for the ESIA is therefore defined to include all areas potentially affected in each topic under investigation.

1.5.5 Mitigation and Management

A principal objective of ESIA is to identify ways of reducing the impacts of development. The assessment undertaken here has followed an iterative approach. A first assessment was undertaken based on the basic project proposals. Where significant impacts were identified options for avoiding, reducing or compensating for these were identified and discussed with EPGE. Where incorporation of measures into the project was technically and commercially feasible these were then taken into account in a reassessment and the residual effects after mitigation are described in this Environmental and Social Impact Assessment Report.

EPGE is committed to undertaking all the agreed measures and they are set out in an Environmental and Social Mitigation and Management Plan which forms part of this document (see Chapter 12).

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1.5.6 Public Consultation and Disclosure

EPGE is fully committed to an open and consultative approach to development of the project. In accordance with international best practice there has been consultation during the preparation of this ESIA Report and this will continue as the project proceeds to completion of construction and beyond.

For the purposes of this plan, a stakeholder is defined as ‘any individual or group who is potentially affected by a project or can themselves affect a project’. The objective of stakeholder identification is therefore to establish which organizations, groups and individuals may be directly or indirectly affected (positively and negatively) by the project; and who may have an impact or influence on the project. Stakeholder identification is an ongoing process requiring regular review and updates.

To date a diverse range of stakeholders identified in Table 1.5 have been identified for the wind farm project and will be consulted during the ESIA. This list will be updated as additional parties are identified.

Table 1.5 Preliminary List of Key Stakeholders

Group Name Connections to the project Government Constanţa Local National, regional and local government Environmental individuals of primary political Protection Agency importance to the project with permitting Constanţa County requirements that must be met by the Council project. Independenţa Mayoralty and Commune Council Chirnogeni Mayoralty and Commune Council Payment and Intervention Agency for Agriculture based in the Constanţa County Council building Constanţa County Prefect Institution (Representative of the central government at county level) Communities Viroaga Households and communities that will receive impacts (positive or negative) as a result of the project.

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Group Name Connections to the project Chirnogeni Movila Verde Independenţa Negru Vodă Local NGOs, NGO Mare Nostrum Organisations with direct interest in the other (research, project and that are able to influence the media) project directly or through public NGO Oceanic Club opinion. Such organisations may also “Grigore Antipa” have useful data and insight and may be National Museum of able to become partners to the project in Natural History in areas of common interest. Bucharest National History and Archaeology Museum in Constanţa Ecological Cooperation Group Romanian Bats Protection Association Romanian Ornithological Society IFIs and donors Potential financers with requirements for international best practice, with an influence and interest in seeing that project is delivered in compliance with in international best practice.

Preliminary consultation meetings with the local authorities and communities have been undertaken as part of the ESIA procedure, prior to the screening and Scoping stage (see Annex 26 - Minutes of consultation meetings with local government authorities and public).

1.6 STRUCTURE OF THE ENVIRONMENTAL REPORT

The remainder of this Environmental and Social Impact Assessment Report is set out as follows:

• General Information; • Technological Processes; • Waste and Chemicals;

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• Soil, Subsoil and Water Resources; • Air Quality; • Noise and vibrations; • Traffic and transport; • Ecology and Nature Conservation; • Landscape and visual impacts; • Socioeconomics; • Other Operational Impacts; • Cumulative impact assessment; • Environmental and Social Mitigation and Management Plan; and • Requirements stipulated by other regulatory acts. Supporting information is provided in annexes as follows:

• Annex 1 – Site Location Map; • Annex 2 – Site Layout Map; • Annex 3 – Road map in Constanta County; • Annex 4 – Ecology and Nature Conservation; • Annex 5 – Map of Protected Areas; • Annex 6 – 30 km Zone of Visual Influence (100 m to hub) and viewpoint locations; • Annex 7- 30 km Zone of Visual Influence (145 m to tips) and viewpoint locations; • Annex 8 - Land Use Map; • Annex 9 – Local Landscape Character Areas Map; • Annex 10 – Landscape Character in Wider Areas; • Annex 11 – Photomontage for Viewpoint 02; • Annex 12 – Photomontage for Viewpoint 04; • Annex 13 – Photomontage for Viewpoint 05; • Annex 14 – Photomontage for Viewpoint 09; • Annex 15 – Photomontage for Viewpoint 11; • Annex 16 – Photomontage for Viewpoint 12; • Annex 17 – Photomontage for Viewpoint 15;

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• Annex 18 – Photomontage for Viewpoint 18; • Annex 19 – Photomontage for Viewpoint 19; • Annex 20 – Photomontage for Viewpoint 20; • Annex 21 – Photomontage for Viewpoint 24; • Annex 22 – Socioeconomic questionnaire for Chirnogeni Commune; • Annex 23 – Socioeconomic questionnaire for Independenta Commune; • Annex 24 - Location of identified archaeological monuments; • Annex 25 – Technical Memorandum; • Annex 26 – Minutes of consultation meetings with local authorities and public during the scoping stage; • Annex 27 - Zone of visual influence map: Chirnogeni and Deleni combined visibility; • Annex 28 - Zone of visual influence map: Chirnogeni and A combined visibility; • Annex 29 - Zone of visual influence map: Chirnogeni, Deleni and Pecineaga A combined visibility; and • Annex 30 - Cumulative photowirelines. A summary of impacts is provided in the Non-Technical Summary, which is a standalone document, part of the ESIA package which comprises:

• ESIA for Chirnogeni Wind Farm 80 MW - the current document, which was prepared by ERM in 2008-2009, and revised in 2011; • ESIA for High-voltage (“HV”) Transmission Line - supplementary information to the ESIA for Chirnogeni Wind Farm 80 MW, which was produced by ERM in 2011; • a set of standalone documents covering both ESIA reports mentioned above: Environmental and Social Action Plan (ESAP), Stakeholder Engagement Plan (SEP) and Non Technical Summary (NTS).

1.7 INFORMATION ON THE PROJECT DEVELOPER

The investment described above will be made by EP Global Energy (EPGE), which is the ultimate parent company of EP Wind Project (ROM) SIX SRL (EPWP6), part of The Paraskevaides Group. EPGE is a private development company active in the power generation field, with its head office in Cyprus and five regional offices (Cyprus, Greece, Albania, the United Arab Emirates,

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and Romania: Bucharest and Constanţa). EPGE proposes to carry out several development projects in power production in Romania in the near future.

The company’s team consists of specialists with experience in the development and implementation of projects, starting from the phase of pre- planning and marketing to construction and commissioning and operation. Partnerships at the local level are an important element in the company’s strategy, based on long-term relationships developed by The Paraskevaides Group in the past 60 years.

EPGE’s mission is to create a fair value for shareholders by developing a portfolio of investment targets both in the production of renewable energy (power produced from wind, solar or hydro sources) and conventional energy (power produced from natural gas).

In September 2007, the Romanian Government approved an energy strategy for 2007-2020 (G.D. no. 647/2001), with a goal to fully cover the domestic electricity and heating consumption. This strategy takes into consideration the energy developments in the European Union, focusing on the following:

• increasing energy efficiency; • boosting renewable energy; • diversifying import sources and transport routes; • modernizing existing lines; and • protecting critical infrastructure. Electricity generated by the Chirnogeni Wind Farm (80 MW) will contribute to the Romanian Government goals to boost renewable energy and modernize existing electricity lines, strengthening the renewable energy industry in Romania.

In order to achieve its objectives, EPGE established a local development office for EP Wind Project (ROM) SIX SRL (EPWP6) based in Chirnogeni at 16 Albinelor Street. The contact person is the Managing Director of EPWP6, Mr. Ionel David whose contact details are as follows: phone number +40 731 066010, email [email protected].

1.8 INFORMATION ON THE CERTIFIED AUTHOR OF THE ESIA REPORT

This document is an Environmental and Social Impact Assessment Report (ESIA) prepared by ERM Environmental Resources Management SRL (ERM) for a development to be undertaken by EPGE through the project implementation

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company EPWP6. The contact person for ERM is Ms. Dana Afrenie whose contact details are as follows: phone number +40 731 300 155, fax no. +40 31 405 1681, email [email protected].

1.9 PROJECT NAME

As noted above and shown in Annex 2 – Site Layout Map, the objective of the proposed investment comprises the development of a wind farm with a capacity of 80 MW called Chirnogeni Wind Farm (80 MW) (“the project”). The project is to be located on agricultural land approximately 2.4 km to the west of Chirnogeni Village (Chirnogeni Commune) and approximately 5 km to the southeast of Movila Verde Village (Independenţa Commune).

1.10 PROJECT DESCRIPTION

The wind farm will comprise 32 wind turbines each with a capacity of 2.5 MW, a Project Substation 20/110 kV with a capacity of 80 MW and a permanent pole to support a weather station (to be located on plot A 349/1/29).

The main components of the project are listed below and shown in Annex 2– Site Layout Map:

• The Chirnogeni Wind Farm will have a total capacity of 80 MW, (84.2 MVA) and will comprise 32 ‘out-of-step’ NORDEX wind turbines, which each have a Doubly Fed Induction Generator (DFIG) and rated power of 2.5 MW (Un=0.66 kV). • The construction of a permanent concrete foundation at the site of each turbine which will be required for the installation and maintenance of the turbines. • The construction of permanent crane pads. • The upgrade of approximately 13 km of existing exploitation roads to the site and the construction of a permanent network of approximately 12 km of access roads (between the turbines and exploitation roads). • Construction of a Project Substation 20/110 kV with a capacity of 80 MW to be located within the wind farm site boundary. • Installation of a network of underground medium voltage (20 kV) electrical connection lines having a length of approximately 26 km to link the turbines to the Project Substation 20/110 kV (within the wind farm site boundary).

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• Construction and operation of underground transmission lines (110 kV) of approximately 4.47 km from the Project Substation to the (existing) Chirnogeni Substation 110/20 kV which connects to the Power Distribution Grid owned by SC Enel Distribuţie Dobrogea SA (“ENEL”). • The construction of a temporary construction compound within the wind farm site boundary. • Installation of equipment for a new underground transmission line 110 kV switch in the existing Chirnogeni substation in order to enable connection of the wind farm (see Section 2.1.8). Further details about the project components are provided in Section 2.1.1.

1.10.1 Information on production

The Chirnogeni Wind Farm will produce annually 80 MW of wind energy.

The energy generated by the wind farm will be transferred to the point of connection with the Power Distribution Grid (PDG), which is at the (existing) Chirnogeni Substation 110/20 kV. This existing substation is located within the incorporated area of the Chirnogeni Commune, approximately 5.7 km to the east of the wind farm.

1.10.2 Information on the raw materials, chemical substances or compounds

The wind farm will not require any raw materials, chemical substances or compunds for production purposes. It will produce electricity using a renewable source of energy: the wind.

1.10.3 Information on the physical and biological pollution resulting from the activity

The operation of the wind farm will not generate any significant biological and physical pollution of the environment. Any impacts arising during the construction of the proposed project will be assessed and mitigation measures will be discussed during the following chapters.

1.11 SCHEDULE FOR CONSTRUCTION AND OPERATION

Construction of the project is currently planned to commence in the first quarter of 2012 and this phase is anticipated to last approximately 18 months. The operational life of the wind turbines is expected to be at least 20 years.

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1.12 DESCRIPTION OF THE MAIN ALTERNATIVES STUDIED BY THE DEVELOPER

Romania’s wind resources are well documented by numerous expert studies conducted by wind energy institutions and associations. Based on these studies, the highest wind energy potential was identified in eastern Romania, namely Dobrogea region in the south-east and the Moldavian Plateau in the north-east(7).

EPGE started to perform wind measurements for the selection of the 80 MW project site in November 2007. The consultancy company Cube Engineering GmbH (Cube) documented the data and provided support with the installation of a first wind mast in the Chirnogeni 80 MW project site. This mast was 50 m high and was equipped with sensors for the measurement of wind speed, direction, outside temperature and humidity.

In September 2008, EPGE installed a second wind measurement mast in the area in order to select the exact site for the 80 MW Chirnogeni Wind Farm project site. The Wind Hunter mast is 80.9 m high and comprises the following elements:

• sensors to measure wind speed at different heights (e.g. 20 m, 30 m, 59.9 m,. 80.5 m and 80.9 m); • sensors to measure wind direction at two heights: 17.4 m and 78.2 m; • sensor to measure temperature and humidity at a height of 10 m; • solar panel installed at a height of 6 m; and • data logger installed at a height of 3 m. EPGE has chosen the Dobrogea region as area of interest for the development of the wind farm project. The final selection of the site was based on the consideration of the following factors:

• results of the measurement of wind speed and direction performed over a period of 6 months;

(7) Source: EBRD renewables site, http://www.ebrdrenewables.com/sites/renew/countries/Romania/profile.aspx#Wind

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• available grid capacity to allow the distribution of the energy generated by the wind farm into the national power grid; • distance of the site from the nearest residential housing; • distance of the site from the nearest Natura 2000 and protected natural sites (see Annex 5 – Map of protected areas). EPGE approached several turbine manufacturers in order to select the type of turbine to be used for the development of the wind farm project. Nordex and Suzlon were the two most significant turbine vendors which EPGE considered for this project. Nordex was chosen to supply the N90 turbine due to its excellent performance and reliability and the superior power quality that these turbines produce.

As part of the technical documentation required by SC Enel Romania SRL and the National Electric Energy Transportation Company „Transelectrica” SA, in order to issue the Technical Connection Permit, EPGE submitted a two-Phase Solution Study. This Study was produced by the Agency for Maintenance and Energy Services Oradea using consultancy support from the Polytechnical University of Bucharest – Faculty of Energetics.

The Phase I Solution Study examined three technical solutions for the connection of the wind farm to the national power grid, as presented below:

I.a Connection to the Chirnogeni Substation 110/20 kV via 110 kV overhead project transmission line having an approximate length of 5.7 km. I.b Connection to the Chirnogeni Substation 110/20 kV via 110 kV underground project transmission line having an approximate length of 5.7 km. II Connection in the Viroaga Substation 110/20 kV via 110 kV overhead project transmission line having an approximate length of 8 km. EPGE proposed these three options in the Solution Study due to the proximity of the Chirnogeni and Viroaga Substations to the wind farm.

Alternative number I.b was selected. It was considered to be the best option due to the following reasons:

• the alternative of building an overhead transmission line required that approximately 100 land owners has to be approached in order to conclude sell agreements for the necessary plots;

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• in case the above-mentioned plots were obtained from the land owners, the resulting zig-zag overhead transmission line made the utility easements impossible to be grounded; • the Chirnogeni substation was located on the edge of commune closest to the proposed wind farm; • post-construction impacts such as concerns regarding electric and magnetic fields (EMF) are usually less of an issue for underground lines compared to overhead; • underground lines are not visible after construction and have less impact on property values and aesthetics; • underground power lines are also protected from outside elements such as wind and ice, which may knock down overhead transmission lines and poles or cause them to freeze and snap; • going south to Viroaga substation would need to involve an additional commune – Cerchezu Commune; • considering the distance of 8.0 km measured in the Solution Study and the average number of existing parcels in the area of the Movila Verde village (12 parcels per linear km), the selection of option II would have required that additional 27 landowners had be crossed in order to get to the Viroaga connection point.

1.13 DESCRIPTION OF THE SITE

1.13.1 Identification and address, local topography

The project site is located partly within the unincorporated fields of Chirnogeni Commune, approximately 2.4 km to the west of Chirnogeni Village and partly within the unincorporated fields of Independenţa Commune, approximately 5 km north-north-west of Movila Verde Village and 5 km north-west of Independenta Village, in Constanţa County.

Annex 1 – Site location Map shows the location of the villages and communes in close proximity to the project site (see Table 1.6).

Table 1.6 Site Neighbours

Locality Administrative unit of Approximate distance Orientation the locality from the site boundary* Viroaga Cerchezu 3.7 km southwest

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Locality Administrative unit of Approximate distance Orientation the locality from the site boundary* Chirnogeni Chirnogeni 2.4 km east Plopeni Chirnogeni 4 km north Movila Verde Independenţa 5 km north-north- west Independenţa Independenţa 5 km northwest Cerchezu Cerchezu 6.5 km southwest Negru Vodă Negru Vodă 5.7 km southeast Note: distances are measured from the site boundary (safety area) to the closest point of a village/town.

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Figure 1.3 View of the project site as of October 2008

1.13.2 Information on the existing documents / regulations regarding the land planning / land use in the area of the project site

The total project site is approximately 16.9 km2 which includes the project footprint, the wind safety area and a development buffer area. The project footprint also comprises the total area that was rezoned to industrial use, namely 0.124 km2. This area will be occupied by the turbine foundationss, Project substation, permanent crane pads and access roads and represents only 0.73% of the 16.9 km2 project site.

The project site includes privately owned land and public land which belongs to Independenţa and Chirnogeni Communes. According to the Urban Certificate no. 173 dated 29 April 2009 issued by the Constanta County Council, the current land use is agricultural (arable).

The lands where the turbines and the Project Substation 20/110 kV will be located are owned by EPGE and leased by EPWP6.

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1.13.3 History of the site

According to the Urban Certificate no. 173 dated 29 April 2009, the single known use of the land is agricultural (arable).

1.13.4 Information on the proposed means of connection to existing infrastructure

Main access to the site

Site access will be via the National Road DN 38 Constanţa – Mangalia and the County Roads DJ 391 and DN 39 via the commune road Dc 16. Commune roads and existing exploitation roads used during construction will be upgraded and covered with gravel. A network of new access roads located within the project site boundary will be constructed of aggregate materials.

Water supply

Water during construction will be provided via mobile tanks of about 1,000 litres each and will be used by approximately 50 workers for sanitary purposes.

Water resources necessary for the wind farm operation are minimal and will be provided via a mobile tank. The tank will be supplied through a specialized company from Constanta.

Electricity supply

Electricity during construction will be provided via one generator having an output power of 125 kW.

During operation, the energy needed for internal consumption by low voltage electric equipment, SCADA equipment and the Project Substation will be self- sufficient. In situations of wind speed below 3 m/s or exceeding 25 m/s (when the turbines will not be operational), the power required for monitoring, control and data transmission will be supplied via one auxiliary transformer with a voltage of 20/0,4 kV, which will be backed/up by a 125 kW diesel generator.

Gas supply

No gas supply is required during the construction or operation of the project.

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2 TECHNOLOGICAL PROCESSES

2.1 TECHNOLOGICAL PRODUCTION PROCESSES

The kinetic energy in wind can be captured by the blades of wind turbines and transformed into electricity. When the turbine blades capture wind energy they start moving and spin a shaft that leads from the hub of the rotor to a generator which transforms rotational energy into electricity.

Figure 2.1 Diagram of a wind turbine

2.1.1 Overview of the Project Components

Section 1.10 provides an overview of the key project components which are described in more detail below.

2.1.2 Access Roads

The project includes the construction of a network of approximately 12 km of access roads (or tracks) on the Project Site, which will be required both during construction and operation of the project (the latter for maintenance activities).

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The access roads will have an estimated width of 4.5 m and will be constructed from surplus compacted material remaining from the excavation activities, and topped with a layer of compacted crushed natural stones. This structure shall have to undergo a load of 12-15 t /axle and a maximum weight of 140 t.

Additionally, approximately 13 km of 4 m-wide existing exploitation roads will be upgraded and covered with a layer of compacted crushed natural stones.

The standard track design applies for free draining subsoil conditions. It also applies to sections where the soft subsoil does not exceed 1.0 m in depth, in which case the soft layer would be stripped to expose the stratum with the appropriate drainage and bearing capacity. A geotextile membrane would be laid onto the surface to act as a stabiliser, which minimises the volume of the required crushed rock material. Where a rock base exists, the aggregate will be built up directly on that surface. Several layers of crushed rock will be built up and compacted.

Any excavated soil will be stored immediately next to the locations where the access roads will be constructed and will be used as construction material.

2.1.3 Turbines

The 32 Nordex N90 wind turbines that EPWP6 proposes for the Chirnogeni Wind Farm (80 MW) have the following characteristics:

• each turbine will have a production capacity of 2.5 MW, resulting in a total capacity of 80 MW; • turbines will be linked together through a network of underground 20 kV electrical connection cables which will feed to the Project Substation 20/110 kV which will have a capacity of 80 MW;

• the footprint of the base of each turbine will cover approximately 600 m2; • each turbine will comprise the following component parts: electrical generator; a tower consisting of 6 rolled steel sections having an approximate height of 100 m; a nacelle (generator mechanical protection); the hub (to support the turbine blades, which connects with the axle generator) each with a height of 100 m; and

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three turbine blades of glass fibre reinforced with plastic, each with a length of 43.8 m. Each turbine will have a total height (tower +blade) of approximately 144 m, a total weight of approximately 468 tons and an approximate weight of 10.2 tonnes per blade. The colour in which the tower, nacelle and blades will be painted will be defined following consultation with the aviation authority. • A 0.66/20 kV transformer having the following size: length x width x height – 3.5 x 2.5 x 2.78 m will be located on a concrete platform near the base of the turbine.

Figure 2.2 Key elements of a wind turbine(8)

(8) Source: New South Wales Government, Department of Water and Energy, www.dwe.nsw.gov.au

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The turbine components will be transported by ship to the port of Constanţa and subsequently transported to the site by low loader vehicles over a distance of approximately 60 km, via the National Road DN 38 Constanţa - Mangalia. Access to the site is described in Section 1.13.4.

The turbines are designed to generate electricity from wind speeds of between 3 and 25 m/s. According to the turbine design requirements, at wind speeds exceeding 25 m/s the turbine control system will apply a braking mechanism, and the turbine will cease operation temporarily.

Each turbine is equipped with a ‘fail safe’ system. This system ensures the turbines shutdown safely even in the event of a loss of energy. The turbine design is in accordance with international standards and Romanian (SR EN 64100-1:2006 Wind Turbines Design Specifications).

2.1.4 Foundations

Foundations for the wind turbines will be circular with a diameter of 19 m and a depth of 1.86 m below ground. The foundation will consist of a foundation plate and a stand with a height of 0.75 m and a diameter of 6.00 m. An adjustment of the foundation depth to local conditions may occur during detailed design following consideration of the permitted total height and the local ground water level.

A Geotechnical Study was conducted in 2009 and provides detailed information on the soils and geology for each turbine location. Final details of foundations will depend on these data.

2.1.5 80 MW Project Substation 20/110 kV

A new 80 MW Project Substation 20/110 kV will be located within the wind farm site boundary (plots A11/3/11 and A11/3/12, on the fields of Chirnogeni Commune, approximately 3 km away from the closest residential property which is a pig farm and 4.2 km from the (existing) Chirnogeni substation 110/20 kV.

32 wind turbines will be connected through their own hermetic three-phase oil transformers of 2700 kVA, 0.66/20 kV to a network of 20 kV underground electrical cables connected in cascade. The energy produced by the turbines will be transferred to the proposed substation by means of electrical switches.

The substation will comprise the following equipment:

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• a 20/110 kV transformer; • 20 kV and 110 kV breakers; • high and low voltage electric apparatus; • binding equipment, connections, cables and underground electrical lines; and • Supervisory Control and Data Acquisition (SCADA(9)) equipment. Parts of the equipment, including the SCADA equipment, will be installed in a control building, which forms the Inner Substation 20 kV, and the remaining equipment will be installed outdoors and form the so-called Outdoor Substation 110 kV (Figure 2.3 below shows an example of Outdoor Substation).

The control building for the Inner Substation 20 kV will be approximately 3 m high and cover an area of 250m2. This building will have metal corrugated exterior and roofing and will require concrete foundations. The construction materials will be transported from concrete plants from Constanta or Mangalia. The land within the boundary of the substation will be flat with a hard core surface covered in gravel. The excavated soil will be stored temporarily on site and reused for construction of roads or disposed in agreement with the local authorities. The top soil will be reused for reinstatement after completion of the constructions. Concrete bases will be built for the installation of the electrical equipment. For security reasons the substation will be surrounded by a 2.5 m high gated chain wire fence.

The energy generated by the Chirnogeni Wind Farm (80 MW) will be transmitted from the proposed project substation (see Section 2.1.5) to the (existing) Chirnogeni Substation 110/20 kV (see Section 2.1.6) via the proposed 110 kV Underground Transmission Lines (see Section 2.1.8).

(9) SCADA is a process control system enabling a site operator to monitor and control processes that are distributed among various remote sites.

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Figure 2.3 Example of an Outdoor Substation

2.1.6 Existing Chirnogeni Substation 110/20 kV

The existing Chirnogeni Substation 110/20 kV is owned and maintained by ENEL. It is located 2.6 km west from the proposed wind farm site, on the fields of Chirnogeni Commune.

2.1.7 Underground Electrical Cables

The project will include a network of approximately 26 km of 20 kV voltage buried cables connecting the wind turbines to the 80 MW Project Substation 20/110 kV. The cables will be buried to a depth of 1.5 m and will be coated to prevent erosion. They will be laid on a bed of sand.

Cables in the carriageway of the access roads will be installed between two sand layers approximately 20 cm thick above the cables and 10 cm underneath. As a safety measure, warning foil will be laid above the sand layers.

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All cable trenches will be backfilled with excavated subsoil and topsoil.

The optical fiber cables required to transfer SCADA data will be fitted in 50 mm high-density polyethylene (HDPE) tubes, which will also be installed in the cable trenches.

2.1.8 Underground Transmission Lines

The project will require underground transmission lines (110 kV) of approximately 4.47 km from the project substation to the (existing) Chirnogeni Substation 110/20 kV which connects to the Power Distribution Grid owned by “ENEL”.

These lines will be single circuit with three conductors installed in trefoil formation with the phase spacing of 160 mm. They will be constructed in a concrete cable trench whose width and depth was not defined at the time of writing this ESIA. However, both cables and trenches will be defined during the detailed deisgn. The construction method appliedto bury the cables will comply with the relevant standards in force.

The cable insulation material (XLPE) was chosen taking into account local weather conditions and the need to dissipate heat. The construction method used for installing the cable will include trenching on most of the route length and horizontal directional drilling for undercrossing the agricultural field drain channel.

A geotechnical study will also be prepared in order to determine the soil's ability to move heat away from the line or special backfill material considered to be used instead of soil in the trench around the line to ensure a good heat transfer to surrounding soil or groundwater.

2.1.9 Construction Management

Construction Principles

The project will be constructed in accordance with standard techniques and best practices in the industry, using companies with appropriate experience for design, construction and operation. A project manager appointed by EPWP6 will oversee the construction works and will liaise with environmental consultants who will provide technical support.

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Temporary Construction Compound

During construction a temporary construction compound (Annex 2 – Site Layout Map) of approximately 50 m by 100 m (5,000 m2) will be required and will contain the following.

• site office and bedroom containers for 50 workers; • portable toilets with septic tank incorporated , which will be emptied on a weekly basis or as necessary;

• 2000 m2 for car parking - an area of compacted stone which will be restored to its original condition following construction; • temporary storage for turbine components; • crane assembly pads and temporary storage platform - this area will be constructed using similar methods to the construction described for the site access roads. Following construction, the temporary storage platform will be returned to agricultural use as fully as practical. • the site will require water and electricity during construction - water will be provided via mobile tanks of about 1,000 litres each and will be used by approximately 50 workers for sanitary purposes. Electricity will be provided via one generator having an output power of 125 kW.

Turbine Assembly

Pre-assembled generator parts and components will be transported to site, followed by the hub components. Finally the turbine blades will be installed. The turbines will be erected using a crane with a carrying capacity of 500 tonnes. This crane will be supported by a mobile crane with a capacity of 120 tonnes.

Construction Workforce

The construction stage of the project will involve an average daily workforce of 50 workers, 15 of which will be employed from the local available manpower. They will be accommodated in the bedroom containers to be provided within the contruction compounds.

Construction Working Hours

Construction working hours will be 0700 – 1900, Monday to Friday and 0700 – 1300 on Saturday.

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Indicative Construction Schedule

Construction is anticipated to take approximately 18 months and will comprise the following key phases:

• civil works - 7 months; • logistics - 9 months; • electrical works - 12 months; • turbine installation and commissioning - 10 months; • restoration - 2 months. Table 2.1 presents an indicative construction schedule, illustrating how many activities will overlap.

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Table 2.1 Indicative Construction Schedule

Chirnogeni Wind Project Construction Schedule 18 Month Timeframe

Month 12 3 4 5 6 7 8 9 101112131415161718

Civils Clearing & Grading Install Site Offices Installing Permanent and Temp Roads Turbine Foundation Excavation

Transportation Turbine Components Transported to site

Electrical Project Substation Construction Project Transmission Line Construction Collection Lines (Between turbines, underground) Upgrade Chirnogeni Substation Offsite Transmission Line Upgrades

Turbine Installation Foundation construction & hardening Hoist & Install turbines 1-5 Hoist & Install turbines 6-10 Hoist & Install turbines 11-15 Hoist & Install turbines 16-20 Hoist & Install turbines 21-25 Hoist & Install turbines 26-32

Testing & Commissioning

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Construction Materials

The main materials to be used for construction include geotextiles, cement and aggregate materials, sand, steel casings and electrical cables. All these construction materials will be supplied on site from Constanta or Mangalia, using authorized vehicles (e.g the cement will be supplied by cement plants located in Constanta or Mangalia). It is not assumed that large quantities of these materials will be stored on site; they will be supplied periodically, depending on the construction phase.

2.2 DECOMMISSIONING ACTIVITIES

The wind farm components have an operational life of at least 20 years. At the end of this period there are a number of possible options: an extension of operation; refurbishing or renewing of the wind farm components; repowering the site with newer and more sophisticated plant; or decommissioning of the wind farm. For the purposes of this ESIA Report, it will be assumed that the turbines will be dismantled and removed after 20 years.

The decommissioning of the wind farm will be performed gradually as follows. The estimated quantities of material resulting after decommissioning of all project components are presented in Table 2.2 below:

Table 2.2 Estimated quantities of materials resulting from decommissioning of the wind farm

Project Construction materials Estimated quantity(10) of component materials after decommissioning (tonnes) Per piece Per total Rotor Spheroidal graphite cast 55 1760

(10) Estimated quantities are based on the weight of the project components included in the Technical Description of the Nordex N90 wind turbines.

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Project Construction materials Estimated quantity(10) of component materials after decommissioning (tonnes) iron Rotor hub Spheroidal graphite cast 25 800 iron Blades Glass-fibre reinforced 10.2 979.2 plastic Gear box graphit cast iron 18.5 592 Generator graphit cast iron 12 384 Tower Steel 306 9798

When dismantling and removing the turbines, the bases would be broken out to 1 m below ground level. Depending on the construction of the foundation, the estimated quantities of materials resulting after decommissioning are 600 m3 concrete and 70 tons of steel waste. All cables buried to the depth of 1 m will be cut and the most appropriate option for their disposal will be identified. All crane hardstandings and onsite tracks would either be left for use by the land owner or covered with local topsoil material and seeded with grass, with the permission of the local authorities.

It is expected that the process of turbine removal and site reinstatement will take approximately 6 months. Disposal measures for the resulting demolition materials will be established on the technical documentation to be submitted for obtaining the demolition permit.

No chemicals, including asbestos and polychlorinated biphenyls (PCBs) will result after decommissioning.

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3 WASTE AND CHEMICALS

3.1 WASTE

3.1.1 Waste generation

Waste is likely to be generated during construction and operation of the wind farm.

Construction waste may include the following:

• domestic waste; • excavated material (waste soil, subsoil, top soil); • waste cement; • waste cable; and • cardboard, metal, wood and plastic packaging waste from equipment and materials supplied on site. During operation, there will be minimal waste generated from maintenance activities which will mainly comprise domestic waste and waste oils. The estimated quantities of waste oil resulting from regular maintenance are presented in Table 3.1 below:

Table 3.1 Estimated quantities of waste oil

Waste Type of waste Specification 2010 2011 2012 2013 Code 20 03 Domestic waste Trash 50 kg .50 kg 50 kg 50 kg 01 13 01 Hydraulic oil 10* Waste oil <450 L <450 L <450 L <450 L 13 02 Hydraulic oil 05* Packaging waste 15 01 Metal packaging waste contaminated with < 10 kg < 10 kg < 10 kg < 10 kg 10* hazardous chemicals

3.1.2 Waste management

During construction, the main contractor will be required to identify opportunities for recycling or re-use, disposal routes and licensing requirements for all waste from construction in line with applicable legal

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requirements. Waste will be segregated into appropriate categories and stored in clearly identified containers for disposal via an authorized waste operator.

During operation, all wastes arising from maintenance activities, such as domestic waste or waste oils will be removed from site to an authorized waste operator. There will be no deposits or discharges on site.

3.2 TOXIC AND DANGEROUS CHEMICALS

Paint will be the only type of chemicals used during the construction phase and the estimated quantities are presented in Table 3.2.

Table 3.2 Estimated Quantities of Paint Required during Construction

Use Quantity (litres) 80 MW Project Substation 20/110 kV 91 Existing Chirnogeni Substation 110/20 kV 236 Transmission Line Poles of Power Distribution Grid 2,640 Subtotal 3022 Contingency @ 10% 302.2 TOTAL 3,324.24

The components of the Project Substation requiring paint include only the metal corrugated walls and roofing.

Many of the surfaces at the existing Chirnogeni Substation 110/20 kV need refurbishment or replacement (e.g. the existing fencing will be replaced with a galvanized “chain link” type fence). The existing substation building will be repainted on the outside and inside. Paint required for these activities will be stored in an offsite maintenance building located in Chirnogeni.

The solution study could include requirements to paint Transmission Line pole structures from Chirnogeni to Basarabi. At the current project stage, this requirement is uncertain and will be laid out in the final transmission solution study. Table 3.2 includes estimated quantities of paint which may be required in case the final solution study requires paint coverage of the Transmission Line pole structures.

Oils, hydraulic fluid and lubricants needed to maintain the wind turbines, containing multiple protection systems against leakage, will be the only chemicals handled during the operation of the wind farm. These will be stored in the offsite maintenance building located in Chirnogeni.

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Material safety data sheets for all hazardous substances and chemicals will be made available to maintenance workers who will be trained to handle them appropriately.

The wind farm’s operation will not fall under Seveso Directive.

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4 SOILS, GEOLOGY AND WATER RESOURCES

4.1 INTRODUCTION AND SCOPE

This chapter considers the impacts of the proposed wind farm upon soil, geology, groundwater and surface water resources existing in the project area. Section 4.3 provides a summary of the baseline features of the project area. Impacts of the project and associated mitigation measures are discussed for construction in Section 4.4 and for operation in Section 4.5.

Impacts to land use are assessed in Chapter 10, Social and economic environment.

4.2 METHODOLOGY

This assessment is based on a desktop study and the findings of a geotechnical study(11).

For assessing the significance of impacts to soil, the nature and quality of resources available within the proposed site boundary and the effect of the development on these in terms of loss, sterilisation or reduction in quality as a result of construction or operation have been considered.

For assessing the significance of impacts to water resources the following factors have been considered:

• the magnitude of the potential impact, as determined by its intensity and by its extent in space and time; • the sensitivity and value of the surface and ground water resources in the vicinity of the Project, taking into account current groundwater flow characteristics, water quality and considering potential secondary impacts (e.g. within catchment areas and groundwater recharge zones); and

(11) Geotechnical study which the Romanian company SC Geotec Consulting SRL performed on the project area in April- May 2009

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• the sensitivity of uses of the water environment (e.g. abstractions, and recreational users). Impacts are described as being not significant, or of minor, moderate or major significance as follows:

• Minor impact: small, very short or highly localised changes in the quality or availability of resources of local importance; these may be considered to be of some significance but should not be given much weight in the project design and permitting process; • Moderate impact: substantial changes in quality or availability of resources affecting beneficial uses of local importance, or lesser changes affecting resources of more than local importance; these should be taken into account in project design and decision making; and • Major impact: substantial changes in the quality or availability of resources affecting beneficial uses of more than local importance, including any impacts which make existing beneficial uses no longer viable; these should be given major weight in project design and decision-making.

4.3 BASELINE ENVIRONMENT

4.3.1 Topography

The project site is located in the Negru Voda plateau whose altitude ranges between 150 m and 180 m above sea level. The project site itself is flat terrain, surrounded by very gently sloping hills.

Morphologically, the site has the shape of a prolonged plateau on northnorthwest-southsoutheast direction, parallel with the two valleys bordering the site (Independenta Valley in a south and west direction and Chirnogeni Valley in north and east direction). Both valleys originate in the Negru Voda plateau in the southern part of the Dobrogea region, and develop in a northnorthwest direction following the River Danube. The Negru Voda plateau is part of Dealu Trei Hotare hill (161.3 m) with altitudes ranging between 137 and 161 m, described as a gently undulating.

4.3.2 Soils

The project site is underlain by Chernozem soils, which are common in the Dobrogea region. These soils are characteristic for areas with a lower amount of rainfall than water losses through vaporisation.

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Chernozem soils are very fertile and have a high production capability due to their well-developed, dark, humus horizons and rich nutrient content. They have a fine middle texture with carbonates in the topsoil. The humus layers range between 3 and 12 cm in thickness. As there is a limestone parent rock in the project area, the soil is alkaline and rich in calcium.

There is no history of soil contamination known at the project site.

4.3.3 Geology

The Paleozoic(12) bedrock(13) of Southern Dobrogea is covered by sedimentary deposits, the first of which is a formation known exclusively in the area Palazu Mare – Cocosu near Constanta and includes conglomerates(14), argillite(15) and slate. In the project area, these deposits include clay and lime formations which are alternatively repeated and their added thickness of these Paleozoic sediments exceeds 1,000 m. The Paleozoic deposits start at a depth of approximately 400 m below ground level.

The Mezozoic Era(16) deposits mainly comprise alternating calcareous (limestone) and detritic (sand or gravel) layers with numerous sedimentary discontinuities added in the period of the Middle Jurassic until the Superior Cretaceous. In the project area, Mesozoic deposits range between 220 m and

(12)The Paleozoic or Palaeozoic Era is the earliest of three geologic eras of the Phanerozoic eon spanning from 542 to 251 million years ago (ICS, 2004). It is subdivided into six geologic periods, which, from oldest to youngest, are: the Cambrian, Ordovician, Silurian, Devonian, Carboniferous, and Permian. Source: http://en.wikipedia.org/wiki/Paleozoic as of 14 April 2009

(13) The igneous and metamorphic rocks that exist below the oldest sedimentary cover. In some areas such as shields the basement rocks may be exposed at the surface.

(14) A clastic sedimentary rock that contains large (greater then two millimetres in diameter) rounded particles. The space between the pebbles is generally filled with smaller particles and/or amorphous cement that bind the rock together.

(15) This rock sometimes resembles an indurated clay or shale. It is for the most part extremely fissile, often affording good roofing-slate.

(16) The Mesozoic is considered to have lasted from roughly 251 million years ago (Mya) to 65 Mya, when the Cenozoic era began. This Mesozoic has three geological subdivisions, from oldest to youngest, Triassic, Jurassic and Cretaceous. Source: http://en.wikipedia.org/wiki/Mesozoic as of 14 April 2009

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250 m in thickness and are covered by Tertiary(17) deposits. The boundary between Mesozoic and Tertiary deposits is approximately 150 m below ground level. Tertiary deposits represented by sarmatic deposits (superior neogen) are well developed in the region and in the project area range between 100 m and 120 m in thickness. Two main strata are identified – Bessarabian - composed of 4 horizons (mainly green-yelow clay with clayey sand lenses, alternating with limestone, bentonitic clay and limestone lenses) and Kersonian strata comprised mainly by lumashell or oolitic limestone, and secondary by limy conglomeratic sandstone, sand and clay intercalations in limestone layers.

Based on the information from on site geotechnical investigations (geotechnical study from April 2009) this sarmatic layer was encountered in three structural drillings at depths between 22,8 m in FT7; 18,9 m in FT17 and 27,2 m in FT28. At the base of the reddish clay in FT 17 and FT 28 occurs a shallow zone of limestone fragments 4.2 m thick. This layer is comprised of a heterogen material composed by a yellowish-grey-redidish clay formation with iron oxidation incorporating limestone element in an advanced weathering stage.

Quaternary deposits (18) cover tertiary deposits and are mainly subdivided into Pleistocene and Holocene sediments. Pleistocene deposits mainly include a 2- 6 m-thick clayey base horizon and an upper 15-30 m-thick horizon characterised by loess deposits. Quaternary deposits are represented by the following layers:

• Upper Peistocene (qp22-qp3) found in the interfluvial spaces (including the project site) lays directly on the sarmatic limestone and is composed of two horizons. Clayey base horizon (± sandy) has a generic thickness of 6-16 m with limestone of red-purple with manganese and limestone concretions with iron spots. The results of the geotechnical investigation have identified this layer as clayey deposit (B) mainly formed by dusty clays

(17) The Tertiary era is a geologic period from 65 million to 1.8 million years ago.

(18) The Quaternary Period is the geologic time period after the last Tertiary (Neogene) Period, lasting from roughly 1.8 million years ago to the present.

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with frequent limestone concretions at different layers. These clay deposits are entirely encountered by the three advanced borings drillings down to the sarmatic base, and it presents thicknesses of b 6,3 m, 10,6 m and 16,2 m. The presence of reddish clay was identified also in other two drillings advanced on the project site, starting at a depth of 7.8 m and 8,8 m . Superior horizon represented by loess deposits is mainly composed by clayey sandy dust, clayey sands and yellowish clayey sands with limestone concretions. In the geotechnical study this layer is labelled as Loess Complex (A) and is located underneath the vegetal soil 0,4 m - 0,8 m thick. It is mainly comprised by dusty loess soils (70-5% dusty clay) and clayey loess soils (25-30%clayey dusts). Often are observed limestone concretions and disseminations as well as oxidation zones (nodules, lances and nests of iron-manganese oxides). Based on the intrusive as well as geophysical investigations performed on site was observed that the thickness of the loess complex layer ranges between 7.8 and 16m below ground level (bgl). The Loess deposits are considered to be the geological structure on which the project elements will be constructed and represent the material where the fundament elements of the wind farm will be placed.

Figure 4.1 Geological Map of the Project Site

Project site

Section from sheet K35 –V Mangalia geological map, 1:200.000 scale, Romanian Geological Institute 1967

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• Holocene (qh2) is developed in the more prominent river valleys (valea Independenţa, valea Chirnogeni), wher it is represented by sands, gravels and sandy-clayey silt, as well along the shore as beach sands.

4.3.4 Seismicity

According to Annex 3(19) of Law 575/2001 regarding the Approval of the Spatial Planning of the National Territory – Section V: Natural hazard Areas and the Romanian standard of seismic zonation (SR 11100/1-93), Negru Voda town (the closest urban settlement indicated as reference, at a distance of 5.7 km southeast to the project site limit) is located in an area of macroseismic (20) intensity I=71 MSK . This value refers to very strong intensity earthquakes and the value of the index refers to a 50-year return period. According to the MSK intensity scale, this corresponds to an average seismic risk for the project area. This means that the project area is not a seismically active area in itself but it is located in the direct vicinity of Vrancea, a confirmed seismically active area. The town of Focsani, seat of Vrancea county administration, is located at approximately 300 km north-northwest of Constanta. Earthquakes in Vrancea can range from minor (up to 5 km deep) to intermediate (up to 220 km deep). Intermediate earthquakes correspond to a macroseismic intensity of I= 7 MSK and statistically occur three times per century. Given the high depth at which they are produced, intermediate earthquakes can have impacts over distances of several hundred square kilometres. Local rural and urban areas can be strongly impacted by intermediate earthquakes(21).

According to the new Norm P100-1/2006, the project site can be characterised

by a Pick Ground Acceleration for design: for design (ag) for earthquakes with

(19) Annex 3 lists the Romanian urban settlements located in areas for which the seismic intensity exceeds 7 MSK.

(20) The Medvedev-Sponheuer-Karnik scale, also known as the MSK or MSK-64, is a macroseismic intensity scale used to evaluate the severity of ground shaking on the basis of observed effects in an area of the earthquake occurrence. The MSK scale has 12 intensity degrees expressed in Roman numerals, starting from earthquakes whose intensity is not perceptible to very catastrophic ones, resulting in complete destruction of underground and surface structures. Source: http://en.wikipedia.org/wiki/Medvedev-Sponheuer-Karnik_scale as of 15 April 2009

(21) Teaching material on child awareness raising on earthquakes and their effects prepared by the Romanian Institute for Research – Development of Construction Economy within a partnership between the Romanian Ministries of Transport & Construction and Education, 2006.

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medium seismic recurrence of a 100 years: ag = 0,16 g and control period TC = 0,7 sec.

4.3.5 Groundwater

The hydrogeological features of the project area comprise permeable rocks which generate rapid infiltration of water at different depths in the karstic levels. The shallow groundwater table in the project area is estimated to be below 35-40 m depth according to the geotechnical study(22). Taking into consideration the morphological features of the area, it is estimated that groundwater flows from northwest to the southeast.

During the investigations of the geotechnical study the groundwater layer was not encountered down to 30 m bgl. The limestones encountered during the drillings did not present traces of groundwater.

During the past 50 years, construction works to set up irrigation systems and to develop transportation on the River Danube have had adverse impacts on the hydrology as well as hydrogeological regime of Constanta county(23). During the former communist regime, Constanta had one of the most developed irrigation systems in the country, which included deep underground pipelines containing asbestos, aboveground metal pipes, pumping stations, irrigation channels paved with concrete tiles. For example, the pumping stations in Negru Voda were supplied with water from Carasu river, a section of the area where the Danube-Black Sea channel was constructed.

Drinking water in Chirnogeni Commune, including Chirnogeni, Credinta and Plopeni villages, is supplied via a drinking water supply system. This system was constructed in early 1970s and includes underground pipelines made of iron and asbestos containing materials. The drinking water supply network is

(22) Geotechnical study which the Romanian company SC Geotec Consulting SRL performed on the project area in April- May 2009

(23) Dãnescu, F., Costãchescu, C., Petrila, M., Necessity study for installation of network shelterbelts for field protection in Constanta County, Forest Research and Management Institute (ICAS) Bucharest, Romania, ICAS Annals, 50:299-316, 2007

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operated by the county water supply operator Regia Autonoma Judeteana de Apa Constanta (RAJA) SA and water is provided from 5 groundwater abstraction wells drilled at a depth of 300 m: one in Credinta village, two in Plopeni and two in Chirnogeni. Approximately 95%(24) of the population of Chirnogeni commune is connected to the drinking water supply network. The remaining 5% represent the population which rejected the connection to the water supply network and continues to use water from springs or own wells.

In Independenta Commune, only three villages out of five, namely Movila Verde, Independenta and Olteni have a drinking water supply network having the length of 20 km. The network in Independenta village is approximately 30 years old and it is operated by Regia Autonoma Judeteana de Apa Constanta (RAJA) SA. The networks in Movila Verde and Olteni were constructed in 1997, respectively 2006, and are owned by the Independenta Mayoralty. Each of these three villages has two groundwater abstraction wells. Approximately 90%(25) of the population of the three villages is connected to the water supply network. According to the local authorities, the remaining 10% represent the population which rejected the connection to the water supply network and continues to use water from springs or own wells.

Neither Chirnogeni nor Independenta Commune have a public sewage network.

The Tertiary deposits underlying the project area are mainly formed of permeable sediments, which represent an aquifer below the project area with a groundwater table in depths between 29 m and 32 m below ground level. This groundwater has a high mineral content (700 mg – 1000 mg/l) and a high concentration of Chlorine and Sulphate ions (100-200 mg/l and 50-100 mg/l respectively).

(24) Statistical data for 2007 included in the Chirnogeni Commune Factsheet published on the website of Constanta County Coucil on 18 May 2009.

(25) Statistical data for 2007 included in the Independenta Commune Factsheet published on the website of Constanta County Coucil on 4 March 2009.

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In the shallow Quaternary deposits (loess sediments), groundwater is only present in form of a temporary accumulations of small amounts of stormwater in the porous structure of the loess and thus does not represent a permanent aquifer.

4.3.6 Surface Water

The surface water network within the county of Constanta has a very low density (0.1 km/km2). No rivers or lakes are located within close proximity of the project site. The following water bodies are located at some distance from the site limit:

• Plopeni Lake - approximately 6.9 km north-northeast of the site; • Negreşti Moor - approximately 7.8 km north of the site; and • River Danube located approximately 42 km northwest of the site. An agricultural irrigation channel is present in the vicinity of the proposed underground transmission lines. It was observed to be dry in October 2008.

According to Annex 5(26) of Law 575/2001 Approval of the Spatial Planning of the National Territory – Section V: Natural Hazard Areas, the area of Independenta commune is exposed to risks of flooding at times of very heavy rainfall which may cause sudden gushes of water to pour down from the neighbouring hills.

The decision on the type of construction materials and features of the foundations for the turbines, polls and project substation will have to take the flooding risk of the area into account. Calculations will be made by construction experts to minimize any risks for the Project components.

(26) Annex 5 lists the Romanian urban and rural settlements which may be affected by flooding from the water bodies or from gushing water.

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4.4 CONSTRUCTION IMPACTS

4.4.1 Assessment of Impacts to Soils

The employed construction method is briefly described in Section 2.1.8. The soils within the study area are considered to be fertile and of value to the local farming community. According to the geotechnical study, the soil will suffer compaction measures in the areas of the future fundations of turbines, platforms/pads and access roads (see Section 4.5.5).

Compaction to soils can also occur from the movement of heavy vehicles and machinery during construction, subsequently altering the soil structure. This can also cause deterioration in soil fertility due to the absence of oxygen (anaerobiosis). Stripped soil in storage alongside construction working areas will be vulnerable to degradation, dehydration, wind and water erosion and contamination by pesticides used to control weed invasion unless mitigation measures are implemented. Degradation may occur due to the breakdown of organic materials and biological structures binding the soils together. Best practice soil handling techniques will be implemented and detailed within the Construction Environmental and Social Management and Monitoring Plan which will mitigate these potentially adverse effects. These will include the following measures:

• Topsoil stripping will be limited to the footprint of the turbine, platform and pads locations and the access roads. • Topsoil will be stored carefully to one side of the construction working area, in such a way that it is not mixed with sub soil or trafficked on by vehicles. • After the installation of the cable for the underground transmission line, the stored soil and topsoil will be used as backfill for the trenches and the area will be restored to its initial condition. • Following reinstatement, any surplus (uncontaminated) soil will be spread over fields subject to agreement with the landowner/occupier and/or used for landscaping within the project area. • Stockpiles will be a maximum of 2 m high to avoid compaction from the weight. • The construction working area will be reinstated as far as practicable to the same condition as before. Contamination of soil during construction could occur through direct spillage of materials such as fuels and lubricants from vehicles and generators.

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In order to limit potential impacts associated with direct spillage of fuels and lubricants the following measures aimed to prevent harmful substances from reaching the subsurface will be implemented:

• Refuelling of vehicles or equipment will be restricted to impermeable hardstanding within the construction camp. Any maintenance or re- fuelling will take place only with implementation of appropriate secondary containment and spill controls. • Transportation vehicles and construction equipment will be parked on paved surfaces during the night. The paved surfaces should be equipped with oil/water separators to treat storm water, if possible. • Construction works will be executed so that subsurface contamination is avoided. Any oil or fuel spills will be immediately cleaned up, and any contaminated areas will be remediated and restored after construction. The contractor will also develop procedures for emergency/spill response, and for the storage and handling of fuels, construction materials and wastes.

Contamination that may already be present in the soil from current or historical sources may also be encountered during excavation and this could impact the construction workforce via contact and associated ingestion, the land drainage network via surface run-off from stockpiles. However, given the agricultural nature of the project area, the presence of historical contamination is considered very unlikely and, if present, it is likely to be only as localised hotspots or low concentration. Soil analytical analyses performed so far at the project site have been conducted for geotechnical purposes only (no environmental aspects addressed), for assessing the aggressiveness of the soils to metal and concrete elements of the future foundations. One soil sample (s1) was collected from the borehole advanced on the location of the platform near turbine no. 2 from 2 m bgl. A second soil sample (s2) was collected from the borehole advanced on the location of the future turbine no. 28, from 4.5 m bgl. Following parameters have been determined:

Table 4.1 Results of soil aggressiveness on metal on concrete elements

Item Parameter Units S1 S2 1 pH 5.7 5.9 - 2 Bicarbonates mg. CO3H / kg 2348.26 1147.69 3 Calcium mg. Ca2+ / kg 68.7 47.6 4 Magnesium mg. Mg2+ / kg 126.35 46.9 5 Chlorides mg. Cl- / kg 1731.04 7235.81 2- 6 Sulphates mg. SO4 / kg 9.25 7.89

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The soil samples present a very weak pH aggressiveness, a moderate bicarbonates aggressiveness and a none - very weak magnesium aggressiveness. sampel s2 presents an aggressiveness due to the chlorides content.

The soils that will be directly impacted by the project are of value to local farmers, however, given the ability of the soils in the project area to respond well to reinstatement, and the mitigation measures to be implemented, it is predicted that there will be no significant impacts to soils during construction.

4.4.2 Assessment of Impacts to Groundwater

Groundwater is not expected to be present at shallow depths over the project area (see Section 4.3.5). According to the data supplied by the Chirnogeni Mayoralty, there are two groundwater abstraction wells located in Chirnogeni, two in Plopeni and one in Credinta village. Drinking water from these wells is abstracted from a depth of 300 m.

In terms of groundwater vulnerability, the medium permeability of the overlying sediments (loess complex (A) with average hydraulic conductivity of k = 2,35 x 10-6cm/s) is compensated by the relatively deep location of the groundwater table (35-40 m bgl). Therefore, it could be considered that the groundwater vulnerability is medium. Given that the aquifer may be used (including for drinking purposes) by the population without connection to the potable water supply system, the groundwater sensitivity could be considered high.

The overall sensitivity and vulnerability of the groundwater is therefore considered to be medium-high. This is also supported by:

• the water accumulations in the macropore structures of the loess layer (6- 16 m thick) have a temporary character being strictly dependent on the precipitations, without posibility to form a permanent aquifer; and • the relatively shallow soil depths impacted by the construction works (maximum 4 m bgl. Potential impacts to the groundwater resource during construction may occur from leaks or spills of diesel or lubricants on the site from equipment or machinery, or from the reworking of contaminated material. In order to minimise any adverse impacts to groundwater from potential contaminants from construction activities, measures as described in Section 4.4.1 will be implemented. Cut off ditches will be used to prevent water from entering excavations. Any draw-down of groundwater during excavation works is

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expected to be localised and levels will normalise rapidly once pumping ceases. Where possible, cut-off drains will be used rather than pumping to control water levels. However, in either case the effects of dewatering will be shortlived and very localised, and no impacts on water resources are predicted.

No significant impacts to groundwater are therefore predicted to occur as a result of construction contamination or dewatering activities.

Given the nature of the land in the project area contaminated material is very unlikely to be encountered (see Section 4.4.1) and therefore no significant impacts on groundwater quality are predicted during construction.

4.4.3 Assessment of Impacts to Surface Water and Drainage Patterns

The only surface water feature identified within close proximity of the site that may be potentially affected by construction is an agricultural field drain which lies close to the positioning of the underground transmission lines. This was observed to be dry during site visits conducted in October 2008 and early March 2009. The agricultural field drain will be undercrossed by the underground transmission line. As part of the permitting process, the National Administration for Land Reclamation and Improvement (Administratia Nationala a Imbunatatirilor Funciare) may define specific requirements that will have to be incorporated in the design of the drain crossing.

The condition of the field drains located in the proximity of the site will be surveyed and documented prior to construction in order to provide a basis for assessing any damage created during the construction phase and to enable an accurate delineation for the potential reinstatement needs. Any land drainage features disturbed during the construction phase will be completely reinstated. Good site working practices to be implemented as discussed in Section 4.4.1 will ensure that any contamination of the field drains is avoided.

Excavation activities will be restricted during periods of intense rainfall, and temporary bunding will be provided to reduce the risk of sediment, oil or chemical spills to the natural field drainage system.

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4.5 OPERATIONAL IMPACTS

4.5.1 Assessment of Impacts to Soils

During the operation phase, potential impacts may be associated with the minimal modification to run-off rates and drainage patterns due to the introduction of impermeable surfaces within the project area.

No significant impacts on soils are anticipated during project operation.

4.5.2 Assessment of Impacts to Groundwater

Overview

Turbine foundations could create a preferential pathway for contaminants to reach groundwater resources. However, no existing contamination has been identified. Turbine maintenance requires only minimal use of lubricants of other materials with groundwater potential.

Given that the concrete foundations depth will be limited to 2 m bgl and the aquifer was not encountered by the geotechnical boreholes advances to 30 m bgl, the groundwater contamination risk can be considered very low.

Rotor bearing

During rotor bearing operation, grease may leak from the labyrinth seals in the rotor bearing. The grease flows into two drip trays (approximately 10 or 25 l), which are regularly emptied during maintenance.

Gearbox

The gearbox has non-abrasive, non-wearing sealing systems on both the drive shaft and the driven shaft. In the case of an accident, oil that emerges from the gearbox is collected in a drip tray beneath the gearbox. Any oil leaking from the oil cooling circuit is collected in the drip tray in the tower, which is emptied during maintenance.

Tower

The highest tower platform is designed as a drip tray. The volume of the drip tray is minimum 630 liters.

Electrical Transformer

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The transformer is located outside the wind turbine in the transformer station. The transformer oil is usually not changed during the life time of the equipment. In case of an accident, any oil that emerges is collected in an impermeable concrete drip tray beneath the transformer.

Based on the above, no significant groundwater contamination impacts are anticipated during operation.

Whilst some localised effects on groundwater infiltration into the underlying bedrock may occur, the overall impacts are predicted to be minor given the area of the site (16.9 km2) compared with the area affected by permanent foundations and other permanent cover (a total of 0.124 km2).

4.5.3 Assessment of Impacts to Run-Off Rates and Drainage Patterns

During operation, the project will have no water demands and no discharges will be made. New access roads, turbine bases and other hardstanding areas will, however, increase impermeable areas on the site, and cause a reduced and localised, but still noticeable increase, in runoff rates and peak flood flows across the site. The proposed impermeable areas are small relative to the total site area. In order to reduce the potential impact on the drainage pattern, roadside drains will be designed to avoid disturbance to the natural hydrology. The depth of individual drainage ditches will be kept to the minimum necessary to allow free drainage of the tracks, and drain lengths will be minimised to avoid disruption of natural drainage directions. In addition, the drainage ditches will be backfilled with geotextile and gravel to inhibit the movement of water flow through the channel. The overall magnitude of modifications to the drainage pattern is predicted to be minor. The roadside drainage design will aim to ensure that runoff percolates to the underlying ground rather than concentrates as channel flow.

Runoff from any large hardstanding areas (including the turbine bases, mast base and crane hardstanding) will be drained to the surrounding land which will act as a buffer zone to slow runoff, to attenuate the flood peaks, and allow sediments to settle out.

Overall no significant impact is anticipated to run-off rates or drainage patterns as a result of operation of the wind farm.

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4.5.4 Assessment associated with Natural Hazards

A geotechnical survey was conducted at the site in April-May 2009 by S.C. Geotec Consulting S.R.L. (Geotec). The potential seismic activity at the site was evaluated and the survey results confirmed that the turbine design is able to withstand any probable seismic event in the project area. The turbine supplier (Nordex) will review the geotechnical report prepared by Geotec and will the suitability of the soil in the project area as well as any potential damages from seismic activity.

The main guidelines and standards providing guidance for seismic loading of wind turbines are summarized in the Assessment of Turbine Seismic Risk Report performed by Sandia National Laboratories in California for the US Department of Energy, as follows:

• Guidelines for Design of Wind Turbines, Wind Energy Department of Risoe National Laboratory and Det Norske Veritas, Copenhagen, 2001 • Guideline for the Certification of Wind Turbines (Germanischer Lloyd WindEnergie GmbH, 2003 Edition); and • International Electrotechnical Commission (IEC) Standard 61400-1, Third Edition, Wind turbines - Part 1: Design requirements (IEC, 2005). All three turbine guidelines suggest that there are few regions throughout the world where seismic loads may be design driving. In all cases seismic analysis is only required in regions of high seismic hazard or as required by local authorities. Like all civil structures, wind turbines are subjected to some level of seismic risks. However, since the design life of a wind turbine is approximately 20 years, most turbines will not experience a strong earthquake.

The wind turbines are designed to withstand the earthquake loads.

The 2.5 MW N90 Nordex turbines having a hub height of 100 m have been certified by the German certification body TÜV Nord in 2004 according to the second Division of guidelines of the Deutsches Institut für Bautechnik (DIBt II), member of the European Organisation for Technical Approvals. This Division comprises five sections dealing with constructional subjects of civil engineering, health and environmental protection, physics relating to construction and sealing against water and dampness.

This certification is an acknowledgement that the design of Nordex turbines complies with the standard wind turbine design requirements and includes the necessary considerations of seismic risks.

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4.5.5 Assessment of geotechnical aspects

A series of field and laboratory tests have been performed to assess the suitability of the natural geological conditions and based on these results have been identified solutions to improve the natural system to respond to construction needs. Table 4.2 provides a selection of the physical parameters of the two geological layers of importance for the project (A and B described in Section 4.3.3) n - porosity; e - porosity index; w – water content; Sr – saturation

degree; Ip – plasticity index; Ic – consistency index ; γnat –water natural volumetric content.

Table 4.2 Soil physical parameters

Physical parameters

n e w Sr Ip Ic γnat (%) - (%) - (%) - (kN/m3) Loess complex 32,2 - 0,47- 0,24- 12,5- 0,69- 14,58- 7,7-23,4 layer 52,9 1,12 1,19 24,6 1,34 20,72 (A) Clayey 37,4- 0,60- 0,79- 23,1- 0,72- 18,77- depsoits 20,6-0,8 41,3 0,70 0,93 25,0 0,90 20,01 layer (B)

Depending on the physical-mechanical properties of the geological formations which represent the base for the foundations of the turbines, platforms/pads and accesss roads different improvement activities of the soil are required.

• Turbine foundations have a round shape of 20 m diameter. The foundations will be constructed on the loess complex layer after improving the natural conditions by re-compacting the loess after the addition of gravel – with the purpose to protect the deeper soil layers against water infiltration. The minimum depth for foundation measured at the bottom of the recompated loess base will be 3.5 – 4m bgl including 2 m of concrete. The total foundation depth may increase depending on local geotechnical conditions. • Platform foundations will be constructed only on improved natural soil by applying a succession of 1 m thick compacted gravel layers overlaying a recompated loess layer of 1-1.5 m thick. The necessary gravel is not available locally and therefore existing sources in Dobrogea region will have to be considered (Olteni or Dumbraveni ores).

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• Access roads – will be constructed similar to the platforms foundations with the difference that the recompacted loess -gravel layer may be thinner of approximately 0.50-0.60 m. The geotechnical risk of the project was calculated in the geotechnical study according to the norm NP 074-2007 approved by M.O. 128/2007 based on the assessment of five criteria as summarized in the following table:

Table 4.3 Geotechnical risks matrix

Criteria Ranking Observations Land conditions 3 Acc. to norm P7/2000 - – medium terrains Groundwater 1 Excavations do not reach groundwater Construction Considered special construction type even if 5 category Norm P100-1/2006 classifies it as normal No risks of harming neighbouring constructions Neighbourhoods 1 or networks Acc tp P100-1/2006 for ag=0,16 – 0,20) minor Seismic risk 1 risks. Total 11 Moderate geotechnical risk, 2-nd category

The overall geotechnical risk is estimated to be moderate (11 points) even if the construction category was overestimated and classified as being of special importance due to unusual design and engineering settings and ranked with 5 points. The classification given by the P100-1/2006 (Code of seismic design – Part I Settings for building design) would address this type of construction as of normal importance (3 points).

The total geotechnical risk is moderate even if calculated based on an overestimation of the construction category.

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5 AIR QUALITY

5.1 INTRODUCTION AND SCOPE

This section of the ESIA Report considers the risk of adverse impacts on the atmospheric environment during construction and operation. Emissions to air from the project are generated by the following two mechanisms:

• dust during the construction phase; and • combustion emissions from vehicles visiting the site during the construction and operational phases. In addition to the air emissions generated, this project also has beneficial impacts to air quality via the offset of emissions that would be generated from conventional forms of electricity production.

5.2 SOURCES OF INFORMATION

To assess the air quality impacts from this project, ERM utilised the following sources of information

• Regional climate data from the Environmental Yearly Report 2008 published by the Local Environmental Protection Agency (LEPA) Constanta, • Offset emission reduction calculation guidance from of the British Wind Energy Association http://www.bwea.com/edu/calcs.html; • Information from the European Wind Energy Association http://www.ewea.org; and • Design Manual for Roads and Bridges, published by the UK Highways Agency, Volume 11, Section 3, Annex 1.

5.3 METHODOLOGY

5.3.1 Assessment Methodology

A desktop assessment of air quality impacts was made for this project using the available information sources referenced, as well as drawing on ERM’s previous experiences in similar projects around Europe.

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5.4 BASELINE ENVIRONMENT

5.4.1 Surrounding Environment

The site is located on the South Dobrogea Plateau in Constanta County, which is situated in southeastern Romania. The nearest towns/villages are:

• Chirnogeni - 2.4 km to the east; • Viroaga - 3.7 km to the west/southwest; • Plopeni - 4 km to the north; • Movila Verde - 5 km to the north/northwest; • Independenţa - 5 km to the northwest; • Negru Vodă - 5.7 km to the southeast; • Cerchezu - 6.5 km to the southwest. The Black Sea is approximately 35 kilometres to the east, and the Romanian- Bulgarian border is approximately 13 kilometres to the south. The surrounding vicinity is primarily agricultural (arable) in nature.

There are no national parks or RAMSAR wetlands within 10 kilometres of the proposed location. The nearest Natura 2000 site is the Dumbraveni-Valea -Lacul Vederoasa river region, which at its nearest point is approximately 5 kilometres northwest of the proposed site. There are no other Natura 2000 sites within 10 kilometres of the proposed location. The nearest RAMSAR protected wetland is Lake , which is approximately 31 kilometres northeast of the site.

5.4.2 Climate

From climatic point of view, the South Dobrogea Plateau is under the influence of Mediterranean and Pontic cyclones as well as under continental European-Asian anticyclones. Consequently, the climate is temperate continental, with real sub Mediterranean influences in the southwest, but essentially semi-dry continental in rest of the region, slightly moderated near the Danube River and Black Sea peripheries.

Through climate and relief specifics, the South Dobrogea Plateau is framed as a ‘Plain’ climate (due to low altitudes 70 – 250 m). The data on the principal climate elements reflects a high level of dryness (reduced haziness, high levels of sunstroke and solar radiation, high temperatures, low precipitation, high

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deficit of humidity, dry winds, etc). Table 5.1 – Table 5.5 list the general climate parameters for the region which should be representative of those experienced at the proposed site.

Table 5.1 South Dobrogea thermal characteristics

Sun light Solar ΣT>100C Days with Absolute Frost unities duration Radiation (effectively) critical low with a low hours/year MJ/cm2/day maximum temperature temperature temp < (0C) of <-150C 320C 2180 – 2260 13,5 – 13,7 1300 – 1400 10-20 -20 – 22 4 - 6

Annual average temperatures in the region are greater than the average for Romania (11.20C in Mangalia and 11.20C in ), and in the central Nordic half, the values do not drop below 100C.

Table 5.2 Annual average temperatures in Romania (0C)

Meteorological 2008 Air temperature Station Multi Annual Yearly low Yearly annual average 2008 record and date maximum and average date 10,9 12,2 -17,8/05.01.2008 36,8/16.08.2008 Cernavoda 11,4 12,3 -15,7/05.01.2008 38,9/16.08.2008 Constanta 11,7 13,2 -11,1/05.01.2008 31,6/05.07.2008 Harsova 11,0 12,5 -15,7/05.01.2008 38,9/16.08.2008 Mangalia 11,5 12,8 -13,8/05.01.2008 33,3/18.08.2008 11,1 12,3 -15,5/05.01.2008 36,1/16.08.2008

The absolute lows recorded in the major cities of the region were: – 250C in Constanta on 10 February 1929, - 33.10C in Murfatlar on 25 January 1954 and - 25,20C in Mangalia on 25 January 1942.

The maximum temperatures recorded were: +430C in Cernavoda on 31 July 1985, +410 C in Basarabi on 20 August 1945, +38,50C in Constanta on 10 August 1927 and +360C in Mangalia aon 25 May 1950.

The winds are determined by atmospheric circulation and local geographical conditions. The zone is typical for light breeze in night and days.

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Table 5.3 Recorded values at meteorological station in Constanta County

Meteorological 2008 Precipitation (l/mp) Station Multi annual Total amount in 24 hour maximum and average 2008 date Adamclisi 471,3 496,5 48,6/27.04.2008 Cernavoda 453,1 380,4 51,4/19.06.2008 Constanta 411,5 423,9 61,2/27.04.2008 Harsova 412,1 374,9 24,8/14.06.2008 Mangalia 412,1 467,9 84,6/27.04.2008 Medgidia 443,1 362,4 36,8/27.04.2008

Table 5.4 Precipitations recorded in 2008 (l/mp)

Meteorological Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Station Adamclisi 49,0 4,4 34,1 121,2 67,7 49,2 25,7 17,5 36,2 15,2 22,8 53,5 Cernavoda 13,5 0,9 39,6 75,8 37,6 72,5 29,4 6,4 39,4 10,2 15,9 39,2 Constanta 39,8 0,5 24,2 108,6 52,8 50,2 27,4 1,8 20,6 9,6 39,4 49,0 Harsova 5,4 6,4 19,7 69,6 45,8 69,4 17,4 13,8 51,8 21,4 19,0 35,2 Mangalia 76,8 3,9 30,0 124,0 36,0 36,2 32,2 7,2 66,4 2,6 32,7 19,9 Medgidia 7,7 2,2 23,5 103,5 57,3 35,6 17,2 2,0 33,0 7,7 25,7 47,0

Table 5.5 Average monthly values of air temperature recorded in 2008 (0C)

Meteorological Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Station Adamclisi - 2,6 8,3 12,3 16,2 21,3 22,6 23,9 16.5 12,9 6,7 3,9 1,4 Cernavoda - 2,9 8,7 12,6 16,4 21,6 23,2 24,6 16,9 13,2 7,3 0,9 1,1 Constanta 1,1 3,7 9,0 12,3 16,0 21,6 23,2 24,5 18,1 14,3 9,0 5,7 Harsova - 2,8 8,6 12,6 16,5 21,7 23,2 24,9 16,8 12,7 7,1 3,8 1,2 Mangalia 0,7 3,3 8,6 11,5 15,2 21,1 22,5 24,0 17,8 13,8 9,1 5,7 Medgidia - 2,8 8,3 12,3 16,0 21,3 22,7 24,1 16,7 13,1 7,2 7,1 0,8

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5.4.3 Ambient Air Quality

Existing Sources of Air Pollution Near the Site

The area immediately surrounding the proposed site is agricultural, and as such, there are no existing industrial sources of air pollution within the immediate vicinity. There are some small roads to the north and east of the proposed wind farm location, so some combustion related emissions and road dust would be expected from these sources.

Particulate Matter Baseline

Table 5.6 lists the sediment dust monitoring results for Constanta County according to the yearly report of LEPA Constanta for 2008. Sediment dust is defined as particulates with an aerodynamic diameter greater than 20 μm. The county baseline sediment dust values are based on results from a network of 13 fixed monitoring stations in the following cities/towns:

• Constanta city (5 locations); • Medgidia town (3 locations); • Mangalia town (2 locations); • Basarabi commune; • Cernavoda town; and • Navodari town. Table 5.6 Sediment dust monitoring results for the region

Year Average Maximum Minimum Exceedances Total monthly concentration Concentration frequency number concentration g/sqm/month g/sqm/month % of g/sqm/month samples 2000 8,61 29,51 0,8 11,76 17 2001 27,30 647 1,75 13,75 80 2002 12,47 167 0,9 13,01 123 2003 17,15 162 1 16,84 95 2004 19,39 241 0,4 79 100 2005 87,27 4459 0,79 24,21 122 2006 81,32 1892 0,046 36,05 147 2007 30,13 782 0,021 35,71 140 2008 25,47 386 0,7452 22,54 142

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Figure 5.1 shows the variation of sediment concentrations based on this data. There does not seem to be a discernable trend regarding sediment dust concentrations over the last nine years, apart from a spike in the data for Constanta in 2005 and 2000-2001. This could have been caused by periods of increased aridity. Alternatively, there may have been a local source of dust that skewed the data.

Table 5.6 Sediment dust monitoring results for the region

Year Average Maximum Minimum Exceedances Total monthly concentration Concentration frequency number concentration g/sqm/month g/sqm/month % of g/sqm/month samples 2000 8,61 29,51 0,8 11,76 17 2001 27,30 647 1,75 13,75 80 2002 12,47 167 0,9 13,01 123 2003 17,15 162 1 16,84 95 2004 19,39 241 0,4 79 100 2005 87,27 4459 0,79 24,21 122 2006 81,32 1892 0,046 36,05 147 2007 30,13 782 0,021 35,71 140 2008 25,47 386 0,7452 22,54 142

Figure 5.1 Evolution of particulate matter concentrations during 1994-2008

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Acid Rain Baseline

Acid precipitation monitoring is conducted in Cernavoda at the Radioactivity Station. In 2008, acid precipitation (pH < 6.5) was recorded in the following months: March, June, September, November and December. These acidic conditions were characterised by a reduced total ionic content (conductivity under 100 mS/cm), and the acid characteristics were reflected in the increased

acid gas transportation (SO2, NO2).

Table 5.7 Annual averages for acid precipitation indicator parameters

- + 2- Year pH Cond. S.T.D Cl NH4 SO4 Pb Cd Zn Alc./acid μS/cm mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l 2005 7,04 98,65 57,94 8,58 0,34 10,44 0,013 0,0002 0,019 0,40 2006 6,97 128,47 65,1 16,94 0,28 13,68 0,007 0,002 0,039 0,81 2007 6,40 85,55 43,01 12,12 0,27 6,43 0,040 0,17 0,030 0,66 2008 6,26 65,87 31,42 17,28 2,98 19,3 0,0009 - 0,070 7,71

5.5 CONSTRUCTION IMPACTS

5.5.1 Introduction

During the 18-month construction period air emissions will consist of dust generated from construction activities (e.g. land moving, dust from construction vehicles) and combustion related emissions from vehicles and construction equipment visiting the site.

5.5.2 Dust from Construction Traffic

If unmitigated, dust from construction sites can cause impacts on neighbouring properties and vegetation by causing soiling and blanketing of plant surfaces. In extreme cases, it can also cause respiratory problems through inhalation.

Dust can become airborne due to the action of winds on material stockpiles and other dusty surfaces, or when thrown up by mechanical action, for example the movement of tyres on a dusty road or activities such as sanding or drilling.

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The quantity of dust released during construction depends on a number of factors, including:

• the type of construction activities occurring (e.g. crushing and grinding); • the climate conditions (e.g. humidity); • the volume of material being moved; • the area of exposed materials; • the moisture and silt content of the materials; • distances travelled on unpaved surfaces; and • the mitigation measures employed. There are many types of particulate matter that are included in the definition of dust, varying in size and chemical composition. Dust released by construction usually has a broad size distribution but low compositional variability, being mainly soil-based. The size of dust particles will determine how long they remain airborne.

Large particles (i.e. greater than 100 μm in diameter) are likely to settle within 6 m to 10 m of their source under a typical mean wind speed of 4 m s-1, and particles between 30 μm and 100 μm diameter are likely to settle within 100 m. Smaller particles, particularly those below 10 μm in diameter, can be transported further from their source. These particles can be small enough to be inhaled deep into the lungs and cause respiratory illness.

Dust emissions are exacerbated by dry weather and high wind speeds. The impact of dust emissions also depends on the wind direction and the relative locations of dust sources and receptors.

As part of this project, there will be relatively small areas of ground breaking or disturbance to land, relative to the site as a whole. Based on this, it is not anticipated that significant adverse impacts will arise. Agricultural activities presently being conducted would incorporate some soil management, such as ploughing, which would have generated dust from the area at certain times in the past. The receptors in the area would have experienced dusty episodes at these times.

The closest receptor to the wind farm is a pig farm located at 1.6 km and the nearest residential receptor is Chirnogeni village at 2.4 km. There may be minor impacts during construction of access roads but impacts to residents from dust are not anticipated to be significant. The only protected Natura 2000 ecological site within 10 kilometres is the Dumbraveni-Valea Urluia-Lacul

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Vederoasa river region. Given the relative distance to the site from proposed construction activities, approximately 8 kilometres, the likelihood of any construction dust travelling this distance is low.

To mitigate the impacts from dust, suitable dust control measures will be employed. These measures will be detailed in the site Construction Method Statement and are discussed in Section 5.5.4.

5.5.3 Combustion Emissions from Traffic

Construction of the wind farm has an assumed worst-case peak of approximately 772 one-way truck movements and 600 one-way car movements per month. Based on the construction schedule calculation a 6-day working week, it is estimated that there will be a worst-case peak of approximately 58 two-way truck movements per working day. Based on the same calculation methodology, it is assumed that there will be 44 two-way car movements per day, which is estimated to remain unchanged throughout the entire 18-month construction period.

The preferred access route to the site will be along DN 38 and Dc 16 to Chirnogeni village, with a total distance of 68 km. If we assume all vehicles will travel this route, we can estimate total emissions from construction traffic using EC standard vehicle emission limits as follows:

Emissions = Emission Limit * Route distance

where:

2.72 g CO/km and 1.0 g NOx/km are the emission limits assuming compliance with EU Directive 91/441/EEC for petrol engines;

4.00 g CO/km and 2.00 g NOx/km are the emission limits assuming compliance with EU Directive 1999/96/EC for ETC vehicles used for the carriage of goods and exceeding 3.5 tonnes laden; and

the route distance is 68 km.

With these assumptions, the daily regional CO emissions during the construction phase will be 16.3 kg/day from passenger vehicles and 31.6

kg/day for heavy goods vehicles. For NOx, the daily emissions will be 6 kg/day from passenger vehicles and 15.8 kg/day. Note that impacts from CO

and NOx were evaluated because these are the pollutants with the largest emission rates from vehicle combustion.

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As these impacts will be distributed across the travel route, and are not large in nature, these impacts will not likely impact regional air quality. They will also be offset by the significant emission reduction benefits for these pollutants achieved during the operational phase. As such, a more refined evaluation of these impacts is not considered necessary.

5.5.4 Dust Mitigation

Although significant impacts from dust are not expected to arise, the following measures will nevertheless be adopted during construction:

• water suppression or dust extraction equipment will be fitted to drilling and grinding equipment where necessary; • measures will be taken to prevent the deposit of mud and dirt on public roads; • containers for dusty materials will be enclosed or covered by suitable tarpaulins / nets to prevent escape of dust during loading and transfer from site; • lorries carrying dusty materials to or from the site will be sheeted; • speed limits will be set to minimise disturbance to exposed running tracks; • all measures will be contained within the Construction Method Statement.

5.6 OPERATIONAL IMPACTS

5.6.1 Potential Impacts

During operation, the wind farm will not have any source of pollution, so no pollutants will be released into atmosphere. The traffic associated with the operational phase of the wind farm is estimated to be limited to approximately 4 light vehicle movements per week associated with scheduled maintenance activities and unscheduled visits for trouble shooting and repairs. Consequently, it can be concluded that the operational traffic impacts associated to the wind farm will be insignificant.

As a positive impact, the wind farm will ensure a decrease of carbon dioxide

(CO2), sulphur dioxide (SO2) and nitrogen oxides (NOx) emissions as is it showed in Section 5.7.

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5.6.2 Mitigation

No mitigation measure is required during operation of the wind farm.

5.7 REDUCING THE IMPACTS OF OTHER ENERGY PRODUCTION

5.7.1 Avoidance of Emissions

Every unit of electricity produced by wind power has the potential to replace a unit of electricity generated by other means. As such, wind farm development reduces greenhouse gas emissions and other emissions, which can cause regional and local air pollution (mainly sulphur and nitrogen oxides). On the basis of the measured onsite wind data and long term wind statistics, Cube Engineering(27) has calculated that approximately 80 MW of electricity will be produced annually by the Chirnogeni Wind Farm. The Project will produce approximately 224 million units of electricity annually which will be sufficient to supply the average domestic needs of approximately 48,000 homes.

The electricity potentially replaced by wind farm generation would typically have been supplied by coal-fired or other fossil-fuelled plants. According to the annual report performed by Romanian Energy Regulatory Authority (ANRE) in 2008, the average of the carbon dioxide released from the activities of the energy producers in Romania was 496 grams of carbon dioxide for every unit of electricity (kilowatt hour). Carbon dioxide is an important greenhouse gas implicated in climate change. The generation of power from fossil fuels also emits sulphur dioxide and nitrogen oxides, both causes of acid rain and local air pollution.

To ensure that the positive environmental aspects of Chirnogeni Wind Farm are recognised, the reductions in emissions brought about by the development of the project are presented below.

(27) Cube Engineering GmbH: http://www.cube-engineering.com/en/index1.php?mt=1&st=1

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5.7.2 Impact Assessment

The potential reduction in carbon dioxide (CO2), sulphur dioxide (SO2) and nitrogen oxides (NOx) emissions as a result of operating a 80 MWh wind farm for one year and over a lifetime of 20 years can be estimated using the following formula and are presented in Table 5.8:

CO2 (in tonnes)= (A x 0.3 x 8760 x B)/1000

where:

A = the rated capacity of the wind energy development in MW;

0.3 is a constant, the capacity factor, which takes into account the intermittent nature of the wind, the availability of the wind turbines and array losses;

8760 is the number of hours in a year; and

B = 496 kWh, local factor for carbon dioxide from every unit of electricity.

Table 5.8 Estimated Emissions to Atmosphere Avoided

Pollutant Annual Emission Total Emission Reduction Reduction (25 years) (tones) (tones)

Carbon dioxide (CO2) 104,279 2,606,975

Sulphur dioxide (SO2) 2,100 52,500

Oxides of nitrogen (NOx) 630 15,750 Source: www.bwea.com/edu/calcs.html (Calculated in July 2009)

In addition to benefits from the overall emissions reductions, sulphur dioxide and oxides of nitrogen also contribute to acid deposition. By reducing the regional emissions of these pollutants, impacts from acid precipitation can also be reduced.

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6 NOISE AND VIBRATION

6.1 INTRODUCTION AND SCOPE

This Assessment considers potential noise impacts from the construction and operation of the proposed Chirnogeni wind farm. There are a small number of residential properties in the area whose occupants will be sensitive to noise impacts during the construction and operation of the wind farm. The project also has the potential to change road traffic patterns and hence noise emissions, particularly construction, which may also create traffic noise impacts.

The methodology, criteria and results discussed within this document should be considered as indicative only, and are subject to change as work progresses. The final results will be presented in the Environmental Statement.

6.2 METHODOLOGY

6.2.1 Noise Standards

The significance of operational noise is evaluated by reference to the Romanian Ministerial Order 152/2008 for the approval of the Guideline regarding

the adoption of limit values for indicators Lden and Lnight in case of noise generated by road traffic). The maximum permissible limits for different types of areas are given in Table 6.1 below.

Table 6.1 Romanian Noise Level Limits

Permissible limits for noise levels LAeq (dB) Zone Day Evening Night 7am-6pm 6pm-10pm 10pm-7am Residential 55 - 50 Industrial 60 - 50

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However, the standards in Table 6.1 are not strictly applicable for noise from wind turbines. Guidance from the IFC(28)suggests that noise impacts should not exceed the levels presented in the Table 6.2, nor result in a maximum increase in background levels of 3 dB at the nearest receptor location

Table 6.2 IFC Noise Standards

Permissible limits for noise levels LAeq (dB) Zone Day 7am-10 pm Night 10pm-7am Residential, institutional and 55 45 educational Industrial and Commercial 70 70 Source: IFC General Environmental, Health & Safety Guidelines 2007

Noise generated from wind turbines tends to increase with the speed of the wind, as does overall background. Increased wind speeds may also mask the noise emitted by the wind farm itself, and wind speed and direction may affect the direction and extent of noise propagation. The IFC guidelines suggest that the assessment of background noise levels should therefore take these factors into consideration.

6.2.2 Evaluation of Impact Significance

In the absence of suitable Romanian national guidance on the assessment of wind turbine noise, guidance recommended by planning policy in the United Kingdom has been adopted as best practice. Noise from wind turbines will therefore take this, and the IFC noise standards into account in assessing potential noise impacts from wind turbines.

(28) International Finance Corporation. Environmental, Health, and Safety Guidelines: ‘Wind Energy’. April 30, 2007

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Operational Noise Criteria

Operational noise impacts are assessed following the ETSU guidance(29) that recommends a methodology for measuring prevailing background noise at a wind farm site and for defining operational noise thresholds which can be used to identify significant adverse impacts. The recommendations made in the ETSU Guidance are as follows.

• ”The current practice on controlling wind farm noise by the application of noise limits at the nearest noise-sensitive properties in the most appropriate approach.” • “Noise limits should be applied to external locations and should apply only to those areas frequently used for relaxation or activities for which a quiet environment is highly desirable.” • “Noise limits set relative to the background noise are more appropriate in the majority of cases. Generally, the noise limits should be set relative to the existing background noise at the nearest noise-sensitive properties and the limits should reflect the variation in both turbine source noise and background noise with wind speed.” • “It is not necessary to use a margin above background noise levels in particularly quiet areas. This would unduly restrict developments that are recognised as having wider national and global benefits. Such low limits are, in any event, not necessary in order to offer a reasonable degree of protection to wind farm neighbours.” • “Separate noise limits should apply for day-time and for night-time as during the night the protection of external amenity becomes less important and the emphasis should be on preventing sleep disturbance.” • “Absolute noise limits and margins above background should relate to the cumulative effect of all wind turbines in the area contributing to the noise received at the properties in question. Any existing turbines should not be considered as part of the prevailing background noise.”

(29) The Assessment and Rating of Noise from Wind Farms (ETSU-R-97), ETSU for the DTI, 1996.

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• “Noise from the wind farm should be limited to 5 dB(A) above background for both day- and night-time, remembering that the background level of each period may be different.”

• “The LA90, 10min descriptor should be used for both the background noise and the

wind farm noise, and when setting limits it should be borne in mind that the LA90,

10min of the wind farm is likely to be about 1.5 – 2.5 dB(A) less than the LAeq

measured over the same period. The use of the LA90, 10min descriptor for wind farm noise allows reliable measurements to be made without corruption from relatively loud, transitory noise events from other sources.” • “A fixed limit of 43 dB(A) is recommended for night-time. This is based on a sleep disturbance criteria of 35 dB(A) with an allowance of 10 dB(A) for attenuation through an open window (free field to internal) and 2 dB(A) subtracted to account

for the use of a LA90, 10min rather than LAeq, 10min.” • “Both day- and night-time lower fixed limits can be increased to 45 dB(A) to increase the permissible margin above background where the occupier of the property has some financial interest in the wind farm.”

• “In low noise environments the day-time level of the LA90, 10min of the wind farm should be limited to an absolute level within the range of 35-40 dB(A). The actual value chosen within this range should depend upon: the number of dwellings in the neighbourhood of the wind farm, the effect of noise limits on the number of kWh generated, and the duration of the level of exposure.” • “For single turbines or wind farms with very large separation distances between the turbines and the nearest properties, a simplified noise condition may be

suitable. If the noise is limited to a LA90, 10min of 35 dB(A) up to wind speeds of 10m/s at 10 m height, then this condition alone would offer sufficient protection of amenity, and background noise surveys would be unnecessary.” The recommended absolute noise levels proposed by the ETSU Guidance cover two time periods.

• The quiet daytime period (defined as between 1800 and 2300 hours from Monday to Friday, between 1300 and 1800 hours on a Saturday and all day during Sunday, 0700 to 1800 hours). • The night-time period (defined as between 2300 and 0700). The noise thresholds recommended by the ETSU Guidance address external and internal noise levels in residential properties and include levels for daytime and night-time when noise disturbance inside dwellings is critical. They are specified as free-field noise levels in external locations (e.g. gardens). Daytime levels are set based on maintaining enjoyment of external domestic locations. During the night, it is reasonable to expect most people to be indoors and so the level inside dwellings will be lower than outside as a result

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of attenuation through the building fabric. Hence the external night time thresholds are higher than those for quiet daytime. However, the external night-time thresholds offer a good degree of protection against sleep disturbance due to attenuation of noise from outside to inside (at least 10 dB can be achieved with a partially opened window).

The ETSU Guidance advises that noise from a wind farm should not exceed either specified absolute levels or 5 dB above the prevailing background noise level, whichever is the higher. The noise limits suggested by the ETSU Guidance are shown in Table 6.3.

Table 6.3 ETSU Noise Limits dB LA90, 10 minutes External Free-field

Time Absolute Limits dB(A) Relative Limits Quiet daytime periods 35 to 40 Prevailing background noise plus 5 dB Night 43 Prevailing background noise plus 5 dB

It is considered by the ETSU Guidance that daytime limits within the range of

35 to 40 dB LA90,10 min offer a reasonable degree of protection to wind farm neighbours without placing unreasonable restrictions on wind farm development. The actual value chosen for the day-time lower limit will depend upon a number of factors such as the number of dwellings in the neighbourhood of the wind farm, the effect of noise levels on the number of kWhs generated and the proportion of time for which the noise levels are low.

The ESTU Guidance suggests that ‘For single turbines or wind farms with very large separation distances between the turbines and the nearest properties, a simplified

noise condition may be suitable. If the noise is limited to a LA90, 10min of 35 dB(A) up to wind speeds of 10m/s at 10 m height, then this condition alone would offer sufficient protection of amenity, and background noise surveys would be necessary.’

In the case of Chirnogeni Project, 35 dB(A) is considered to be an appropriate absolute limit for daytime, taking into account the size of the proposed development (32 Nordex N90/2500) and all properties located more than 2.7 km from the outermost turbines.

Construction Noise

There are no national or international standards for noise from temporary sources such as construction but best practice is that noise levels should not

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exceed 70 dB at the nearest receptor for daytime construction activities. Noise in excess of this level would constitute a significant impact.

BS 5228(30) provides a database of noise emission levels from construction plant and offers a method of calculating noise from construction. This guidance also suggests mitigation measures to minimise the impact of noise from construction. The calculation methodology in this guidance will be drawn upon to predict noise from construction.

Road Traffic Noise

Transportation noise impacts resulting from the operation of the proposed project will be permanent.

The road traffic noise assessment has taken into consideration the following guidance as appropriate:

• DMRB(31) to identify where changes in road traffic will require a more detailed assessment; and • CRTN(32) to predict the actual change in road traffic noise as a result of the project. DMRB states that an increase in traffic flow of 25% (or reduction by 20%) is generally needed to increase (respectively decrease) noise levels by 1 dB(A). A change of 1 dB(A) is only perceptible in controlled conditions, and a change of 3 dB(A) is generally accepted as the minimum perceptible under normal conditions. For heavy goods vehicles an increase of around 5% is generally needed to increase noise levels by 1 dB(A).

(30) British Standard BS 5228: 2009 'Code of practice for noise and vibration control on construction and open sites'.

(31) Design Manual for Roads and Bridges (1994), Volume 11, Section 3, Part 7 '’Traffic Noise and Vibration’, August 1994

(32) Department of Transport / Welsh Office. HMSO (1998) ‘Calculation of Road Traffic Noise’

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Flow changes of this size are not expected to give rise to perceptible noise changes under normal listening conditions and have been adopted as the scoping criterion for road traffic noise.

Changes in environmental noise of less than about 3 dB are generally not noticed in typical situations such as when noise sensitive receptors next to a road are subject to noise increases. If other factors change the character of the noise smaller changes can create significant effects and other factors should be considered, but for road traffic noise in this case it is considered that only noise changes greater than 3 dB would be significant for the purposes of this ESIA.

6.2.3 Operational Noise Prediction Model

The noise predictions were carried out under worst-case down wind propagation conditions as described in ISO 9613-2(33). This standard specifies a method for calculating the attenuation of sound during propagation outdoors in order to predict level of environmental noise at a distance for a variety of noise sources. The method predicts the equivalent continuous A-weighted

sound pressure level (the LAeq) under meteorological conditions favourable to propagation from sources of known sound emission.

The sound power levels of the wind turbines used as a basis of the assessment are also measured under down-wind conditions. In undertaking predictions of noise levels from wind farms using the calculation procedure outlined in ISO 9613-2 the following factors have been considered:

• the decrease in sound energy with distance; • the absorption of sound energy in air; • the attenuation of sound energy by passage over acoustically “soft” ground; • screening of the turbines by topography and other obstacles; and

(33) ISO 9613-2 ‘Acoustics - Attenuation of Sound During Propagation Outdoors. Part 2: General Method of Calculation’. ISO, 1996.

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• meteorological conditions. The calculation took account of the sound power level (in octave bands between 63Hz and 8KHz) of a turbine; applied a correction for air absorption, and calculated the noise level (in octave bands between 63Hz and 8Khz) from each of the 32 wind turbines at the closest villages. The calculated noise level from each turbine was then summed to give the predicted noise level from the scheme at each of the closest villages.

For the purpose of the modelling, the conditions are assumed to be 10°C and 70% humidity, no acoustic screening of the turbines and no attenuation from ground absorption to present a worst-case assumption.

6.3 BASELINE ENVIRONMENT

The area studied for the proposed wind farm project is located in the unincorporated fields of Chirnogeni and Independenta Communes.

The closest site neighbours to the site boundary are listed in Table 6.4 below. A site location plan is given in Figure 6.1 and some photographs of the site in Figure 6.2.

Table 6.4 Site Neighbours

Locality Approximate distance Orientation from the site boundary* Viroaga 3.7 km Southwest Chirnogeni 2.4 km East Plopeni 4.0 km North Movila Verde 5.0 km north-north-west Independenţa 5.1 km Northwest Cerchezu 6.5 km Southwest Negru Vodă 5.7 km Southeast *distances are measured from the site boundary (safety area) to the closest point of a village/town.

No baseline noise measurements for any of these communities are available. Because of the separation distance between the site boundary and the site neighbours, calculations have been undertaken at two locations at Viroaga and Chirnogeni and at one location at Plopeni which are the closest communities to the site.

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Figure 6.1 Site Location Map (Annex 1)

Chirnogeni Wind Farm

Figure 6.2 Photographs of Project Area (October 2008)

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6.4 CONSTRUCTION IMPACTS

6.4.1 Potential Impacts

Construction is anticipated to take approximately 18 months in duration, and the permitted working hours will be 0700 – 1900, Monday to Friday and 0700 – 1300 on Saturday. The main phases of construction will comprise the following:

• Phase 1: Civil works - 7 months; • Phase 2: Transportation - 9 months; • Phase 3: Electrical - 12 months; • Phase 4: Turbine installation - 10 months (including commissioning). For the purposes of the noise assessment, the main construction stages for the proposed development have been divided into civil works, turbine installation and restoration.

The precise details of the plant and equipment that will be used during construction works are not known at this stage of the Scheme. Assumptions have been made on the type and number of plant that may be working, and the duration they may be operating during a typical working day based on experience on other projects. Work associated with logistics and electrical works are not considered to have potential to cause significant noise impacts.

A reasonable worst case construction noise assessment has been carried out in accordance with the procedures outlined in the BS 5228 method for calculating construction noise. The closest site neighbour to the construction works is Chirnogeni at 2.4km (distance to approximate site boundary).

Based on the noise levels from the civil works (LWA 114.0 dB), turbine

installation (LWA 114.2 dB) and restoration (LWA 113.8 dB), calculated noise level at Chirnogeni will be up to 42 dB(A). This is below the 70 dB(A) criterion applied to construction noise.

Construction will be sufficiently distant from dwellings to avoid noise impacts on residents although there will be short term disturbance for walkers in the general vicinity.

Construction traffic has been discussed in Chapter 7of this ESIA. During the worst case period, there will be up to 58 heavy vehicle movements per day and up to 44 light vehicle movements.

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Baseline traffic levels on the three potential routes (discussed in Chapter 7) are given below.

Route 1

• DN38: 4,371 vehicles between 0800 and 1800, 639 (14.6%) of which were heavy vehicles. • Dc16: No data available. • This is an average of 437 vehicles per hour. Route 2

• DN38 to junction with DJ392: 4,371 vehicles between 0800 and 1800, 639 (14.6%) of which were heavy vehicles. • This is an average of 437 vehicles per hour. Route 3

• DN38 to DJ391: 3,763 vehicles between 0800 and 1800, 570 (15.1%) of which were heavy vehicles. • DJ391 to DJ392: 200 vehicles between 0800 and 1800, 40 (20%) of which were heavy vehicles. • DJ392 to Dc016: No data available. • This is an average of 396 vehicles per hour. During the worst-case period during which up to 58 heavy vehicle movements per day and up to 44 light vehicle movements will take place each day, road traffic noise level will increase by up to 2 dB(A). This change is not considered significant.

6.5 OPERATIONAL IMPACTS

6.5.1 Potential Impacts from Wind Turbine Noise

The scheme will involve the installation of thirty two Nordex N90 wind turbines (with a power of 2.5 MW each and a hub height of 100 m). The warranted sound power levels for the Nordex N90 wind turbine are presented in Table 6.5 below.

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Table 6.5 Noise Emission Nordex N90/2500 LS Warranty levels according to IEC 61400- 11:2002 Hub height: 90 m - 105 m

Standardised wind Speed at 10m (m/s) Sound Power Level (LWA), dB 3 95.5 4 99.0 5 101.5 6 103.0 7 104.0 8 104.5 9 104.8 10 105.0 11 105.0 12 105.0

Table 6.6 below presents the rated sound power level of the Nordex N60 over all speeds. Because data from the larger Nordex N90 is not available, a correction factor of +2dB has been applied to ensure that the data from the Nordex N60 meets the warranted sound power level of 105 dB(A) at 10 m/s for the Nordex N90. This follows the ETSU Guidance which suggests that: ‘If

the noise is limited to a LA90, 10min of 35 dB(A) up to wind speeds of 10m/s at 10 m height, then this condition alone would offer sufficient protection of amenity.’

Table 6.6 Octave Band Sound Power Levels from Nordex N60 (Corrected for Nordex N90 Warranted Sound Power Level)

Frequency (Hz) A-weighted sound power +2 dB correction for level (dB) for Nordex N60 Nordex N90 (dB) 63 62.6 64.6 125 77.1 79.1 250 85.9 87.9 500 93.7 95.7 1000 98.6 100.6 2000 99.5 101.5 4000 94.3 96.3 8000 79.8 81.8

Rated Level (LWA) 103.4 105.4

The assessment was undertaken using the turbine locations shown in Figure 6.1. The location references and elevations of the turbines are identified inTable 6.7 below.

Table 6.7 Turbine Locations

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Turbine Reference Eastings (m) Northings (m) Elevation (m) T1 752924.47 269709.72 152.00 T2 752489.92 270099.05 148.00 T3 753475.95 269803.36 157.00 T4 753099.68 270113.81 154.00 T5 752789.30 270592.85 158.00 T6 752423.00 270951.00 157.00 T7 752092.93 271342.43 146.00 T8 753941.75 269812.62 156.00 T9 753262.31 270862.99 155.00 T10 752740.49 271463.44 155.00 T11 752390.00 271779.00 154.00 T12 751993.71 272031.52 150.00 T13 754281.03 270815.07 154.00 T14 753929.80 271168.24 150.00 T15 753341.12 271327.47 153.00 T16 753136.91 271766.02 156.00 T17 754148.51 271396.39 156.00 T18 754408.94 271965.21 148.00 T19 753875.26 272087.55 141.00 T20 753393.92 272426.27 146.00 T21 753938.62 270757.84 154.00 T22 755955.76 271366.99 138.00 T23 755968.17 270972.61 142.00 T24 755335.33 270620.40 142.00 T25 755347.85 270262.27 148.00 T26 755704.31 270522.73 146.00 T27 756392.96 270622.84 145.00 T28 756403.73 270287.55 143.00 T29 755322.39 269505.12 151.00 T30 755348.99 269038.33 148.00 T31 756510.08 269585.16 138.00 T32 756522.71 269098.64 138.00

6.5.2 Results of Wind Turbine Noise Predictions

The noise level contribution from each of the turbines was predicted at the closest residential locations in accordance with ISO 9613 (assuming 10°C and 70% humidity) as described in Section 6.2.3. A summary of the predicted noise levels for the five closest locations (two in Chirnogeni and Viroaga and one in Plopeni) are presented in Table 6.8 below.

Table 6.8 Summary of Predicted Noise Levels

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Receptor Easting Northing Elevation Closest LA90, 10-min Turbine * (dB) Chirnogeni 1 759074.88 271279.32 121 T27 (2750m) 24 Chirnogeni 2 758860.56 271943.73 114 T27 (2800m) 24 Plopeni 755388.47 276444.59 103 T20 (4500m) 18 Viroaga 1 749365.89 267550.03 158 T2 (4050m) 19 Viroaga 2 748508.59 268943.16 128 T2 (4150m) 19 *Distances are rounded to the nearest 50m

The results of the assessment indicate noise levels from the development will be up to LA90 24 dB at Chirnogeni, some 2.4 km from the site boundary. This is significantly below the ETSU LA90 35 dB threshold and the IFC Guideline noise levels presented in Table 6.1. Noise levels at other locations further away from the site will be lower. Operational noise impacts are therefore not expected.

The predicted noise level from each individual wind turbine generator at the five assessment locations are presented in Table 6.9 below.

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Table 6.9 Calculated Noise Level of Each Turbine at the Closest Noise Sensitive Villages

Turbine Chirogeni 1 Chirogeni 2 Viroaga 1 Viroaga 2 Plopeni LA90, 10- Distance LA90, 10- Distance LA90, 10- Distance LA90, 10- Distance LA90, 10- Distance min (dB) to turbine min (dB) to turbine min (dB) to turbine min (dB) to turbine min (dB) to turbine (m) (m) (m) (m) (m) T1 < 1 6349 < 1 6344 8.5 4164 7.2 4484 0 7173 T2 0 6691 0 6634 9.1 4033 8.6 4147 0 6978 T3 2.5 5792 2.4 5796 6.4 4688 5.0 5043 0 6913 T4 1.5 6089 1.6 6046 7.0 4530 6.2 4740 0 6734 T5 < 1 6480 < 1 6374 7.3 4466 7.3 4444 < 1 6469 T6 0 6659 < 1 6504 6.6 4636 7.4 4439 1.2 6171 T7 0 6989 0 6794 6.2 4724 7.7 4349 1.7 6022 T8 4.0 5340 3.9 5363 4.8 5106 3.4 5504 0 6790 T9 2.3 5829 2.7 5703 4.8 5115 4.7 5128 1.9 5975 T10 < 1 6338 1.3 6141 4.6 5168 5.5 4927 2.9 5643 T11 0 6705 < 1 6474 4.5 5200 5.9 4809 3.3 5548 T12 0 7122 0 6869 4.5 5196 6.5 4658 3.2 5570 T13 1.4 6118 1.7 6018 6.2 4743 6.0 4785 < 1 6317 T14 4.7 5151 5.2 5008 2.5 5770 2.3 5828 3.2 5562 T15 2.8 5696 3.4 5516 3.4 5514 3.7 5426 3.4 5497 T16 1.9 5959 2.7 5728 2.9 5657 3.7 5423 4.5 5194 T17 5.3 4969 6.1 4770 1.2 6178 1.3 6162 4.8 5106 T18 6.3 4718 7.3 4454 0 6703 0 6630 6.8 4588 T19 4.3 5263 5.2 4989 < 1 6398 1.1 6221 6.7 4614

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Chirogeni 1 Chirogeni 2 Viroaga 1 Viroaga 2 Plopeni T20 2.4 5797 3.5 5489 < 1 6325 1.8 6001 7.2 4488 T21 5.9 4818 6.3 4719 2.1 5901 1.6 6069 2.6 5740 T22 13.4 3123 14.2 2964 0 7616 0 7832 4.8 5111 T23 13.4 3124 13.8 3054 0 7437 0 7732 3.4 5504 T24 10.1 3799 10.2 3768 0 6713 0 7031 2.3 5826 T25 9.8 3865 9.7 3897 0 6569 0 6966 1.2 6184 T26 11.7 3457 11.7 3464 0 7001 0 7368 2.0 5932 T27 15.4 2759 15.2 2792 0 7679 0 8067 2.1 5888 T28 14.9 2852 14.2 2966 0 7552 0 8010 1.0 6242 T29 8.5 4153 7.9 4299 < 1 6270 0 6838 0 6941 T30 7.7 4350 6.9 4560 1.3 6166 0 6842 0 7408 T31 13.6 3076 12.3 3332 0 7429 0 8028 0 6952 T32 12.2 3359 10.6 3484 0 7323 0 8016 0 7434

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6.5.3 Operational Vibration and Low Frequency Noise / Infrasound

Wind turbines are not typically a source of vibration and no vibration impacts are expected during operation. The nearest residential receptor, Chirogeni is approximately 2.4 km from the site boundary. A comprehensive study of vibration measurements in the vicinity of a modern wind farm undertaken in 1997(34) found that vibration levels 100 m from the nearest turbine were a factor of 10 less than those recommended for human exposure in critical buildings such as laboratories housing precision measurement instruments.

Comprehensive research on low frequency noise has been published by DEFRA(35). There are no direct health effects from noise at the level of noise generated by wind turbines. It has been repeatedly shown by measurements of wind turbine noise undertaken in the UK, Denmark, Germany and the USA over the past decade, and accepted by experienced noise professionals, that the levels of infrasonic noise and vibration radiated from modern, upwind configuration wind turbines are at a very low level; so low that they lie below the threshold of perception, even for those people who are particularly sensitive to such noise, and even on an actual wind turbine site. In response to concerns that wind turbines emit infrasound and cause associated health problems. Dr Geoff Leventhall, author of the DEFRA Report says:

‘I can state quite categorically that there is no significant infrasound from current designs of wind turbines.’(36)

Wind shear is a measure of how much wind speed increases with height. The methodology used to assess noise from wind farm sites is based on the use of wind speed measurements at a reference height of 10 metres, based on the turbine noise data at 10 metres height at varying wind speeds.

(34) ETSU W/13/00392/REP 'Low frequency noise and vibrations measurement at a modern wind far'. Department of Trade and Industry, 1997.

(35) "A Review of Published Research on Low Frequency Noise and its Effects" Report for DEFRA by Dr Geoff Leventhall Assisted by Dr Peter Pelmear and Dr Stephen Benton. May 2003

(36) http://www.bwea.com/ref/lowfrequencynoise.html

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For very stable atmospheric conditions, which may occur at night, hub height wind speed may be substantially increased over that which is expected from consideration of ground roughness alone, leading to higher source noise levels for specific 10 metre height wind speeds than for standardised conditions.

Although there is no evidence to suggest that stable atmospheric conditions may occur, the effect is highly unlikely to increase wind turbine noise above the relevant criteria given that predicted wind turbine noise is significantly below the relevant criteria at the closest site neighbour.

6.5.4 Results of Road Traffic Noise Assessment

During operation the vehicle movements to the site is estimated to be 4 light vehicle movements (8 trips) per week, as a worst case scenario. Given the existing levels of road traffic (see Section 6.4), road traffic noise from operation is not considered significant.

6.6 MITIGATION

No operational noise impacts have been identified in accordance with the assessment methodology outlined in the ETSU Guidance. Full consideration of potential noise impacts from the siting of the wind turbines was taken into account during the layout design, and any additional mitigation measures beyond site best practice are not required.

6.6.1 Mitigation during Construction

A reasonable worst case construction noise assessment has been carried out in accordance with the procedures outlined in BS 5228. The assessment considered potential noise from civil works, turbine installation and restoration where the calculated noise level at the closest site neighbour (Chirnogeni, 2.4 km from the site boundary) was up to 42 dB(A); well below the 70 dB(A) criterion.

Construction will be sufficiently distant from dwellings to avoid noise impacts on residents.

6.7 ASSESSMENT OF RESIDUAL IMPACTS

There are no other wind farms in close proximity to this development, and no residual noise impacts have been identified.

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6.8 SUMMARY

This assessment has considered the potential for noise impacts resulting from the construction and operation of the proposed scheme. The assessment of noise from wind turbines was undertaken following the United Kingdom ETSU guidance which offers best practice guidance for defining operational noise thresholds which can be used to identify significant adverse impacts. The noise predictions were carried out under worst-case down wind propagation conditions as described in ISO 9613.

In summary, operational noise from the scheme will be below the appropriate ETSU criteria at all locations and there will be no significant impacts on the closest site neighbours.

Noise from construction was assessed using the British Standard BS 5228. The proposed site is relatively remote from noise sensitive receptors and no noise impacts during construction were identified.

No noise impacts from traffic associated with the construction and operation of the scheme were identified.

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7 TRAFFIC AND TRANSPORT

7.1 INTRODUCTION AND SCOPE

This chapter of the ESIA assesses the impact of the traffic that is expected to be generated by the Project on local traffic and roads. This includes consideration of the major and minor roads, as well as farm access tracks. Accidents and safety are also discussed.

The traffic associated with the operation of the wind farm is considered to be minor as the wind farm will be remotely controlled and site visits will be made only for scheduled maintenance or repair works. Consequently, this assessment focuses only on the construction traffic.

7.2 METHODOLOGY

7.2.1 Sources of Information

The assessment was conducted based on publicly available data, road maps and the 2007 local traffic data made available by the Constanta County Roads and Bridges Autonomous Administration for the following local roads what lead to the project area:

• National Road DN 38 Constanţa – Negru Vodă – border to Bulgaria; • County Road DJ 391: DN 39-Albeşti-Cotu Văii-Negru Vodă-Cerchezu- Viroaga-Negreşti--Ciobăniţa-Osmancea-Mereni-- Biruinţa-Tuzla; and • County Road DJ 392: Mangalia-Pecineaga--General Scărişoreanu- Plopeni-Movila Verde-Independenţa-Dumbrăveni. The assessment took into account the information provided during preliminary consultation with the Constanta County Roads and Bridges Autonomous Administration and the local road conditions as observed during the several field trips made to the site area in November 2008, March and May 2009.

7.2.2 Assessment Methodology

The impact of traffic is dependant upon a wide range of factors which include:

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• the volume of traffic; • traffic operational characteristics; and • traffic composition (e.g. percentage of HGVs). In the absence of any specific Romanian guidelines in assessing impacts to traffic and transport, the UK guidelines such as Institute of Environmental Management and Assessment (IEMA) guidelines(37) are referred to. These guidelines state that in order to assess the traffic impact the volume of vehicle trips related to the development must be identified and set within the context of existing traffic movements in the locality.

The Institution of Highways and Transportation (IHT)(38) suggests that significant impacts to highway capacity may occur if:

• peak hour traffic flow increases by more than 10%; or • peak hour traffic flow increases by more than 5% (where the network is sensitive). These guidelines are useful in determining the scope for highway capacity impacts. Although the above criteria are used for assessing the long term traffic impacts, they are used for the assessment of the impacts of construction traffic. Impacts from traffic flow are described as being of minor, moderate or major significance as follows:

• 1 - 30% changes in traffic levels are considered as a minor adverse impact; • 30 - 60% changes in traffic levels are considered as a moderate adverse impact; and • 60 - 90% changes in traffic levels are considered as major adverse impact respectively.

(37) Institute of Environmental Assessment (1993) Guidelines for Environmental. Assessment of Road Traffic, Guidance Notes No 1, IEA

(38) Ministry of Transport Manual of Environmental Appraisal, Part B, Section 4, 1983.

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In the absence of criteria specifically for the assessment of construction traffic impacts on traffic conditions, a common sense approach and professional judgement is used to identify whether or not an impact may occur. These criteria are not prescriptive and consideration needs to be given to local conditions.

7.3 CONSTRUCTION ACCESS ROUTE

7.3.1 Introduction

Figure 7.1 below (Annex 3 – Road map in Constanta County) shows the main roads in southeast Constanta County(39). Construction traffic will access the site via national road (DN 38) which is a surfaced road in good condition, followed by either county road DJ391/DJ392 or Commune Road Dc16. The final route will be discussed and agreed in consultation with Constanta County Council and the National Highway and Roads Company prior to construction. Based on the preliminary consultation with the Constanta County Roads and Bridges Autonomous Administration, national and county roads are suitable for abnormal loads.

Road widening and upgrade may be necessary along commune roads (Dc16) and farm access tracks. This will be agreed with the Local Mayoralties. Permits for the transportation of abnormal loads will be required from the following authorities:

• National Highway and Roads Company in Romania for national roads such as DN 38 Constanta - Negru Voda; • Constanta County Roads and Bridges Autonomous Administration for county roads such as the DJ 391 or DJ 392; and • Commune Mayoralties for commune roads such as Dc 16 to Chirnogeni commune.

(39) http://www.cjc.ro/drumuri_jud/Harta/harta.html

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Figure 7.1 Road Map of Southeast Constanta County (see Annex 3)

Source: Website of Constanta County Council http://www.rajdpct.ro/

Key:

National roads

Asphalted county roads

County roads with gravel Dirt county roads

Asphalted commune roads Commune roads with gravel

Dirt commune roads

7.3.2 Baseline Traffic Flows

The traffic data presented below were the most recent gathered from Constanta County Roads and Bridges Autonomous Administration for national and county roads DN 38, DJ 391 and DJ 392 in July 2007 (Table 7.1). No monitoring is undertaken for commune roads (such as Dc16).

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Table 7.1 Baseline Traffic Flows near the Project Site (1-way)

DN 38 Topraisar and South (towards Negru North (towards Totals Negru Voda Voda) Topraisar) Passenger vehicles 218 192 410 Light trucks 43 47 90 Passenger minibuses 19 13 32 Articulated vehicles 18 20 38 2-axle trucks 4 6 10 3 or 4-axle trucks & 4 1 5 derivatives Bikes, mopeds, 4 3 7 scooters, motorbikes Agricultural vehicles 3 5 8 Animal traction 4 3 7 vehicles Buses 1 0 1 Subtotal Light 291, (92%) 263, (91%) 554 Vehicles Subtotal Heavy 28, (8%) 27, (9%) 55 Vehicles Total per day 318 290 608

DJ391 Mangalia and East (towards Constanta) West (towards Negru Voda project site) Subtotal Light vehicles 616 (93%) 531 (93%) 1,147 Subtotal Heavy 46 (7%) 40 (7%) 86 vehicles Total per day 662 571 1,233

DJ392 (1) General East (General West (towards Scarisoreanu and Scarisoreanu) project site) Amzacea Subtotal Light vehicles 89 (90%) 92 (90%) 181 Subtotal Heavy 9 (10%) 10 (10%) 19 vehicles Total per day 98 102 200 (1) Road traffic data for the DJ 392 were only available for between General Scarisoreanu and Amzacea villages where there is the junction with DN 38 and so does not reflect accurately the situation at the project site. NOTE: The number of vehicles was recorded at 15-minute intervals between 0800 and 1800 on each road segment in both directions.

The figures presented above indicate that the traffic flows are similar in both directions. No ‘rush hour’ or busy period during the morning or afternoon is

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apparent from the raw data for the DN38. The DJ 391 (county road) near the project site showed a slight morning peak between 1030-1045 and an afternoon peak between 1530-1545. The DJ 392 (county road) shows a slight morning peak between 0845-0945 and an afternoon peak between 1515-1715.

7.4 CONSTRUCTION IMPACTS

7.4.1 Introduction

Construction of the wind farm will commence in the first quarter of 2012 and will last a period of 18 months. Construction traffic will be accessing the site as presented in Section 7.3.1.

Table 7.2 presents the anticipated peak two way vehicle movements to and from the site. Whilst it is unlikely that all these vehicles will be utilised at the same time, this number is assessed as it presents the worst case scenario.

Table 7.2 Predicted Daily Vehicle Movements during Construction

Vehicle Type Daily 2-way Peak Light Vehicles 44 (88 one-way) Heavy Vehicles 58 (116 one-way) Total Vehicles 102 (204 one-way)

The heavy vehicles identified above include the following:

• Restricted Access Vehicles (RAV) longer than 19 m or heavier than 42.5 tons. These RAV will be used to transport wind turbine components; and • Semi-trailers – used to transport pad mounted, foundation cages – resulting, reinforcing steel for foundations, transformer for the 80 MW Project substation, miscellaneous Project substation equipment, 110 kV and 20 kV cables, 110 kV structures, miscellaneous cabling items such as conductors etc, construction equipment (trenching & smaller pieces) and site establishment & disestablishment equipment. Construction hours are Monday to Friday 0700 to 1900, and 0700 to 1300 on Saturday. For the purposes of this assessment 0700 to 1900 has been assumed for Monday to Saturday. Therefore personnel will be arriving at the site between 0600 and 0700 and leaving between 1900 and 2000.

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The heavy vehicles construction flows are expected to be consistent on an hour by hour basis throughout the day. However, at the start and end of each working day there will be additional traffic comprising staff vehicles accessing and leaving the site as mentioned above. For the purposes of the assessment the following has been assumed:

• 0600 to 0700 - staff vehicles inbound; • 0700 to 0800 - construction HGVs inbound; • 0800 to 1800 - construction HGVs two-way; • 1800 to 1900 - construction HGVs outbound; and • 1900 to 2000 - staff vehicles outbound.

Table 7.3 Predicted Daily Movements during the Construction Phase as Assumed for the Assessment (expressed as 1 –way movements)

Estimated Baseline Construction Traffic % change Flow Flow DN38 0600 - 0700 60 * 44 (LV) 73% 0700 – 0800 60 10 (HV) 17% 0800 – 1800 600 100 (HV) 17% 1800 – 1900 60 10 (HV) 17% 1900 – 2000 60 44 (LV) 73% Total 204 (one-way) 102 (two-way) DJ 391 0600 - 0700 123 * 44 (LV) 36% 0700 – 0800 123 10 (HV) 8% 0800 – 1800 1,230 100 (HV) 8% 1800 – 1900 123 10 (HV) 8% 1900 – 2000 123 44 (LV) 36% Total 204 (one-way) 102 (two-way) DJ 392 0600 - 0700 20 * 44 (LV) 220% 0700 – 0800 20 10 (HV) 50% 0800 – 1800 200 100 (HV) 50% 1800 – 1900 20 10 (HV) 50% 1900 – 2000 20 44 (LV) 220% Total 204 (one-way) 102 (two-way)

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Estimated Baseline Construction Traffic % change Flow Flow *baseline traffic flow estimated as an average for each period based on the baseline data provide in Table 8.1 LV: Light Vehicles HV: Heavy Vehicles NOTE: Grey shading indicates the peak baseline traffic flow Table 7.3 above indicates that the peak construction hours (when personnel will be arriving at and leaving site) do not coincide directly with the peak baseline hours for each road assessed.

7.4.2 Potential Impacts

At this stage of the project, it is not possible to provide precise details relating to the impacts of construction traffic on individual roads within the local road network as the specific routes will be finalised in consultation with the relevant authorities. However, an assessment of the potential local roads to be used for construction traffic has been undertaken and this provides a good indication of the likely impacts, and therefore generic mitigation measures that will need to be considered when preparing a Traffic Management Plan.

The following potential impacts have been assessed to national and county roads DN 38, DJ 391 and DJ 392 which are representative of the local roads likely to be used during construction for the delivery of materials and general access to the project site. Potential impacts to Dc16 (for which no baseline data are available) are considered to be similar to those of DJ 391 and 392.

• DN38: The percentage increase over the baseline traffic situation to DN 38 is 73% increase during the peak construction hour between 0600 to 0700 hrs, however this relates to the movement of light vehicles only during this time. The percentage increase during the peak baseline hours is predicted to be 17% during the morning and afternoon peak on DN 38. These increases are within criteria as set out in Section 7.2.2, indicating that there would be major adverse impacts to the road from the construction movements during the peak construction hours, and moderate adverse impacts during other hours. • DJ391: The percentage increase over the baseline traffic situation to DJ391 is 36% increase during the peak construction hour between 0600 to 0700 hrs however this relates to the movement of light vehicles only during this time. The percentage increase during the peak baseline hours is predicted to be 8% during the morning and afternoon peak on DJ 392. These increases are within the criteria as set out in Section 7.2.2, indicating that there would be moderate adverse impacts to the road from the construction

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movements during the peak construction hours, and minor adverse impacts during other hours. • DJ392: The percentage increase over the baseline traffic situation to DJ392 is 220% increase during the peak construction hour between 0600 to 0700 hrs however this relates to the movement of light vehicles only during this time. The percentage increase during the peak baseline hours is predicted to be 50% during the morning and afternoon peak on DJ 392. These maximum increases are clearly outside the criteria as set out in Section 7.2.2, indicating that there would be major adverse impacts to the road from the construction movements during the peak construction hours, and moderate adverse impacts during other hours. During construction there will be use of farm access roads and other drives and tracks (some of which are currently un-surfaced and will be upgraded for the project). The resulting upgrading of the tracks will constitute improvements to the road surface. Overall minor adverse impacts are anticipated as a result of the increase in traffic on local farm tracks, particularly during the sowing and harvesting periods.

The additional traffic that will be generated during construction could increase the rate of personal injury road accidents in the immediate vicinity of the site and measures will be required to be incorporated into a Construction Traffic Management Plan to ensure that road safety. This plan will establish routes that avoid sensitive areas (pedestrian areas, schools, clinics, etc.), air quality protection measures and also will require driver training.

Please note that traffic related air quality and noise impacts are assessed separately in Chapters 5 and 6.

7.4.3 Mitigation

There are a number of mitigation measures which will be employed to reduce the temporary traffic related impacts of wind farm construction activities. These will include:

• consultation with Constanta County Council and the statutory authorities to develop specific routes for use by construction traffic to avoid sensitive residential areas and unsuitable parts of the network, and regarding the proposed alterations to existing road infrastructure; • routes for abnormal loads will be arranged and agreed with the authorities, local police and emergency services. Where oversized vehicles

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require a police escort, local police dictate the timing of delivery. All abnormal loads will be suitably marked to warn other road users; • using minibuses to transport workers from the construction base; • provisions for the advance warning of construction works in the area, including details of any proposed diversions and road closures, particularly in relation to abnormal loads; • consultation with landowners and users will be undertaken and access will be maintained at all times where required; and • the developer/ principal contractor will hold regular consultations with the local authorities regarding the management of construction. The above mitigation measures will be incorporated into a Construction Traffic Management Plan (CTMP) which will provide a framework for the management of construction traffic impacts of the development. This document will be prepared at a later date in consultation with the authorities and the local community and will aim to minimise the impact of both construction traffic and construction activities on the local road network (including the safety of road users). The CTMP will cover all traffic-related aspects of the construction period including consideration of:

• access to the construction areas; • speed restrictions for construction vehicles; • routing of construction traffic; • temporary traffic control and management; • parking facilities; • movement of plant and materials on the public highways and any escorting arrangements; • keeping public highways clean of mud and dust; • upgrading of local roads; • pavement crossovers; • temporary pavement works; • temporary traffic signs; • road closures, if necessary and the maximum duration; and • hours of transport operations. The plan will take into account the nature of the transport network and its suitability for the transport of materials. The plan will be developed

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continuously by the Contractor and as vehicle movement requirements are refined and will be agreed in final form prior to the commencement of construction activities.

Construction traffic may impact the structural condition of the existing road infrastructure. In order to identify whether any damage has occurred the developer proposes a joint site inspection with the Administration for Roads and Bridges prior and after the project’s transport activities to survey the existing road conditions on the selected route. The procedures and actions to be taken in case of damage to the local road infrastructure by construction traffic will also be detailed in the transport management plan.

7.4.4 Residual Impacts

With the implementation of a combination of mitigation measures set out above including the use of minibuses to transport construction workers to site, the impact of construction traffic flows during the peak construction hours (0600 – 0700 and 1900 - 2000) will be reduced to a minor adverse impact to local or county roads. Minor or moderate adverse impacts in the form of congestion, will remain to traffic flow during other hours throughout the day when heavy vehicles will travel to site.

The mitigation measures outlined above will ensure that there are no significant impacts to the road infrastructure and that traffic safety measures are in place. Minor adverse impacts are likely to remain to local farmers with regard to access to land in particular during sowing and harvesting periods.

7.5 OPERATIONAL IMPACTS

The traffic associated to the operational phase of the wind farm is estimated to be limited to approximately 4 light vehicle movements (8 trips) per week associated with scheduled maintenance activities and unscheduled visits for trouble shooting and repairs.

No significant impacts are anticipated to occur to the local road network as a result of operational traffic flows.

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8 ECOLOGY AND NATURE CONSERVATION

8.1 INTRODUCTION AND SCOPE

This chapter addresses impacts on resources of importance for biodiversity and nature conservation. Section 8.2 outlines the methodology used to assess these impacts. The baseline environment is described in Section 8.3. The assessment of impacts and description of measures planned to mitigate significant adverse impacts are then presented, first for construction in Section 0 and then for permanent effects and long term operation in Section 8.5.

Key aspects of the project (see Chapter 2) which form the basis of this assessment are as follows.

• The project will occupy an area of approximately 16.9 km2. • The land being used for the wind farm site is agricultural. The land being used for the installation of underground transmission line from the project substation to the existing Chirnogeni substation is agricultural. • During operation there will be no emissions from the project. Impacts which could arise as a consequence of the development include the following:

• Loss of habitat and species due to land take for the project. • Creation of permanent and temporary barriers to the movements of fauna. • Temporary damage to habitats and disturbance/ displacement of species arising from secondary effects around construction areas (working areas will generate noise, human disturbance and dust deposition effects. Also artificial lighting, spillage of fuels and chemicals, and emissions from plant). • • Introduction of invasive and/or alien species during the construction works. • Death or injury of birds or bats as a result of collision with turbines which may especially be an issue for migratory species.

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8.2 METHODOLOGY

8.2.1 Sources of Information

Consultation

Consultation was undertaken with the Romanian Bats Protection Association, a non government organization, with regard to the potential impacts of the proposed Project. They recommended that the project make reference to the guideline document “Bats and EIA” developed by the Association.

Surveys of the Study Area

Field surveys were conducted in the study area (including the project footprint and the wider project area – up to approximately 2 km from the site boundary). Ecological surveys conducted include the following.

• Ecological field survey undertaken on November 11, 2008 within the Project footprint. It should be noted that this survey has been conducted outside the optimum time of year for such a survey (which would be the summer months), however, the main plant communities are considered to have been represented. Vegetation structure and floristic composition were examined and plant samples were collected and identified. The area was also inspected for signs of fauna. Findings of the field surveys refined and supplemented those obtained from published information and maps. • Baseline data on insects were collected during May-June 2009, by sampling young and adult individuals at research stations in the study area using an entomological net. • A survey of molluscs was undertaken during April to June 2009. Species of molluscs were identified by means of observation conducted in the study area. • Baseline data on amphibians and reptiles were collected during April to June 2009 (which is an optimum time of year for such a survey), in the study area. The survey used a transect method (the detailed methodology is provided in Annex 4 – Ecology and nature conservation). Some specimens were caught for a precise identification. All animals were released in the habitat of origin identification. • A bird survey was conducted in the study area during spring migration period (March –April 2009), and the nesting period (May-June 2009).

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Methods of assessing populations of birds used included fixed point (Vantage Point) surveys, transect methods, and searching for nests. • A bat survey was conducted in the study area during the June 2009. Recordings were made using two types of ultrasonic detectors from a fixed point and on a transect. Details of the habitat and species survey methodologies are contained in Annex 4 – Ecology and nature conservation of this ESIA. The findings of these surveys are summarised throughout the chapter.

Literature Sources

Various literature papers(40) on flora and fauna in the Dobrogea region and Chirnogeni area were reviewed which served as scientific support for the

(40) Andrei, M., 2002. Contributions to the knowledge of the herpetofauna of southern Dobroudja (Romania). Travaux du Museum National d’Histoire Naturelle „Grigore Antipa”,44: 357-373.

Bavaru A., Sãlãgeanu Gh., Turcu Gh., Parincu Mariana, Skolka M., 1995 - “Pãdurea Dumbrãveni”, o rezervatie stiintificã ce trebuie protejatã prin lege. Analele Dobrogei, I (1): 244 - 249, Ed. Muntenia, Constanta.

BirdLife International 2004. Birds in Europe: Population estimates, trends and conservation status. Cambridge, UK: BirdLife International

Cuzic, V., Cuzic M. 2003. Ornithological studies in the area of the lakes Bugeac, and Dunăreni. Analele Ştiinţifice ale Universităţii "Al.I. Cuza" 49. 259-266.

Doniţă, N., Popescu, A., Paucă-Comănescu, M., Mihăilescu, S., Biriş, I.A. (2005). Habitatele din România. Edit. Tehnică Silvică, Bucureşti,

Heath, MF and MI Ewans (2000) Important Bird Areas in Europe: Priority Sites for Conservation. Cambridge, UK.: BirdLife International.

Papadopol, A. 1962. Quelques aspects de la faune ornithologique de Băneasa (Adamclisi) de la Dobroudja. Travaux du Museum National d’Histoire Naturelle "Grigore Antipa". 3. 341-349.

Papadopol, A. 1964. Le moineau espagnol (Passer hispaniolensis hispaoniolensis (Temm.)) en Roumanie (Aves, Passeridae). Travaux du Museum National d’Histoire Naturelle "Grigore Antipa". 5. 509-512.

Papp, T., Sándor, A.D. (eds) 2007. Arii de Importanţă Avifaunistică din România/Important Bird Areas in Romania. Editura Societatea Ornitologică Română & Asociaţia pentru Protecţia Păsărilor şi a Naturii „Grupul Milvus” Târgu Mureş, 252 p.

Petrescu, A. 2005. Data on the distribution and populations of the Bee-eater, Merops apiaster Linnaeus, 1758 (Aves: Coraciiformes) in Romania. Travaux du Museum National d’Histoire Naturelle "Grigore Antipa". 47. 297-309.

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desktop survey. These are referred to in footnotes throughout the chapter. Maps of the main migration routes used by birds in south eastern Romania were also consulted.

It should be mentioned that there is no comprehensive assessment of bat populations performed in Romania, in order to allow the classification of existing species as rare or very common and widespread.

8.2.2 Assessment Methodology

The following criteria have been used to define the magnitude of change to ecological resources:

• Low Magnitude: Affects a specific group of localised individuals within a population or a particular localised habitat over a short time period; • Medium Magnitude: Affects a portion of a population and may bring about a change in abundance and/or distribution over one or more generation; and • High Magnitude: Affects an entire population or species in sufficient magnitude to cause a decline in abundance and/or change in distribution. The value or importance of habitats is assessed according to the following widely accepted criteria.

Sandor A. and J. Szabo 2002. Censusing Birds to Protect Habiatas - Report for the Common Breeding Bird Monitoring. Interim report ROS, Cluj.

Sándor, D. A. 2000. Metode speciale de numărare a unor categorii de păsări. [Special bird census methods.]. In: Bibby, C., M. Jones, S. Mardsen (eds.): Metode de evaluare a abundenţei păsărilor. SOR, Cluj. 135-141.

Sándor, D. A. 2005. Valorile stepei dobrogene. [Values of the Dobrogea Steppe.]. Despre Păsări. 1. 2-3.

Sándor, D. A. 2009. Status and breeding distribution of the Long-legged Buzzard (Buteo rufinus) in Romania. Submitted manuscript

Vahatalo, A., Petrescu E., Taiminen M. 2001. Numbers of wintering geese in Dobrogea area, Romania, possible threats and solutions for the conservation of geese. Ocrotirea Naturii. 44-45. 85-94.

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• the presence of any habitat, plant or animal species that is internationally, nationally, regionally or locally rare; • diversity of the habitats and their individual species richness; • ‘naturalness’ of the habitat; • the fragility and sensitivity of the habitat and its ability to recover from disturbance; and • whether a species has a seasonally variable vulnerability due, for example, to breeding. The sensitivity of a specific receptor also takes into account the following:

• habitat extent or species population size (at a given geographical level); • habitat or population fragility (including ability to recover); • the rarity of a species or habitat; and • susceptibility to environmental change (e.g. from disturbance or pollution). Significance is then derived as a function of the magnitude of change and the value or sensitivity of the receptor. For the purposes of this assessment the following levels of significance are referred to:

• No significant impact: Imperceptible impacts on habitat or species. • Minor significant impact: Slight, very short or highly localised impact on habitat or species which may be considered to be of some significance but which should not be given much weight in the decision making process. • Moderate significant impact: Limited impact (by extent, duration or magnitude) which may be considered significant. • Major significant impact: Considerable impact (by extent, duration or magnitude) of more than local significance, in which the holding would no longer be viable. The bird species that have been considered in this assessment are predominantly those species identified as priority species that are potentially at risk of impacts from onshore wind farms. This includes birds recognised as requiring special conservation measures – those listed on Annex I to the EC Wild Birds Directive (79/409/EC) and regularly occurring migratory species.

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8.3 ECOLOGICAL BASELINE ENVIRONMENT

8.3.1 Protected Areas

No protected areas are located in the immediate vicinity of the project site. The assessment has focused on a range of 20 km from the project boundary and protected areas of European Importance which have been identified within this are presented in Table 8.1 below. Further detail on each of the sites is presented in Annex 4 – Ecology and nature conservation and their location presented in Figure 8.1 (Annex 5 – Map of Protected Areas) below.

Table 8.1 Protected Areas identified within 20 km of the Project Site

Name and Type of Reasons for Distance Connections Classification distance designation designation with other at National Natura 2000 level sites Dumbrăveni Natura Natural 5 km - ROSCI0022 IUCN –Urluia 2000, SCI Monuments north of Canalele Category III Valley – under the Lake the site Dunării and IV* Lake Habitats Vederoasa -ROSPA0001 Vederoasa Directive 2 protected - species of Adamclisi bat -ROSPA0007 Balta Vederoasa -ROSPA0036 Dumbrăveni Dumbrăveni Natura 23 12 km - ROSCI0071 IUCN Forest 2000, SCI protected northwest Dumbrăveni Category IV and SPA species of of the site - Valea under the bird under Urluia - Habitats Annex 1 Lacul and Birds 66 species Vederoasa Directive of migratory bird Important area used by raptors Hagieni Natura 700 species 15 km - ROSCI0157 IUCN Forest 2000, SPA of flora southeast Hagieni Category IV under the of the site Forest – Habitats Cotu Vaii

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Name and Type of Reasons for Distance Connections Classification distance designation designation with other at National Natura 2000 level sites Directive - RO SPA0092 Bancova Forest Aliman – Natura 33 17 km - ROSCI0071 IUCN Adamclisi 2000, SPA protected northwest Dumbrăveni Category IV under the species of of the site - Valea Birds bird under Urluia - Directive Annex 1 Lacul 38 species Vederoasa of migratory bird Important area used by raptors SCI: A Site of Community Importance is defined in the European Commission Habitats Directive (92/43/EEC) as a site which, in the biogeographical region or regions to which it belongs, contributes significantly to the maintenance or restoration at a favourable conservation status of a natural habitat type or of a species and may also contribute significantly to the coherence of Natura 2000, and/or contributes significantly to the maintenance of biological diversity within the biogeographic region or regions concerned. SPA: Special Protection Areas are strictly protected sites classified in accordance with Article 4 of the EC Birds Directive, which came into force in April 1979. They are classified for rare and vulnerable birds (as listed on Annex I of the Directive), and for regularly occurring migratory species. *IUCN - International Union for Conservation of Nature Category III: area containing one or more specific natural or natural/cultural feature which is of outstanding or unique value because of its inherent rarity, representative or aesthetic qualities or cultural significance. Natural Monument: protected area managed mainly for conservation of specific natural features. (In the present study “Locul Fosilifer Credinta” – geomorphologic reserve). Category IV: protected area managed mainly for conservation through management intervention. Area of land and/or sea subject to active intervention for management purposes so as to ensure the maintenance of habitats and/or to meet the requirements of specific species. (In the present study “Padurea Dumbraveni Natural Reserve”.

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Figure 8.1 Protected Areas within 20 km of the Project Site (Annex 5)

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8.3.2 Habitat Context

Overview of Habitat Context within the Wider Project Area

As a result of its specific continental climate, Constanţa County has a great biological diversity with many types of habitats and ecosystems hosting numerous species of flora and fauna. Semi-natural habitats found in this county include:

• aquatic habitats - freshwater aquatic habitat, brackish, marine and coastal; • terrestrial habitats - habitat of forests, steppe grasslands and bushes, forest-steppe habitat, habitat of swamps; and • underground habitats (habitat of cavernes or caves). These habitats can be divided into the following subclasses:

• halophiles and coastal communities; • continental water; • bushes and meadows; • forests; • marshes and swamps; • gravel; • rocks and continental sands; and • agricultural land and artificial landscapes. Table 8.2 lists 58 types of natural habitat and ruderal communities (agricultural land and artificial landscapes), according to the classification presented in the paper “Habitats in Romania”(41) regarding the protected natural areas, conservation of natural habitats, wild flora and fauna and Annex no. I of the

(41) Habitats in Romania 2005, N. Donita & others and Annex 2 of Government Emergency Ordinance no. 57/2007

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Habitats Directive (92/43/EEC). Figure 8.2 shows the distribution of habitat types within 20 km of the project site.

Table 8.2 Habitat Types present in Constanta County

Class Subclass No. of habitats Coastal and halophyles Marine communities 2 communities Branches and shores 3 Swamps, stepped, bushes and 4 halophyle forests Dune of sand and coastal beaches 7 Continental water (non-marine) Freshwaters 9 Bushes and meadows Temperate bushes 5 Steppe and xerics calcicol 7 grasslands Wet grasslands and communities 2 of high herbs Marshes and swamps Vegetation of waters’ offshore 7

Gravel, rocks and continental Continental dune of sand 1 sands Caves Caves closed the public 1 Forests Temperate forests of the deciduous 3 trees Forests and bushes of meadow and 3 swamp Agricultural land and artificial Ruderal communities 4 landscapes (in Figure 6.2 these are illustrated by numerous field boundaries)

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Figure 8.2 Distribution of Habitat Types within 20 km of the Project Site

Note: areas not marked are agricultural fields, ‘localities’ refers to villages.

Habitat Context within the Project Area

The Project area covers 16.9 km2 which is characterised by a steppe habitat comprising relatively flat arable land which was cultivated for Helianthus annuus (sunflowers) at the time of the site visit undertaken in November 2008. The only other habitats present within the site area are agricultural drains and field margins, which support common species of flora (see Section 8.3.3).

According to the data obtained from the National Institute for Statistics – Independenta Commune Factsheet (2005) - other main crops that are cultivated in the area (and therefore may also be cultivated within the project area in another year) include:

• Triticum sp. (wheat); • Solanum tuberosum (potato); and

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• Zea mays (maize).

Figure 8.3 Sunflower Cultivation in the Project Area (access track shown to the right)

8.3.3 Flora

Overview

The predominant species of flora in Constanta County are Eurasian species (25%) complemented by numerous Balkan species, Pontic-Mediterranean, Sub-Mediterranean (25%) and continental species (17%). Approximately 2,000 plant species are known to exist within the Dobrogea region demonstrating a rich diversity. Plant species are dominated by xerophiles(42) and mesophiles(43).

(42) Xerophiles are extremophilic organisms that can grow and reproduce in conditions with a low availability of water, also known as water activity.

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Eight plant species known to existing in the region are characteristic of steppe and forest-steppe habitats and require the designation of special conservation areas according to national legislation. These include Moehringia jankae, Centaurea jankae, Centaurea pontica, Echium russicum, Liparis loeselii, Salicornia veneta, Campanula romanica, Potentilla emilii-popii.

Over 200 species of vascular flora of national interest have been identified within Constanta County. Additionally a number of endemic species in Dobrogea exist such as Adonis vernalis var. murfatlariensis, Paeonia tenuifolia, Brassica elongata var. splendidepinnulata, Linum borzeanum, Carduus murfatlarii, Centaurea orientalis f. murfatlarii and Stipa lessingiana f. murfatlarii.

Flora within the Project Footprint

The survey findings indicate that vegetation within the project footprint is dominated by arable fields (as described above) which on a rotational basis support the crop species identified in Section 8.3.3 above.

The large arable fields are separated by agricultural irrigation channels and access roads which support semi-natural marginal habitats. Examples of these features are shown in Figure 8.4 and Figure 8.5. A list of species recorded during the site survey is presented in Table 8.3 below. These areas of locally greater species diversity make up a small proportion of the project site. One agricultural irrigation channel is known to be present in the vicinity of the proposed underground transmission line . It was observed to be dry in October 2008.

(43) A mesophile is an organism that grows best in moderate temperature, neither too hot nor too cold, typically between 15 and 40 °C (77 and 104 °F). The term is mainly applied to microorganisms.

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Figure 8.4 Access Road Irrigation Channel

Figure 8.5 Vegetation of Irrigation Channels

Figure 8.6 Vegetation of Access Roads and Margins of Arable Fields

Table 8.3 Flora Species Recorded within the Project Footprint

Latin Name Common Name Location Comments and Protection Status

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Latin Name Common Name Location Comments and Protection Status Helianthus annuus Sunflower Arable fields within - the site footprint Solanum tuberosum Potato Arable fields within - the site footprint Triticum sp. Wheat Arable fields within - the site footprint Zea mays Maize Arable fields within - the site footprint Agropyretum pectiniformae Semi-desert stepper Irrigation channel - (Prodan 1939) Dihoru 1970 with grasses Medicagini-Festucetum Perennial grass Irrigation channel - valesiacae Wagner 1941 Calamagrostetum epigeii Eggler - Irrigation channel - 1933 Festuca valesiaca Perennial grass Irrigation channel - Medicago minima Burr medick Irrigation channel - Agropyron cristatum ssp. Crested wheatgrass Irrigation channel - pectinatum Calamagrostis epigeios Chee reed grass Irrigation channel - Chrysopogon gryllus Grass sadină Irrigation channel - Botriochloa ischaemum Perennial grass Irrigation channel - Agropyron, Melica ciliate Wheatgrass Irrigation channel - Stipa capilata Perennial grass Irrigation channel - Elymus repens Couch-grass Irrigation channel - Poa angustifolia Kentucky bluegrass Irrigation channel - Bromus tectorum Downy brome Irrigation channel - Bromus squarrosus Corn brome Irrigation channel - Bromus hordeaceus Soft brome Irrigation channel - Hordeum vulgarae Barley Irrigation channel - Achillea setacea Yarrow Access roads and - field margins Xeranthemum anuum - Access roads and - field margins Teucrium polium Felty Germander Access roads and - field margins Marrubium peregrinum Branched horehound Access roads and - field margins Sideritis Montana Mountain ironwort Access roads and - field margins Eryngium campestre Field eryngo Access roads and - field margins Salvia nemorosa Woodland sage Access roads and - field margins Salvia austriaca - Access roads and - field margins Convolvulus cantabrica - Access roads and - field margins Astragalus onobrychis - Access roads and - field margins

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Latin Name Common Name Location Comments and Protection Status Potentilla recta Sulphur cinquefoil Access roads and - field margins Teucrium chamaedrys Germander Access roads and - field margins Artemisia austriaca - Access roads and - field margins Artemisia campestris Wormwood Access roads and - sagewort field margins Artemisia absinthium Common sagewort Access roads and - field margins Allium rotundum Wild garlic Access roads and - field margins Daucus carota Bird's nest Access roads and - field margins Orlaya grandiflora Large Flowered Access roads and - Orlaya field margins Hypericum perforatum Klamath weed Access roads and - field margins Seseli campestre - Access roads and - field margins Thymus pannonicus Eurasian thyme Access roads and - field margins Thlaspi perfoliatum Perfoliate Penny Access roads and - Cress field margins Nigella arvensis Nigella Access roads and - field margins Petrorhagia prolifera Proliferous Pink Access roads and - field margins Verbascum banaticum - Access roads and - field margins Carthamus lanatus Downy Safflower Access roads and - field margins Carduus thoermeri - Access roads and - field margins Centaurea solstitialis Yellow starthistle Access roads and - field margins Consolida regalis Royal knight's-spur Access roads and - field margins Galium humifusum - Access roads and - field margins Silene otites ssp. parviflora Breckland Catchfly Access roads and - field margins Buglossoides arvensae - Access roads and - field margins Crepis sancta - Access roads and - field margins Crepis foetida Stinking hawksbeard Access roads and - field margins Euphorbia helioscopia Madwoman's milk Access roads and - field margins

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Latin Name Common Name Location Comments and Protection Status Euphorbia niceensis - Access roads and - field margins Trifolium campestre Field clover Access roads and - field margins Trifolium repens White clover Access roads and - field margins Lotus corniculatus Birdfoot deervetch Access roads and - field margins Medicago falcate Blue Alfalfa Access roads and - field margins Medicago lupulina Black medic clover Access roads and - field margins Medicago minima Bur medick Access roads and - field margins Galium verum Yellow Spring Access roads and - bedstraw field margins Galium album False baby's breath Access roads and - field margins Senecio vernalis Eastern Groundsel Access roads and - field margins Galium molugo - Access roads and - field margins Melilotus officinalis Tall yellow Access roads and - sweetclover field margins Sisymbrium orientale Indian Access roads and - hedgemustard field margins Eryssimum diffusum - Access roads and - field margins Tragopogon dubius Yellow salsify Access roads and - field margins Daucus carota ssp. carota Wild carrot Access roads and - field margins Echium vulgarae, - Access roads and - field margins Torilis arvensis Spreading Access roads and - hedgeparsley field margins Cichorium intybus Chicory Access roads and - field margins Papaver rhoeas Corn poppy Access roads and - field margins Rezeda lutea - Access roads and - field margins Althaea officinalis Common Access roads and - marshmallow field margins Sanguisorba minor Small burnet Access roads and - field margins

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The project area does not support any plant species of conservative interest, listed in Romanian Red Lists or in Annexes of the Habitats Directive or the Bern Convention.

8.3.4 Terrestrial Fauna within the Project Footprint

The habitats within the site area are of limited value to many fauna. Only a few mammals and reptiles were recorded as well as common species of invertebrates. Bird species recorded are described in Section 8.3.6. A species list is provided in Table 8.4 and the findings summarised below.

Table 8.4 Fauna Species Recorded within the Project Footprint

Latin Name Common Name Location Comments and Protection Status Insects Eurygaster maura European tortoise bug Eurygaster austriaca Shield bug Eurygaster integriceps Cereal bug Found in quite large numbers, indicating the absence of effective treatments with chemicals. Anisoplia austriaca Wheat Grain Beetle Anisoplia segetum - Found in quite large numbers. Anoxia villosa - Malachius bipustulatus Malachidae Trichodes apiarius Bee beetle Decticus verrucivorus White-faced Bush- Platycleis sp., cricket Poecilimon sp Chorthippus brunneus Common field grasshopper Chorthippus Lesser marsh albomarginatus grasshopper Omocestus rufipes Woodland grasshopper Stenobothrus lineatus Stripe-winged grasshopper Calliptamus italicus Italian locust Tettigonia viridissima Great green bush cricket Pieris rapae Cabbage white butterfly Pontia daplidice Bath white butterfly Colias croceus Clouded yellow butterfly

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Latin Name Common Name Location Comments and Protection Status Pararge megera Wall brown butterfly Polyommatus icarus Common blue butterfly Aricia agestis Brown argus butterfly Carcharodus alceae Mallow skipper butterfly Autographa gamma Silver Y moth Helicoverpa armigera The Cotton Bollworm moth Anax imperator Emperor dragonfly IUCN status: LC Sp Bombylus Sp Anthrax Apis mellifica Common honeybee Bombus agrorum Carder bee Bombus hortorum Small garden bumblebee Scolia hirta Wasp Molluscs Cernuella virgata Vineyard snail - Cepaea vindobonensis - - Helix pomatia Brown garden snail - Chondrula tridens - - Reptiles Podarcis tauricus Balkan Wall Lizard Present in relatively Listed under Annex IV high numbers on the of 92/43/CEE field margins and in Directive * irrigation channels – this is also good IUCN status: LC habitat for insects, which (foraging habitat). Also found on the outskirts of forests (Dumbraveni, Negru Voda) – outside the project site. (R) (see Figure 6.6 for location) Lacerta viridis European Green Occasional on the Listed under Annex IV Lizard margins of arable of 92/43/CEE fields, this is also good Directive * habitat for insects, which (foraging IUCN status: LC habitat). Also found on the outskirts of forests (Dumbraveni, Negru Voda) – outside the project site. (R) (see Figure 6.6 for

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Latin Name Common Name Location Comments and Protection Status location) Mammals Talpa europaea European Mole Arable fields (R) IUCN status: LC Microtus arvalis Common Vole Arable fields (R) IUCN status: LC Citellus citellus European suslik Arable fields (R) - Vulpes Vulpes Red Fox Arable fields and - marginal habitats (R) Lepus europaeus European Hare Arable fields (R) IUCN status: LC * Species with community interest which require strict protection (R) Resident species (P) passage migrant (S) summer visitor LC – IUCN classification - A taxon is Least Concern when it has been evaluated against the criteria and does not qualify for Critically Endangered, Endangered, Vulnerable or Near Threatened. Widespread and abundant taxa are included in this category

Fauna biodiversity in the project site is relatively poor, dominated by insects. The main groups observed included orthoptera (grasshoppers and crickets) and Lepidoptera (butterflies and moths). A number of species were identified whose cycle of development takes place on cereals or brasicaee (cabbage and rape plants). The fauna recorded is typical of agricultural ecosystems in the region.

The only protected species identified within the project footprint are bats (see below) and two species of reptile that are listed under Annex IV of the 92/43/CEE Directive on the conservation of natural habitats and of wild fauna and flora (the Habitats Directive). The Directive requires that these species receive strict protection, including the prohibition of the deterioration or destruction of breeding sites or resting places. The location of these records is shown in Figure 8.7 below.

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Figure 8.7 Location of Reptiles Recorded during Survey (June 2009)

8.3.5 Bats

31 species of bat are known to exist in Romania. The closest sites known to support bat species is Dubrăveni Forest (the bat area is located 11 km north of the project site), however, this site is not considered to be of such importance to bats. The Cave at the coast, the cave systems of Movila, Gura Dobogei region and the smaller caves of the Murfatlar Plateau and Baneasa Gorge and are also important sites that are located more than 25 km from the project site. These caves are primarily wintering sites comprising limestone cliffs but also some hold important nursery colonies.

The main habitat type within and around the project footprint is arable land. No lines of trees or bushes exist (like the connection between bats shelters and feeding areas) within the study area which would provide good commuting or feeding/roosting areas for bats. During the summer, such open habitat is only likely to be used by a few species which may commute across theses areas. Nevertheless, in such areas, it is possible that flight paths of bats during migration may exist (spring and autumn). As the survey was undertaken in

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June 2009 using bat detectors (results presented below), the migration potential of the site is currently uncertain and further surveys area recommended to confirm this at the appropriate time of year.

The site area and vicinity was not considered to contain any suitable roosting sites (old trees or buildings) favourable to bats that would be worthy of survey. No habitats of significance for foraging bats were identified within the project footprint or surrounding area.

The survey focused on the following observations:

• inventory of potential roost sites around the project site, correlated with previous studies; and • detecting the use of habitat by bats (with ultrasound detectors).

Table 8.5 Bat Species Recorded by Ultrasound Detectors within the Project Area (June 2009)

Number of Protection Latin name Common name Habitat Activity individuals Status

Nyctalus Noctule bat 5 detections Arable fields. P Annex IV noctula Also known to exist in of Habitats Negru Voda forest. Directive Eptesicus Serotine bat 3 detections Arable fields. P Annex IV serotinus of Habitats Directive Nyctalus Leisler's bat 3 detections Arable fields. P Annex IV leisleri of Habitats Directive Vespertilio Parti-coloured Bat, 4 detections Arable fields. P Annex IV murinus Rearmouse Also known to exist in of Habitats Negru Voda forest. Directive Pipistrellus Pipistrelle bat 3 detections Arable fields. P Annex IV pipistrellus Also known to exist in of Habitats Negru Voda forest. Directive Pipistrellus Nathusius's 4 detections Arable fields. P Annex IV nathusii/ pipistrelle/ Kuhl's Also known to exist in of Habitats Pipistrellus pipistrelle Negru Voda forest. Directive kuhlii Hypsugo savii? Savi's Pipistrelle 1 detection Arable fields. P Annex IV of Habitats Directive

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Number of Protection Latin name Common name Habitat Activity individuals Status

P – passage migrant (foraging)

The site survey was based on surveying 8 points across the project area used to detect bats presence (see Annex 4 – Ecology and Nature Conservation). Bats were recorded only at five of these locations (points 1-5). It is therefore concluded that the site area and surrounds is of low conservation value for bats. However, further surveys are recommended during the migration season.

Figure 8.8 Bat Survey Locations (June 2009)

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8.3.6 Birds

Survey Results

Surveys were carried out during spring migration period (March-April 2009) and the breeding season (May-June 2009), a list of species recorded is provided in Table 8.6. Of 30 species recorded during the survey, 7 were recorded as breeding on the site, 8 were recorded as resident and 15 others as summer visitors. Five species of raptor were recorded.

Table 8.6 Bird Species Recorded within the Project Footprint (March-April 2009 and May-June 2009)

Scientific Common March/April or Bird activity Level of Protection name name May/June Grey May/June Annex II/1, III/1 of Perdix perdix 5 individuals (B) partridge 79/409/CEE Directive Coturnix Common 1 individual March/April Annex II/2 of coturnix quail 2 individual (B) May/June 79/409/CEE Directive Merops European 3 individuals March/April - apiaster bee-eater 10 individuals (S) May/June Coracias European 1 individual March/April Annex I of garrulus roller 2 individuals (S) May/June 79/409/CEE Directive Upupa epops Hoopoe 1 individual (S) May/June - Melanocorypha Calandra 4 individuals March/April - calandra lark 8 individuals (B) May/June Galerida Crested 5 individuals March/April - cristata lark 20 individuals (S) May/June Alauda 1 individual March/April Annex II/2 of Skylark arvensis 5 individuals (B) May/June 79/409/CEE Directive Anthus Tawny 1 individual March/April Annex I of campestris pipit 1 individual (S) May/June 79/409/CEE Directive Lesser May/June Annex I of Lanius minor grey 1 individual (S) 79/409/CEE Directive shrike European 1 individual March/April Annex II/2 of Pica pica magpie 1 individual (R) May/June 79/409/CEE Directive Corvus 1 individual March/April Annex II/2 of Rook frugilegus 3 individuals (S) May/June 79/409/CEE Directive Corvus corone Hooded 5 individuals March/April - cornix crow 10 individuals (R) May/June Sturnis 1 individual March/April Annex II/2 of Starling vulgaris 3 individuals (S) May/June 79/409/CEE Directive Passer Tree 10 individuals March/April -

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Scientific Common March/April or Bird activity Level of Protection name name May/June montanus sparrow 15 individuals (R) May/June Carduelis May/June Goldfinch 6 individuals (R) - carduelis Miliaria Corn > 10 individuals May/June - calandra bunting (B) Black- May/June Emberiza > 10 individuals headed - melanocephala (B) bunting Saxicola Common May/June 3 individuals (B) - torquata stonechat Eurasian May/June Streptopelia Annex II/2 of collared 1 individual (R) decaocto 79/409/CEE Directive dove Hirundo Barn 3 individuals March/April - rustica swallow 6 individuals (S) May/June White 1 individual March/April Motacilla alba - wagtail 1 individual (S) May/June Corvus 1 individual May/June Annex II/2 of Jackdaw monedula (R) 79/409/CEE Directive Passer House 2 individuals March/April - domesticus sparrow 8 individuals (R) May/June Columba livia Rock 3 individuals May/June - domestica pigeon (R) 2 individuals (a May/June Western pair) recorded Circus Annex I of marsh hunting over aeruginosus 79/409/CEE Directive harrier arable land (S) 1 individual May/June Common recorded hunting Buteo buteo - buzzard over arable land (S) Red- 2 individuals (a May/June Falco Annex I of footed pair) vespertinus 79/409/CEE Directive falcon (S) Falco Common 1 individual May/June - tinnunculus kestrel (S) Eurasian 1 individual May/June Falco subbuteo - hobby (S) (B) Breeding species (R) Resident species (S) summer visitor Annex I- species are recognised as vulnerable species in need of protection in European Union

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Scientific Common March/April or Bird activity Level of Protection name name May/June Annex II/1, 2- Hunting allowed for Member States Annex III- it is not allowed animal capture for commercialization

Five bird species recorded at the project site during the surveys are listed on Annex I to the EC Wild Birds Directive (79/409/EC), species recognised as requiring special conservation measures. Of key importance to wind farm developments is the presence of raptor species, given the potential for collision during operation. Of the Annex I species identified, the results indicate that the project area is likely to be located within the territory of a breeding pair of Western marsh harriers and a pair of red-footed falcons. Figure 8.9 below shows the location of the protected bird species recorded at the project site during the May – June 2009 survey.

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Figure 8.9 Location of Protected Bird Species Recorded at the Project Site (May-June 2009)

Bird Migration

On the African-Eurasian continents there are five main bird migration routes including the East Atlantic, the Black Sea/Mediterranean, the West Asian/East African, the Central Asian and the East Asian/Australasian. The Black Sea/Mediterranean bird migration route (which is the closest route to the project area) uses the western and eastern Black Sea coastline (north to south) and continues along the eastern Mediterranean coast or incorporates a direct crossing of Eastern Anatolian plateau towards Jordan and Israel.

The western part of the Black Sea/Mediterranean migration route crosses the Dobrogea plateau and comprises two principal route corridors:

• the Black Sea coastline and the lake system; • the hilly lines of loess and limestone cliffs along the River Danube in the western part of Dobrogea.

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These approximate bird mitigation routes are shown in Figure 8.10 below. This illustrates that the Project site is at its closest point located approximately 30 km away from the routes. The lines showed in the figure below are considered to represent the center of a migratory flyway, or the most used part of the flyway. These routes are not exclusive, and a number of bird species migrate over a wider front.

These routes are typically used during the spring migration (March to April) and autumn migration (September to November).

Figure 8.10 Center of the bird Migration Routes and Proximity to the Project Area

The bird species that typically use these migration routes are primarily the small birds, particularly passerines that migrate at high altitudes at night. These species also use day-time roosting areas that present good foraging habitat and shelter against predators.

Aquatic birds from the Danube Delta (Orders: Gaviiformes, Podicipediformes, Ciconiiformes, Anseriformes, Gruiformes, Charadriiformes) mainly use the coastal routes. These species have a preference to fly over coastal wetlands. It is not

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anticipated that these aquatic species will visit the project area. Although certain passeriforme species favor open land, non of these species were recorded during the site survey. However, several passeriforme species favour also the woodland areas for feeding and resting, which reduces the likelihood that large numbers of such species will visit the project area. The project site and the surrounding agricultural areas provide suitable habitat for foraging/hunting territories for raptor species. However, these raptor species are considered to roost only in the woodland and not in the Project area. Concequently the risk of large scale collision woul be considerably limited.

During migration, raptor species may hunt in the area.

Bird migration takes place in normal weather conditions, at high altitudes between 450 - 1,500 m which exceeds the height of turbines (145 m), significantly preventing the likelihood of collisions. The flight height and speed can be reduced by the unfavourable weather conditions: clouds, fog, rain, wind and low temperatures, etc.

It is tentatively concluded from preliminary surveys during the spring migration period that the project site is not a significant site for migrating birds, however, a further bird survey is required during the autumn migration season to confirm this.

8.3.7 Further Survey

At present there is no specific baseline information on the use of the site by birds during the autumn migration (September – November). Due to the potential use of the site by migrating birds and bats during this period, further survey will be undertaken to develop information on fall migration. This will also aim to confirm findings of spring migration and breeding-season surveys for birds and bats.

The survey will be undertaken before the facility is commissioned and operates and should be timed to coincide with the main movements of birds during the autumn migration. It will concentrate on recording the use of the site as a feeding and roosting site for migrating birds and bats, especially soaring birds, such as raptors. Depending on results, there may be changes to operating parameters as needed to reduce risks to protected species (e.g., slower blade speeds or temporary shutdowns during high-risk periods).

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8.4 CONSTRUCTION IMPACTS

8.4.1 Introduction

Short-term impacts that may arise during the construction phase of the Project include the following:

• the direct disturbance and loss of habitat and flora species due to land take by wind turbine bases, tracks and other ancillary development; and • indirect impacts including disturbance to fauna and their habitats, generated by construction activities such as noise and vibration, dust, traffic and leaks and spills.

8.4.2 Habitats

The Project area is characterised by arable land with low biodiversity value, with no hedgerows or trees present on the project site, the only other habitats are agricultural drains and field and road margins which support common species of flora.

Construction excavation work and the presence of a construction camp (50 m by 100 m) will temporarily disturb or result in the loss of small parcels of agricultural habitat and the marginal habitats on site. Given that the habitats in question are of low biodiversity value, and that significant amounts of similar or better habitat exist around the site, no significant impacts are anticipated.

8.4.3 Flora

The flora species recorded within the site footprint during field surveys are typical of arable habitats and the species recorded are all common and widespread (no species identified are of conservative interest).

During construction works construction dust generated will be mitigated as far as reasonably practical (see Chapter 5) therefore mitigating any potential impacts to flora. Construction housekeeping will be managed to a high standard by EPGE as outlined in the Environmental Management and Monitoring Plan (Chapter 12), and activities such as refuelling of vehicles and machinery will be undertaken offsite and on-site spill response and clean-up plans will be implemented in order to minimise risks spills of materials such as paints or oil.

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Construction excavation work and the presence of a construction camp (50 m by 100 m) will temporarily disturb or result in the loss of small parcels of agricultural habitat and the marginal habitats on site. Given that the flora species identified are common and widespread, no significant impacts are anticipated.

8.4.4 Fauna

Invertebrates, Reptiles and Mammals

Fauna biodiversity in the project site is relatively poor, dominated by insects and is typical of agricultural ecosystems in the region. All species are known to be widespread and common.

The only protected species identified within the project footprint are bats and two species of reptile that are listed under Annex IV of the 92/43/CEE Directive on the conservation of natural habitats and of wild fauna and flora (the Habitats Directive). The habitat identified at the site is not considered highly suitable for reptiles due to the absence of hibernation sites (large cracks in walls, buildings etc), therefore it is unlikely that a significant population is present. Should construction take place in the winter months (during the hibernation period), EPGE will commission an experienced ecologist to check the site prior to any clearance works to ensure that no significant hibernation sites are disturbed. If a site to be disturbed supports hibernation by one of the protected specie, the site cannot be disturbed until after this season.Should clearance works be undertaken during the summer months when reptiles are active, this measure will not be necessary. With the implementation of this precautionary mitigation measure, no significant impacts are anticipated to occur to reptiles.

A site survey using bat detectors indicates that there is a low level of use of the project site for flight paths or foraging by bats. The project footprint and surrounding area are not considered of importance for foraging, and no suitable roosts were identified on site. Therefore given the low level of activity of bats at the project site, it is not anticipated that construction works will cause any adverse impacts on bats.

Birds

Several species of birds have been recorded during the June 2009 site survey as foraging on the site, 7 species were reportedly breeding on the project site (none of which are protected).

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Construction of the project will lead to temporary disturbance of small parcels of habitat which is used as foraging land for birds. However this mainly arable land is considered to be of low importance to bird species, is relatively small in size, and is surrounded by significant amounts of similar or better habitat which birds can displace to.

If for imperative reason construction works has to take place during the breading season, survey will be undertaken to identify and mark bird’s nests and no work will be allowed in the vicinity of such sites until the young have fledged. Additionaly, in order that construction does not cause adverse impacts to ground nesting birds, clearance activities will be undertaken outside of the bird breeding season (May – June).

Overall no significant impacts are anticipated to bird species during construction.

8.5 PERMANENT AND OPERATIONAL IMPACTS

8.5.1 Introduction

Permanent and long term operational impacts of the Project may include:

• displacement from the site as a result of indirect habitat loss or turbine operation, presence of a turbine close to nest or feeding sites; • disturbance of protected species of nature conservation interest; • barrier effect caused by the location of the turbines on habitual flight routes; and • death or injury of birds or bats as a result of collision with turbines which may especially be an issue for migratory species.

8.5.2 Habitat

The operational Project footprint will require approximately 0.124 km2 of the total 16.9 km2 site area to be taken out of agricultural use for the lifetime of the project (approximately 20 years) which will result in a loss of this amount of habitat.

Following construction works, reinstatement of the temporary compound area and access roads not required for operation will be undertaken to a high standard and given back to agricultural use (outside the necessary safety area which will be a radius of 600 m away from each turbine location and was

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rezoned). The safety area around the turbines will be kept clean in order to prevent weeds from growing and spreding across neighboring arable land.

The loss of 0.124 km2 of the habitat on site (which is considered to be of low biodiversity value) will have no significant impacts.

8.5.3 .Fauna

Invertebrates, Reptiles and Mammals

No significant impacts are anticipated to invertebrates or reptiles during operation of the project.

A site survey using bat detectors indicates that there is a low level of use of the project site for flight paths or foraging by bats. The project footprint and the vicinity are not considered of importance for foraging, and no suitable roosts were identified on site. Therefore given the low level of activity of bats at the project site, it is not anticipated that operation will cause any adverse impacts.

It is currently uncertain as to the level of potential use of the site during the bat migration period. Further surveys are recommended during the appropriate seasons to confirm what is considered to be an unlikely impact from information collated to date regarding the habitat suitability and use of the site during the summer months.

Birds

Five bird species recorded at the project site during spring - summer 2009 survey are listed on Annex I to the EC Wild Birds Directive (79/409/EC), species recognised as requiring special conservation measures as follows.

• The European Roller is a large passerine species, and during the survey undertaken March/April, only one individual was recorded as a spring visitor. During the survey undertaken in June 2009, only two individuals were recorded at the site as summer visitors. This species is in addition to

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the Annex I designation, is also classified as ‘Near Threatened’ by IUCN(44). The survey results indicate the likelihood that the site is located within the territories of one or two breeding pairs (at the time of the June survey). The population of the species in Romania was estimated at between 4,600 – 6,500(45) pairs in 2004. European roller nest in trees or other bird’s nests and the habitat within the wind farm does not encourage nesting by this specie. However, this specie will forage over open ground, hunting large ground dwelling insects. The species is likely to forage over the project area, and may be displaced from the site during operation of turbines. However there is similar suitable foraging habitat nearby, which the species could use if it is displaced, and given the low number recorded, no significant impacts are anticipated. • The Tawny Pipit and Lesser Grey Shrike are both small passerine species, of dry open ground. The site survey undertaken in June 2009 recorded low numbers of both (just one individual of each species). One tawny pipit individual was also recorded during the March-April 2009 survey. Both species have large Romanian populations, with tawny pipit estimated at between 150,000 – 220,000 pairs in 2004 and lesser grey shrike estimated at 364,000 – 857,000 pairs(46). Both species may be displaced from parts of the project area during operation, however recent research indicates that wind farm developments have minimal adverse impacts on smaller wintering species(47) during operation and similarly low impacts may be anticipated during the breeding season. If displaced, there is ample suitable habitat nearby for both species to move to, therefore no significant impacts are anticipated to these species.

(44) A taxon is Near Threatened when it has been evaluated against the criteria but does not qualify for Critically Endangered, Endangered or Vulnerable now, but is close to qualifying for or is likely to qualify for a threatened category in the near future.

(45) Birds in Europe: population estimates, trends and conservation status (BirdLife International 2004)

(46) Birds in Europe: population estimates, trends and conservation status (BirdLife International 2004)

(47) Claire L. Devereux, Matthew J. H. Denny, and Mark J. Whittingham (2008) Minimal effects of wind turbines on the distribution of wintering farmland birds

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• Marsh Harrier is a medium sized raptor, and during the survey undertaken in June 2009, only two individuals were recorded at the site as summer visitors (hunting at the site). The survey results indicate the likelihood that the site is located within the territory of one breeding pair (at the time of survey). The population of the species in Romania was recorded at between 1,700 – 2,500 pairs (48) in 2004. Despite it’s Annex I designation, marsh harrier is classified as ‘Least Concern’ by IUCN(49) indicating that it is widespread and not currently under threat. Additionally, nests of marsh harriers are usually associated with wetland vegetation, habitat which not characterized the wind farm area. There is the potential that the presence of the windfarm will displace marsh harrier away from the windfarm site. Such species have large territories, and given the plentiful surrounding habitat of similar or better quality, birds are likely to be displaced from the project footprint to forage over other habitat nearby. There is the potential for birds to collide with turbine blades during operation, however, which may result in a moderate significant impact to the species at a local level if one of a breeding pair is killed during operation. • The Red Footed Falcon is a summer visitor to Europe, and during the survey undertaken in June 2009, two individuals were recorded foraging at the site. In addition to the Annex I designation, red footed falcon is also classified as ‘Near Threatened’ by IUCN (50). The survey results indicate the likelihood that the site is located within the territory of one breeding pair (at the time of survey). The population of the species in Romania in 2004 was estimated at between 1,300 - 1,600 pairs(51). There is the potential that the presence of the windfarm will displace red footed falcon away from the windfarm site. However, red footed falcon is a tree nesting

(48) Birds in Europe: population estimates, trends and conservation status (BirdLife International 2004)

(49) A taxon is Least Concern when it has been evaluated against the criteria and does not qualify for Critically Endangered, Endangered, Vulnerable or Near Threatened. Widespread and abundant taxa are included in this category.

(50) A taxon is Near Threatened when it has been evaluated against the criteria but does not qualify for Critically Endangered, Endangered or Vulnerable now, but is close to qualifying for or is likely to qualify for a threatened category in the near future.

(51) Birds in Europe: population estimates, trends and conservation status (BirdLife International 2004)

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species and so its nesting site will not be affected, and there is abundant suitable foraging habitat around the site which it will be able to forage over. There is the potential for birds to collide with turbine blades during operation, however, which may result in a moderate significant impact to the species at a local level if one of a breeding pair is killed during operation. As a general note, it is important to mentione that raptors typically hunt in solitary fashion so few would be at risk of collision with the turbines blades. During the breeding season only ground nesting species, such as tawny pipit are likely to breed within the site and there is some limited potential for displacement in response to the operation of the turbines. Research undertaken on large scale wind farms in upland Britain predicted declines in the related meadow pipit of 14.7% (52) within 500m of wind farms (although it should be noted this work was carried out on previously remote and isolated upland sites and other work has suggested farmland birds may be less susceptible to disturbance (53)). Overall the assessment is that if birds are displaced the actual numbers involved will be small and there is capacity within the surrounding area to accommodate small scale displacement given the low density of bird populations. A minor locally adverse but long term effect is therefore predicted for breeding birds through displacement.

.

There is some potential for collision risk as roller, tawny pipit, marsh harrier and red- footed falcon all engage in aerial displays at turbine rotor height, and there is evidence from some areas (e.g. Smola, Norway) that birds that normally show high levels of avoidance are more vulnerable when engaged in display flights.

(1) 52 Pearce-Higgins, J.W., Stephen, L., Langston, R.H.W., Bainbridge, I.P. and Bulman, R. 2009. The distribution of breeding birds around upland wind farms. Journal of Applied Ecology 46, 1323-1331

(2) 53 Devereux, C.L., Denny, M.J.H. & Whittingham, M.J (2008). Minimal effects of wind turbines on the distribution of wintering farmland birds. Journal of Applied Ecology 45, 1689–1694

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Although the impact assessment records only moderate significant impacts on two species above, this is based on results from the spring migration and breeding season, and does not indicate the use of the site during the autumn migration season. Therefore, a further survey will be undertaken as outlined in Section 8.3.7 prior to construction of the wind farm to verify the potential impacts and introduce mitigation measures as appropriate.

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9 LANDSCAPE AND VISUAL IMPACTS

9.1 LANDSCAPE AND VISUAL IMPACTS

9.1.1 Introduction

This chapter of the ESIA presents the results of the assessment of landscape and visual impacts of the Chirnogeni Wind Farm and considers its effects upon:

• landscape character and resources, including effects on the aesthetic values of the landscape, caused by changes in the elements, characteristics, character and qualities of the landscape; and • visual amenity, including effects upon potential viewers and viewing groups caused by a change in the appearance of the landscape as a result of the development. Landscape character and resources are considered to be of importance in their own right and are valued for their intrinsic qualities regardless of whether they are seen by people. Impacts on visual amenity as perceived by people, are therefore clearly distinguished from, although closely linked to, impacts on landscape character and resources. Landscape and visual assessments are therefore separate, although linked processes.

In undertaking the assessment of landscape and visual impacts it is necessary to acknowledge that varying attitudes to wind energy development are expressed by different individuals and constituencies. Aesthetic perceptions have been identified as the strongest single influence on these attitudes, particularly with respect to visual impacts, and these can be positive or negative depending on individual attitudes to the principle and presence of wind generation(54). There is also an increasing body of evidence that negative

(54) Warren C R et al; "Green on Green: Public Perceptions of Wind Power in Scotland and Ireland"; JEPM 48 (6) pp 853-875, Nov 2005.

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attitudes can reduce with time particularly for those living in proximity to sites, as they become familiar with operational sites(55). It is therefore not possible to arrive at a definitive view on the direction and duration of impacts caused by a project but in this chapter we provide an assessment based on the professional judgment of the assessment team.

The remainder of the chapter presents:

• assessment methodology and significance criteria (Section 9.1.3); • baseline - visual amenity (Section 9.1.6); • baseline - existing landscape character and landscape features (Section 9.1.7); • potential significant impacts (Section 9.1.8); • mitigation measures (Section 9.1.9); • assessment of residual construction and other short term impacts (Section 9.1.10); • long term impacts on landscape (Section 9.1.11); • long term visual impacts (Section 9.1.11); • impacts of decommissioning (Section 9.1.13); and • cumulative landscape and visual impacts (Section 9.1.14). A list of map illustrations and photomontages used to support the assessment are presented in the following table.

List of Figures and Tables

FIGURE NO. TITLE Map Illustrations Figure 9.5.1 30km zone of visual influence (100 m to hub) and viewpoint locations (Annex 6)

(55) See primary research findings and various others references quoted in Warren CR (2005), p 858; op cit.

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Figure 9.5.2 30km zone of visual influence (145 m to tips) and viewpoint locations (Annex 7) Figure 9.5.3 Land use Map (Annex 8) Figure 9.5.4 Local Landscape Character Areas Map (Annex 9) Figure 9.5.5 Landscape Character in wider areas (Annex 10) Photomontages Figure 9.5.6 Viewpoint 02 Road linking Independenta to Dumbraveni (Annex 11) villages at the intersection with the road to Olteni village, (ESE to the project site). Figure 9.5.7 Viewpoint 04 Crossroads of Cobadin village road and the road (Annex 12) linking Independenta and Movila Verde villages, (SE to the project site). Figure 9.5.8 Viewpoint 05 Road linking Movila Verde and Plopeni villages, (Annex 13) (S-SSE to the project site). Figure 9.5.9 Viewpoint 09 West of Chirnogeni village. (Annex 14) Figure 9.5.10 Viewpoint 11 Road linking Negru Voda and Plopeni - 2 km (Annex 15) away from the Bulgarian border, (N-NNW to the project site). Figure 9.5.11 Viewpoint 12 Road linking Negru Voda and Cerchezu, ( NNE (Annex 16) to the project site). Figure 9.5.12 Viewpoint 15 From Viroaga village, from the left slope, (ENE to (Annex 17) the project site). Figure 9.5.13 Viewpoint 18 View from southern edge of village (Annex 18) Independenta, (SE to the project site). Figure 9.5.14 Viewpoint 19 From Topraisar, 30 m away from the last house (Annex 19) and 10 m away from the road to Negru Voda, (WSW to the project site). Figure 9.5.15 Viewpoint 20 From Cobadin, 10 m away from the residential (Annex 20) houses, 40 m away from the road to Independenta, (SSW-S to the project site). Figure 9.5.16 Viewpoint 24 From Negru Voda, near the football stadium and (Annex 21) residential houses, (NNW to the project site). Tables Table 9.1 Visual prominence of wind farms- Scottish Executive Planning Advice Note Table 9.2 Levels of Significance of Landscape Impacts Table 9.3 Levels of Significance of Visual Impacts Table 9.4 Protected Areas identified within 30 km of Project Area Table 9.5 Summary of residual impacts on Local Landscape Character Areas Table 9.6 Summary of residual impacts on Wider Landscape Table 9.7 Assessment of Visual Impacts at Selected Viewpoints

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9.1.2 Policy Context

There are no specific regional and local plan policies or guidelines of relevance to the landscape and visual issues which can be applied to the study area. As part of the methodology the assessment of impacts on landscape and visual arising from the Project has been based on four reference documents which are presented in Section 9.1.3 below.

9.1.3 Assessment Methodology and Significance Criteria

Introduction

The assessment was undertaken taking into account the following guidance:

• Guidelines for Landscape and Visual Impact Assessment, Second Edition, Landscape Institute and Institute of Environmental Management and Assessment, 2002; • Guidelines on the Environmental Impacts of Wind Farms and Small Scale Hydro- electric Schemes, Scottish Natural Heritage, 2001; • Visual Representation of Wind Farms, Good Practice Guidance, Scottish Natural Heritage, 2007; and • Environmental, Health, and Safety Guidelines for Wind Energy, IFC, World Bank Group. The key steps in the methodology were as follows:

• two theoretical zones of visual influence (ZVI) were defined for Chirnogeni Wind Farm based on turbine hub (100 m) and tip heights (145 m) and covering distances up to 30 km – see Figures 9.5.1 and 9.5.2. • the landscapes within this area and within the project site itself were analysed taking into account their geology, topographical structure, vegetation, forms of landscape importance (e.g. archaeological, ecological, hydrogeological), existing condition, quality and value (reflecting landscape designations). Drawing upon existing studies and the findings of site visits, and the sensitivity of each area to development of the type and scale proposed was determined; • in the absence of specific policy designations relevant to landscape and visual impacts other designations within land use plan were identified and used within the assessment;

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• viewpoints across the ZVI were selected as representative of the range of views and types of viewer likely to be affected by the project, • photomontage images of the development from various viewpoints were prepared; • the sensitivity of each landscape and visual receptor was assessed; • the magnitude of change in the landscape of each character area and in the visual amenity of viewpoints was predicted; and • the level of significance of impact on each character area and viewpoint was evaluated. Some key definitions used to guide the assessment process are outlined below.

• Landscape value is the relative value or importance attached to a landscape (often as a basis for designation or recognition), which expresses national or local consensus, because of its quality, special features including perceptual aspects such as scenic beauty, tranquillity or wildness, cultural associations or other conservation issues. • Landscape character is the distinct and recognisable pattern of elements that occurs consistently in a particular type of landscape, and how this is perceived by people. • Landscape quality (or condition) is based upon judgements about the physical state of the landscape and its intactness from visual, functional, and ecological perspectives. It also reflects the state of repair of individual features and elements which make up the character in any one place. • Landscape sensitivity is defined in relation to the specific type of change envisaged (the proposed wind farm) and depends on landscape character and how vulnerable this is to change. Landscapes which are highly sensitive are at risk of having their key characteristics fundamentally altered, leading to a different landscape character. Sensitivity is assessed by considering the physical characteristics and the perceptual characteristics of landscapes in light of particular forms of development(56).

(56) SNH and the Countryside Agency (1996); Topic Paper 6: Techniques and Criteria for Judging Capacity and Sensitivity, pages 2-5.

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The landscape and visual impact assessment was informed by data gathered from the following sources:

• field surveys; • computer generated theoretical ZVIs; • computer modeled photomontages; and • descriptions of landscape features in Dobrogea region included in literature papers.

9.1.4 ZVI and Photomontage Methods

Details of the methods used to prepare the ZVIs and photomontages are set out below.

A theoretical ZVI identifies and maps the area(s) within which a proposed development might have an influence or an effect upon the visual environment. It is used as a tool to select areas and points for more detailed assessment. A 30 km radius from the centre of each turbine ZVI was calculated and mapped both for the turbine tips and the hub height. GIS software (ArcGIS 9.2 and Spatial Analyst extension) was used for the calculation of ZVI inter-visibility.

ZVI analysis was undertaken using digital terrain model (DTM) data which consists of a pixel resolution of 90 m. The DTM used for this study was based on SRTM data (Shuttle Radar Topography Mission) from February 2000. The resulting ZVI maps were overlaid on topographical maps 1:100,000 and 1:50,000. The coordinate system used was Stereo70, the national accepted reference system.

In interpreting the ZVIs, two important issues must be considered:

• The ZVIs presented in this report are theoretical in that they do not take account of intervening vegetation, buildings or minor changes in topography, such as road cuttings. Where these features intervene between the viewer and the wind farm then this local screening will reduce the visibility of the project. • The ZVIs indicate where visibility might be possible anywhere within a 0.81 ha grid square (i.e. this is its level of resolution) and it should not therefore be assumed that the wind farm will actually be seen at all points within each 0.81ha square.

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A maximum 30 km radius area from the centre of each proposed turbine was chosen for the ZVI for Chirnogeni.

Photomontage Methodology

Site Photography, Panorama Stitching Photographs were taken by ERM with a digital single lens reflex (SLR) camera and a fixed 35mm digital lens (50mm equivalent). For each viewpoint, PhotoStitch 3.1 was used to combine the individual photographic frames into panoramas. PhotoStitch matched the colours and lighting between adjacent frames automatically.

Perspective Matching Photographs were produced by consultant company Cube Engineering GmbH (Cube), using ”Wind Pro” software programme. The parameters for these computer generated wireframes were based on the recorded viewpoint and camera details. A perspective match was achieved between the computer-generated panoramas and the photographs by iteratively adjusting the perspective parameters (particularly viewcone and azimuth) until all major features in the image were aligned satisfactorily. Where appropriate, objects in the landscape such as electricity pylons were used as additional markers (control points).

Rendering and Output

Once accurate perspective parameters were known, these were fed into the rendering software (Caligari trueSpace). A full model at the scale of the wind farm was built within this rendering software with each turbine having randomly rotated blades. Since the rendering software cannot render a true cylindrical projection the rendering was done in panels, each 20 degrees wide each, to minimise perspective transformation errors. For each viewpoint, the date and approximate time of photography was used to calculate sun azimuth(57) and elevation to ensure a correct lighting model. Other adjustments to the lighting model were made by eye to match the weather

(57) The azimuth of a point on the celestial sphere is defined as the angular distance measured towards the east, from north, along the astronomical horizon to the intersection of the great circle passing through the point and the astronomical zenith with the astronomical horizon.

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conditions of each viewpoint. The final photomontages were composited using Adobe Photoshop.

In interpreting the photomontages, two important issues must be noted.

• There is an element of judgement inherent in the representation of change shown in a photomontage. While the data sources are largely factual, or based on the judgement of professionals, the finished image is ultimately what the compositor believes to be a reasonable imitation of a photograph of the completed proposal taken in similar conditions. • Each photomontage incorporates the lighting seen in the base photograph. It therefore only truly represents the appearance of the proposed development as it would have appeared at that time on that day. The perceptibility of the changes and the visual character of elements of the scheme will undoubtedly be different under different weather and lighting conditions.

9.1.5 Prediction and Evaluation of Landscape and Visual Impacts

The assessment of landscape and visual impacts is based on three stages:

• classification of the sensitivity of the landscape or visual receptors to the type of development proposed; • prediction of the magnitude of change in the landscape or the view resulting from the development, taking into account mitigation; and • evaluation of the significance of residual landscape and visual impacts depending on the sensitivity of the landscape or viewer to change and the magnitude of change.

Sensitivity of Landscape and Visual Receptors

The sensitivity of a landscape is judged based on the extent to which it can accept change of a particular type and scale without adverse effects on its character. Sensitivity varies according to the type of development proposed and the nature of the landscape: its individual elements, key characteristics (land use, pattern and scale of landscape, enclosure/openness), inherent quality, condition, presence of detracting elements (e.g. pylons), value and capacity to accommodate change, and any specific values such as designations that apply.

A viewpoint will typically represent an area over which other broadly similar perspectives of the development site are obtained. The sensitivity of a

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viewpoint depends upon the extent to which its viewers are adversely affected by changes in their view. Viewpoint sensitivity depends on a number of factors including the context of the viewpoint, the current occupation (residents, recreational visitors, passers-by, and workers) and viewing opportunity of the groups of people being considered, and the number of people affected.

In this assessment sensitivity is described as low, medium or high as defined and presented in Table 9.2 (landscape impacts) and Table 9.3 (visual impacts).

Magnitude of Change

The magnitude of change affecting landscape or visual receptors depends on the nature, scale and duration of the particular change that is envisaged in the landscape and the overall effect on a particular view.

In a landscape, this will require consideration of the loss of, or change in, any important characteristic or feature of the landscape, the proportion of the landscape that is affected, and any change in the backdrop to, or outlook from, the landscape that affects its character.

The magnitude of change in views will depend on the scale of the development and the distance from the viewpoint, the angle of view occupied by the development, the extent of shielding by intervening features, the degree of obstruction of existing features, the degree of contrast with the existing view, and the frequency or duration of visibility.

Taking into consideration that no Romanian guidance on landscape and visual assessment is available in relation to distance, the assessment was based on the guidance provided in Scotland by Scottish Executive Planning Advice Note 45, 2002 which notes that the prominence of a wind farm will depend on distance as follows:

Table 9.1 Visual prominence of wind farms – Scottish Executive Planning Advice Note No. 45, 2002.

Distance Perception Up to 2 km Likely to be a prominent feature 2-5 km Relatively prominent Only prominent in clear visibility – seen as part of the wider 5-15 km landscape 15-30 km Only seen in very clear visibility - a minor element in the landscape.

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Whilst it is evident that visibility will vary with weather conditions, season, time of day, direction of view, the number of turbines and their compositional qualities, this provides useful guidance on this aspect of magnitude.

In this assessment magnitude of change is described as being imperceptible, small, medium or large as defined and p in Table 9.2 (landscape impacts) and Table 9.3 (visual impacts).

Significance of Impacts

No established, measurable technical thresholds of significance exist for landscape and visual impacts as in the case for some other EIA disciplines such as noise or air quality (see paragraph 7.42, page 94 from the Guidelines for LVIA(58) which also discusses the lack of international regulations in this field). Significance is therefore determined by considering the sensitivity of the landscape or visual receptor and the magnitude of change expected as a result of the development. Professional judgement and experience are applied on a case by case basis in order to identify broad levels of significance for each receptor. Each case is assessed on its own merits as factors unique to each circumstance need to be considered.

There are however, general principles which can be used as a guide to this process and these are set out in Table 9.2 (landscape impacts) and Table 9.3 (visual impacts). Following these the level of significance of impact is described as being not significant, minor, moderate, or major. This is however recognised as a continuum and where impacts lie on the borderline impacts may be described as minor to moderate for example.

Impacts which are graded as being major are those which the assessor considers should be given greatest weight in decision making. They usually concern immediate landscapes around the site and close views from sensitive visual receptors. Moderate levels of impact are also considered significant in EIA terms, but they are of progressively reducing importance. Impacts graded

(58) The Landscape Institute and Institute of Environmental Management and Assessment (2002) Guidelines for Landscape and Visual Impact Assessment: Second Edition.

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as minor still constitute effects which warrant being brought to the attention of the decision-maker, but the team considers these should carry little if any weight in the decision. Impacts that are less than minor are considered to be not significant.

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Table 9.2 Levels of Significance of Landscape Impacts

Magnitude of Change in Landscape caused by Proposed Development

Imperceptible Small Medium Large

An imperceptible, A small change in A moderate change in A clearly evident and barely or rarely landscape characteristics landscape characteristics, frequent/continuous change perceptible change in over a wide area or a frequent or continuous in landscape characteristics landscape moderate change either and over a wide area or a affecting an extensive area. characteristics. over a restricted area or clearly evident change infrequently perceived either over a restricted area or infrequently perceived. A landscape which is not valued for its scenic quality or where its character, existing land use, pattern and scale are tolerant of the type of change Not significant Not significant Minor Minor to moderate Low envisaged, and the landscape has capacity to accommodate change A moderately valued landscape, perhaps a locally important landscape, or where its character, land use, pattern and scale may have the capacity to Not significant Minor Moderate Moderate to major accommodate a degree of the type of change Medium envisaged. A landscape protected by a regional (structure plan)

Sensitivity of Landscape or national designation and/ or widely acknowledged for its quality and value; a landscape Not significant Minor to moderate Moderate to major Major High High with distinctive character and low capacity to accommodate the type of change envisaged

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Table 9.3 Levels Significance of Visual Impacts Magnitude of Change in View caused by Proposed Development

Imperceptible Small Medium Large

Change which is Minor changes in views, at Clearly perceptible Major changes in view at close barely visible, at very long distances, or visible changes in views at distances, affecting a long distances, or for a short duration, intermediate distances, substantial part of the view, visible for a very perhaps at an oblique resulting in a either a continuously visible for a long short duration, angle, or which blends to distinct new element in a duration, or obstructing a perhaps at an oblique an extent with the existing significant part of the substantial part or important angle, or which view. view, or a more wide elements of view. blends with the ranging, less concentrated existing view. change across a wider area. Small numbers of visitors with interest in their surroundings. Viewers with a passing interest not specifically focussed on the landscape eg Not significant Not significant Minor Minor to moderate

Low workers, commuters. The quality of the existing view, as likely to be perceived by the viewer, is assessed as being low Small numbers of residents and moderate numbers of visitors with a interest in their environment. Larger numbers of recreational road users. Not significant Minor Moderate Moderate to major

Sensitivity of Viewpoint The quality of the existing view, as likely to be Medium perceived by the viewer, is assessed as being medium

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Magnitude of Change in View caused by Proposed Development Larger numbers of viewers and/or those with proprietary interest and prolonged viewing opportunities such as residents and users of attractive and well-used recreational facilities. Not significant Minor to moderate Moderate to major Major

High High The quality of the existing view, as likely to be perceived by the viewer, is assessed as being high This table is a guide only. The descriptions of levels of magnitude and sensitivity are illustrative only. Each case is assessed on its own merits using professional judgement and experience, and there is no defined boundary between levels of impacts.

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9.1.6 Baseline – Visual Amenity

In order to define the area of influence of the project, two ZVIs were produced showing the extent of theoretical visibility of the hubs and the tips of the turbines within an area covering 30 km radius from the centre of each turbine. These are presented in Figures 9.5.1 and 9.5.2.

These theoretical ZVIs are based on bare ground and do not take into account screening by buildings and vegetation. In practice, many views towards the site will be filtered or screened by intervening settlements.

The size and scale of the scheme comprising 32 turbines is categorised as ‘large’ according to the wind farm typologies presented in the landscape capacity studies undertaken within the U.K. The largest of the six typologies identified equates to 76MW or 25-35 turbines and greater.

From inspection of the ZVI and taking into account settlements, main routes through the area, locations of known tourist/visitor importance and hills from which elevated views may be possible, 11 viewpoints were selected to represent the main areas from which the development may be seen and the different types of viewing opportunity these offer (residents, passers-by, walkers etc). Their locations are shown in the ZVI Figures (Annexes 6 and 7). Details of the nature of the viewpoints in terms of the types and numbers of viewers they represent are provided in Table 9.7.

Photographs of existing views towards the site and full photomontages of the project were prepared for the viewpoints. Photowirelines which show the proposed wind turbines in a schematic form, overlaid on a photograph from the viewpoint has not been carried out for two reasons:

• as photomontages have been prepared for all viewpoints; and • the topography of Chirnogeni and surrounding areas have very little screening by intervening features and hence photowirelines will not be very useful in this particular case. Full photomontages were prepared for eleven viewpoints as listed below:

• Viewpoint V02 - representing from the road between Independenta to Dumbraveni villages, at the intersection with the road to Olteni village. Picture was taken 1.5 m on the field to ESE in the direction of the project site at a distance of 9,300 m from the nearest turbine (Annex 11); • Viewpoint V04 - representing from the crossroads of Cobadin village road and the road between Independenta and Movila Verde villages. Picture

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taken to the SE in the direction of the project site at a distance of 5,900 m from the nearest turbine (Annex 12); • Viewpoint V05 - from the road between Movila Verde and Plopeni villages. Direction S-SSE to the project site, 4,800 m away from nearest turbine (Annex 13); • Viewpoint V09 - from the W of Chirnogeni village. 2,708 m from the nearest turbine (Annex 14); • Viewpoint V11 - 2 km away from the Bulgarian border. Direction NNW to the project site, 8,499 m away from nearest turbine (Annex 15); • Viewpoint V12 - representing road between Negru Voda and Cerchezu. Direction NE to the project site, 6,500 m away from nearest turbine(Annex 16); • Viewpoint V15 - from Viroaga village, from the left slope. Direction ENE to the project site, 4,400 m away from nearest turbine (Annex 17); • Viewpoint V18 - at the Commune Independenta. Direction SE to the project site, 5,700 m away from nearest turbine (Annex 18); • Viewpoint V19 - from Topraisar, 30 m away from the last house and 10 m away from the road to Negru Voda. Direction WSW to the project site, 24,140 m away from nearest turbine (Annex 19); • Viewpoint V20 - from Cobadin, 10 m away from the residential houses, 40 m away from the road to Independenta. Direction SSW to the project site, 18,000 m away from nearest turbine (Annex 20); and • Viewpoint V24 - from Negru Voda, near the football stadium and residential houses, direction NNW to the project site, 6,049 m away from nearest turbine (Annex 21). The above viewpoints were selected to illustrate views of the site from different directions and represent different viewing opportunities and types of visual receptors.

9.1.7 Baseline - Existing Landscape Character and Landscape Designations

No landscape character assessment data are available at national, regional or local level. The landscape of the site and environs characterised for the purpose of this assessment is based on map data and field survey.

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National and Regional Level

At the national level, the National Park and Nature Park in Romania are designated areas relevant to landscape and visual assessment and encompass extensive areas of particular geographical interest or outstanding natural beauty. They have an important conservation role and more importantly offer protection to many rare species of animals and plants. While most of these designated areas are protected areas of European Importance e.g. Natura 2000 and have been protected for ecology and biodiversity some are also protected for their landscape under IUCN category III and category V.

Within the 30 km study area there are four protected areas and the reasons for their designations have been described in Table 9.4 below. The nearest one is approximately 5 km to the north of site.

Table 9.4 Protected Areas identified within 30 km of the Project Area

Name and distance Type of designation Reasons for designation

Dumbrăveni – Valley Natura 2000, SCI under Natural Monuments Urluia – Lake Vederoasa the Habitats Directive Lake Vederoasa (approximately 5 km north of the site) 2 protected species of bat Dumbrăveni Natura 2000, SCI and 23 protected species of bird (approximately 12 km SPA under the Habitats under Annex 1 northwest of the site) and Birds Directive 66 species of migratory bird Important area used by raptors Hagiani Forest Natura 2000, SCI under 700 species of flora (approximately 15 km the Habitats Directive southeast of the site) Aliman – Adamclisi Natura 2000, SPA under 33 protected species of bird (approximately 17 km the Birds Directive under Annex 1 northwest of the site) 38 species of migratory bird Important area used by raptors

According to the list of Romanian areas included in Category V – Protected Landscape/Seascape of the International Union for Conservation of Nature (IUCN), there are no sites of internationally recognised landscape value in

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Constanta County where the project site is located. The nearest site included in the IUCN category V is Balta Mica a Brailei, which is more than 70 km away from the project site.

While the proposed wind turbines are located outside the National Park and Nature Park landscape character type, the potential for views of the wind turbines from locations in this landscape remain. In low elevations in the narrow valleys or from within the forests views of the wind turbines are unlikely to be seen. The scale and containment of these landscapes is not likely to be affected and hence a low sensitivity to the proposed change is assessed to arise.

Within the wider study area at the regional level the various landscapes which can be categorised are;

• Large flat plateau or plains – Most of the surrounding areas around the site are characterised by large flat plains. The project site is located in Constanta County and included into a wider form of relief called South Dobrogea Plateau, a typical plateau region, stretching south of Casimcea Plateau. More than half of the South Dobrogea Plateau is characterized by altitudes ranging between 100-200 m with the Danube level to the west and the Black Sea level to the east. The site is located within the South Dobrogea Plateau and several sub-divisions can be identified within the South Dobrogea Plateau, among which the Negru Voda Plateau is where the project site is located. The Negru Voda Plateau is characterized by the lack of a surface hydrographical network and quasi horizontal areas with lime deposits overlaying Jurassic sediments covered by a layer of loess. In the Negru Voda Plateau, the carstic relief is predominant and is represented by sink holes, poljes (steep-walled and flat-floored depression in a limestone region) and caves. The proposed wind turbines are located within this character type and views of the development from locations within this type will be available. These plains are mostly agricultural land with sparse vegetation. A large number of electricity pylons are seen within the landscape as intrusive elements within the landscape. An overall medium - low sensitivity to the proposed change is therefore to arise.

• Steppe vegetation and woodland - The steppe vegetation has been a predominant feature in the South Dobrogea Plateau landscape. However, most of the steppe vegetation has now been replaced by intensive grazing or by agricultural crops. With regards to woodland the Negru Voda woodland is located east to Negru Voda town approximately 9 - 10 km away. The woodland has an area of approximately 950 ha and is formed of

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the following predominant species: oak, hornbeam, ash, poplar, maple, elm and field maple. While the proposed wind turbines are located away from the woodlands, the potential for views of the wind turbines from locations in this landscape character type remain. Within the forests, views of the wind turbines are unlikely to be available however they will be visible from nearby roads, agricultural fields and few areas where steppe vegetation is still found. However the scale and containment of these landscapes is not likely to be affected and hence a low sensitivity to the proposed change is assessed to arise.

• Valleys with lakes –there are valleys of different sizes and shapes within the wider areas. The nearest valley which is within the 30 km study area is the Dumbrăveni – Valley Urluia – Lake Vederoasa which is located 5km to the north of proposed site. The proposed wind turbines are located outside this character area, however, the potential for views of the wind turbines from locations in this landscape remain. Most of the landscape character type is in low elevations in the narrow valleys and views of the wind turbines are unlikely to be available from these areas as seen in the ZVI and hence a low sensitivity to the proposed change is assessed to arise.

Local Level

The project site is located 2.4 km to the west of Chirnogeni Village on agricultural land. The various landscape character types which can be categorised at the local level are as follows:

• Settlements or communes – small nucleated settlements or communes are seen in the surrounding areas which are connected by rural roads. Most of the surrounding communes are small in size and typically characterised by single storey rural dwellings with basic amenities. The largest of them is the town of Negru Voda which is located to the south of project site approximately 5.7 km away. • The surrounding villages are small in size and typically characterized by an average number of 1,000 houses, a church, small school, basic healthcare facilities and, usually, one community centre to host different types of political or social gatherings. Rural areas display a predominance of one-storey houses made of compacted soil or bricks. The houses in the Chirnogeni and Independenta communes, as well as in the villages under their administration, are single storey, built of compacted soil on small

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plots of land and painted. A high number of these constructions have been neglected and currently in dilapidated conditions. Towns like Negru Voda comprise approximately 1,800 dwellings under the form of houses or apartment blocks. Given that there are valleys within the surrounding topography, some of the nearby communes will not be able to obtain views of the wind turbines especially most residences in Viroaga, Cerchezu, Magura, Olteni, Conacu, Credinta, and Casimcea as seen in the ZVI.

Given the average quality and condition of the residential settlements around the site, sensitivity to the proposed change is considered to be medium-low.

• Surrounding farmland – The surrounding land use is open agricultural land cultivated with cereal crops and rural settlements scattered around. Very small commercial and industrial units mainly used for livestock farming can also be seen. Commercial units are mainly within the boundaries of villages while industrial or utility supply units are generally scattered at the limits of the settlement or on the fields. These mainly appear as single storey sheds and also used for sheltering animals or to store agricultural field equipments. The only local landscape features which can be see within the agricultural land are the irrigation channels (oriented from north to south) seen in the vicinity of the underground transmission line (This was observed to be dry in October 2008 during a site visit). Within the landscape overhead, transmission lines, pylons and the smaller electricity poles are a dominant feature within the landscape and are visually intrusive elements in the existing landscape. Therefore sensitivity to the proposed change is considered to be low.

• Water bodies -The closest surface water body to the site is Plopeni Lake located at approximately 6.9 km north of the site and Negreşti Moor, located at approximately 7.4 km north of the site. Given their distance as well as considering the fact that these would not be affected as they are located at lower levels in the valley, sensitivity to the proposed change is considered to be low. There are no Area of High Landscape Value (AHLV), Heritage Coast, Historic Parks and Gardens, Designed Landscape, Scheduled Ancient Monuments, Conservation Areas and Listed Buildings within or in the surrounding area of Project site.

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Figure 9.1 Existing land use in the surrounding area

Figure 9.2 Farm areas

Figure 9.3 Pylons and transmission lines within the rural landscape

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Taking into account the distance as well as considering the average quality of the landscape, sensitivity to the proposed change is considered to be moderate within the surrounding farmland landscape character type.

9.1.8 Potential Significant Impacts

The proposed Chirnogeni Wind Farm has the potential to cause significant impacts on the landscape of the immediate area such as:

• change to the landscape character of an area; • visual intrusion to sensitive receptors such as residents, recreational users, drivers etc; and • loss of existing screening. These impacts will be largely limited in time to the period of operation of the wind farm, currently scheduled to be 20 years, and will be reversed by decommissioning and removal of the turbines, access tracks, buildings and structures after this period.

In addition to these long term impacts, there is also the potential for significant short and medium term impacts during construction and decommissioning, and during the periods following these activities when the vegetation is re-establishing over disturbed areas.

9.1.9 Mitigation Measures

The following detailed mitigation measures have been addressed within the design to mitigate elements of potential significant landscape and visual impacts:

• Tracks have been designed, as far as possible, to follow and fit with contours in the land. The severance and removal of vegetation has been minimised in the planning and design of the access tracks. Permanent tracks take the shortest route to the turbine where possible. • Signage will be provided only for health and safety purposes and will be located on the turbine doors. Advertising and brand names will not be permitted on the turbines. • There will be no external lighting. • The turbines and all other aboveground structures will be removed at the end of the operational lifetime of the wind farm.

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9.1.10 Measures to Mitigate Impacts during Construction and Decommissioning

The Construction Method Statement (CMS) will take into account landscape mitigation measures during the construction stage of the project. These will include for the protection of vegetation to be retained during the construction phase. Replacement vegetation or tree planting will be undertaken where feasible once construction is complete. Topsoil will be carefully removed and stored in stockpiles not exceeding 2m in height, in order to retain soil structure, during the construction phase. This process will be controlled and implemented through a Soil Handling Strategy as part of a wider Construction Method Statement. Following construction, batches of topsoil will be reinstated to the areas from which it originated as far as is practicable.

Specific landscape mitigation measures during construction will include:

• limiting land clearance and occupation to the minimum necessary for the works; • minimising tree and other vegetation removal; • using fencing to keep contractors out of areas where damage may result; • restricting construction site lighting outside normal working hours to the minimum required for public safety and security; • maintenance of tidy and contained site compounds; • spreading of topsoil and replacement of turf, or reseeding and planting as soon as possible after sections of work are complete; • constructing tracks at the beginning of the construction period to minimise disturbance of other ground. Movement of vehicles will be confined to these routes, thus avoiding soil compaction from vehicles tracking over farmland areas, and consequent impacts on vegetation. A similar approach will be adopted to mitigate significant impacts during decommissioning; and • although significant short term impacts are not expected to occur, similar measures will be adopted during any short term maintenance activities during the operation of Chirnogeni Wind Farm.

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9.1.11 Assessment of Residual Construction and Other Short Term Impacts

9.1.12 Sources of Impact

During construction, there will be short term landscape and visual impacts from plant and activities on the site including:

• clearance of vegetation and topsoil stripping; • construction of internal tracks for access to turbines, mast and switch building locations; • temporary haul road from the site entrance to the turbines; • one temporary construction compound; • temporary fencing; • machinery and material storage; • plant and vehicle movements and tall cranes; • in-situ concrete works including falsework, shuttering and reinforcement; • excavations for foundations and cable trenches; • installation and assembly of turbine towers, nacelles and blades; • installation of the anemometry mast; • construction of the grid connection and operations and controls building; and • construction site lighting in winter months.

9.1.13 Residual Impacts during Construction

It is considered that the above will cause major but temporary landscape and visual impacts at short range over the 18 months duration of construction activity. The significance of the impacts will be reduced with increasing distance from the turbines. Following construction, restoration of replanted areas will take time and these revegetated areas will be visible at short range as relatively bare areas in the early years of establishment from viewpoints located close to the site. Given that the site and surrounding areas are agricultural fields these effects may last for up to a year or two and will decline over the period.

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9.1.14 Other Short Term Residual Impacts During Operation

Once the Chirnogeni Wind Farm is operational there may be occasional infrequent requirements to repair or replace defective turbines or generators. This will result in large vehicles and cranes being present on site for a number of days. There will also be a requirement to relay the temporary haul road under this scenario. Because of their short term nature these are considered to be of small magnitude and not to constitute significant landscape or visual impacts.

9.1.15 Long Term Impacts on the Landscape

Sources of Impacts

The following long term actions will contribute to the landscape and visual impact from the project:

• The introduction of 32 wind turbines, overall maximum height of 145 m to tip and 100m to hub. These will add man-made elements of considerable scale to the landscape establishing a new landmark feature and a point of reference in views from the wider area. Each turbine will permanently displace an area of grassland, and be accompanied by a crane hardstanding. • Limited loss of vegetation, albeit restricted to the minimum required, will include arable farmland. • Creation of a network of new access tracks through the site. Most tracks will be at, or close to, grade avoiding the need for cut and fill slopes. • Establishment of a control building for the Inner Substation 20 kV comprising a single storey building measuring 10m x 25m x 3m height. The residual landscape impacts of these elements are described in relation to each of the Local Landscape Character Areas below.

Residual Landscape Impacts on Local Landscape Character Areas

Settlements or Communes and surrounding Farmlands

The proposed Chirnogeni Wind Turbines will be located in this landscape and therefore it will be directly affected by the project (Figure 9.5.4 - Local Landscape Character Areas). Indirect effects will also arise as a result of the visibility of the

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proposals from within these areas there is limited vegetation cover due to large scale agricultural fields.

A low- medium sensitivity to the proposed change is assessed to arise in this landscape and this reflects the potential visual exposure of this landscape but also takes into account of the detracting elements such as high transmission power lines, pylons, electric poles, low quality industrial sheds and farm houses which reduce the landscape quality. The magnitude of change is assessed to be large and therefore the significance of impacts is assessed to be minor to moderate.

Water bodies

The Plopeni Lake and Negresti Lake are located approximately 7 km away to the north of site. Considering their distance as well as the fact that they are located at lower levels within the valley the sensitivity to the proposed change is considered to be low. The magnitude of change is assessed to be medium and therefore the significance of impacts is assessed to be minor.

Residual Landscape Impacts on the wider Area

At the regional level the three landscape character types which are affected by the proposed wind turbines have been assessed below (Figure 9.5.5 -Landscape Character in Wider Areas).

Flat plateau or plains

The proposed wind turbines are located within this character type. Views would be available from locations within this type which are mostly agricultural farmland, with sparse vegetation as well as pockets of open rough grazing land. A low sensitivity to the proposed change is assessed to arise in this landscape and this reflects the potential visual exposure of this landscape but also takes into account the detracting elements such as high transmission power lines, pylons, electric poles, low quality industrial sheds and farm houses which reduce the landscape quality.

The magnitude of change is assessed to be medium and therefore the significance of impacts is assessed to be minor.

Steppe vegetation and woodland

Most of the steppe vegetation in the wider area of the project location has now been replaced by intensive grazing or by agricultural crops. The closest woodland is Negru Voda and is located approximately 9-10 km away. Given

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the distance, the sensitivity is considered to be low. The magnitude if change is considered to be medium given that the scheme is large and will be visible from open agricultural farmland and steppe vegetation areas. The significance of the impact is assessed to be minor.

Valleys with lakes

The proposed wind turbines are located outside this character area and most of the valley is in low elevations in comparison to the site. Hence a low sensitivity to the proposed change is assessed to arise. The magnitude of change is considered to be small and the significance of the impact is therefore assessed to be not significant.

The summary of residual impacts on Local and Regional landscape character areas has been described below.

Table 9.5 Summary of Residual Landscape Impacts on Local Landscape Character Areas

Local Landscape Sensitivity to the Magnitude of Impact Character Areas Proposed Change Change Significance Settlements or Low-medium Large Minor to Communes and Moderate surrounding Farmlands Water bodies Low Medium Minor

Table 9.6 Summary of Residual Landscape Impacts on Wider Areas

Regional Sensitivity to the Magnitude of Impact Significance Landscape Proposed Change Change Character Areas Flat Plateau and Low Medium Minor Plains Steppe vegetation Low Medium Minor and Woodlands Valleys with Rivers Low Small Not Significant

As there are no Areas of High Landscape Value (AHLV), Heritage Coast, Historic Parks and Gardens, Designed Landscape, Scheduled Ancient Monuments, Conservation Areas and Listed Buildings within or in the surrounding area of the Project site, there are no residual impacts.

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9.1.16 Long Term Visual Impacts

Receptor Locations and Visualisations

The removal of existing features, introduction of new structures and activity around the site will have impacts upon the quality of views experienced by people living, working or visiting in the surrounding area. The Chirnogeni Wind Farm will be seen from fixed locations and as people move through the area on roads, paths and agricultural farmlands. Table 9.7 in this section identifies the principal viewpoints selected to represent the range of opportunities which people will have to see the development from different types of location, distances and directions.

Wind Turbines Visibility

The extent of theoretical visibility of the Chirnogeni wind turbines has been illustrated in the zone of visual influence (ZVI) Figures 9.5.1 and 9.5.2. The site is located in a rural landscape characterised by large open agricultural fields and rough grazing land. The character of the landscape is already adversely affected by power lines, pylons, electricity poles and farm sheds. The settlements or communes have basic infrastructure and are of average quality. There are no high quality landscape features within or in close proximity to the site.

The main areas from which the turbines and mast will in theory be visible are:

• Individual farm houses and nearby settlements like Chirnogeni, Negru Voda, Plopeni, Independenta, Movila Verde, etc. (However, given that there are valleys within the surrounding topography some of the nearby communes will not be able to get views of the wind turbines especially most residences in Viroaga, Cerchezu, Magura, Olteni, Conacu, Credinta, and Casimcea as seen in the ZVI); • Road users on roads linking the settlements and communes; and • Farmers and agricultural workers. The smaller components of the development i.e. access tracks and the site buildings, are likely to be much less visible, only affecting close views. Operational lighting as opposed to lighting during construction and vehicle/people movements will have little or no visual impacts.

The visual impacts from turbines will be limited to the operating lifetime of the project.

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Residual Visual Impacts on Fixed Locations

The degree of impact of Chirnogeni Wind Turbines on each of the 11 viewpoints identified in Table 9.7 was assessed as being either: not significant, minor, moderate or major significance, taking into account the sensitivity of the receptors represented by the viewpoint together with the quality of the existing view and the magnitude of change in the view, in order to evaluate the resulting significance of impact.

The assessment was assisted by the preparation of visualisations of the development of 11 viewpoints. It must be appreciated that photomontages, by their nature give a restricted and artificial view, and the real effect can only be seen by experiencing the view in person. The illustrations do not therefore provide an exact replication of future views, but the turbines are shown to scale to give an idea of the size of the structures and their effect on the view. In assessing the visual impact in each case, consideration is also given to the effect of light and weather conditions on visibility, and the variation in the view around the exact position of the photograph.

The assessment indicates that there will be impacts of minor significance at four of the viewpoints identified in Table 9.7, not significant at four viewpoint locations and minor to moderate at three viewpoint locations.

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Table 9.7 Assessment of Visual Impacts at Selected Viewpoints

Key

Viewer type: H = housing (residential); R = recreational; T = road users; W = workers. Viewer numbers: Residential and Recreational: Many >50; Mod 15-50 ; Few 0-15 , Road users and Workers: Many >1000, Mod >500, few <500. Viewer sensitivity: High, Medium, Low Magnitude of Change: Large, Medium, Small, Imperceptible Significance of Impact: NS = Not Significant, Minor, Moderate, Major.

Description of Components in Existing View Proposed View Viewpoint Grid Ref Easting Grid Ref Northing in Elevation meters to Distance turbinenearest (m) Viewer Type and Type Viewer Number Viewpoint Viewpoint Sensitivity of Magnitude Change of Significance Impact Viewpoint No. No. Viewpoint 1(V02) Road from 43.9339 28.025 168 9,300 T Earth mound to the left, single The cluster of proposed wind low small not Independenta 478 0840 tree in the centre of agricultural turbines will be visible in the far significant Commune to Mod; fields, shed to the right (white distance near the earth mound. Dumbraveni village, painted roof) bordered by A number of them will be on the intersection W former electricity poles and trees screened by the earth mound. with the road to along the road to Independenta The turbines barely attract the Olteni Commune, Few Commune. eye as does the existing mound. 1.5 m on the field

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Description of Components in Existing View Proposed View Viewpoint Grid Ref Easting Easting Ref Grid Ref Grid Northing Elevation in meters to Distance nearest turbine (m) Viewpoint Viewpoint Sensitivity of Magnitude Change ofSignificance Impact Viewpoint No. No. Viewpoint Viewer Type and and Type Viewer Number 2(V04) Crossroad between 43.9564 28.116 128 5,900 T Agricultural farm land and The wind turbines will be clearly low medium minor the road from 099 8115 electricity pylons in the skyline. visible as new small elements on Cobadin Commune Mod; Damaged electricity/telephone the skyline adding to the and the road pole in the foreground and a existing line of electricity pylons connecting W typical traffic sign in the centre. in the skyline. Independenta Commune and Few Movila Verde villages

3(V05) On the road between 43.9527 28.156 107 4,800 T Agricultural farm land, rolling The hub and blades of wind low medium minor Movila Verde and 799 7697 farmland and electricity cables turbines will be visible as new Plopeni villages Few; in the skyline and the road small elements on the skyline. between Movila Verde and Only the tip of blades will be W Plopeni villages visible for some wind turbines due to rolling topography. Few

4(V09) West of Chirnogeni 43.8933 28.222 127 2,708 W Agricultural farmland and The wind turbines will be clearly low medium minor Commune 057 6777 electricity pylons in the visible as new elements on the Few foreground and background, skyline adding to the existing shed within concrete fence, line of electricity pylons in the H enclosed industrial area used to skyline. Existing pylons and store agricultural equipment. shed likely to remain main Many Cluttered view. feature

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Description of Components in Existing View Proposed View Viewpoint Grid Ref Easting Easting Ref Grid Ref Grid Northing Elevation in meters to Distance nearest turbine (m) Viewpoint Viewpoint Sensitivity of Magnitude Change ofSignificance Impact Viewpoint No. No. Viewpoint Viewer Type and and Type Viewer Number 5(V11) 2 km away from the 43.7991 28.171 152 8,499 T Agricultural farm land and trees Few wind turbines can be barely low small not Bulgarian border 277 6736 on the far left and right which seen as new elements within the insignificant Mod can be barely seen line of existing trees at the far end. W

Few

6(V12) Road between Negru 43.8274 28.115 178 6,500 T Agricultural land, small knoll to The wind turbines will be clearly low medium minor Voda town and 559 5058 the left and electricity pylons visible on a clear day as new Cerchezu village Mod and anemometer mast to the small elements on the skyline right in the background adding to the existing line of W electricity pylons in the skyline. The anemometer likely to Few remain main feature in the skyline.

7(V15) Viroaga village, from 43.8759 28.086 135 4,400 H Residential houses and Very few wind turbine tips and high small minor to the left slope 739 7297 backyards, trees, agricultural blades (around 5/6) would be moderate Mod equipment and cereal rolls in the visible in the skyline. Most of foreground, agricultural land, them would be screened. W electricity pylons and trees in the background. Cluttered view. Few

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Description of Components in Existing View Proposed View Viewpoint Grid Ref Easting Easting Ref Grid Ref Grid Northing Elevation in meters to Distance nearest turbine (m) Viewpoint Viewpoint Sensitivity of Magnitude Change ofSignificance Impact Viewpoint No. No. Viewpoint Viewer Type and and Type Viewer Number 8(V18) Independenta 43.9423 28.087 133 5,700 H High electricity mast in the Few wind turbine tips and high small minor to Commune 363 8855 background on a small mound, blades would be visible as new moderate Many group of trees and former farm elements adding to the existing buildings used to store line of electricity pylons in the W agricultural equipment to the skyline. Existing pylons , shed left, existing road, tree and shed and the high electricity mast Few potentially used for agricultural likely to remain main feature purposes, livestock grazing and electricity pylons in the background . Garbage strewn across some parts of the agricultural land.

9(V19) Topraisar Commune, 44.0076 28.442 93 24,140 H Line of trees along the road to The cluster of wind turbines can high impercepti not 30 m away from the 355 8590 Negru Voda town, ploughed be barely seen in the skyline and ble insignificant last house and 10 m Many agricultural land and old would add to the existing line of away from the road damaged structures of the electricity pylons. to Negru Voda T former irrigation system in the background. Electricity lines Many seen in the skyline.

W

Few

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Description of Components in Existing View Proposed View Viewpoint Grid Ref Easting Easting Ref Grid Ref Grid Northing Elevation in meters to Distance nearest turbine (m) Viewpoint Viewpoint Sensitivity of Magnitude Change ofSignificance Impact Viewpoint No. No. Viewpoint Viewer Type and and Type Viewer Number 10(V20) Cobadin Commune, 44.0620 28.219 134 18,000 H Residential houses in Cobadin The cluster of wind turbines can high impercepti not 10 m away from 206 9055 commune, existing commune be seen in the skyline at far ble significant houses, 40 m away Many road, trucks and tractors, distance and would add to the from the road to electricity pylons in the existing line of electricity pylons. Independenta T foreground and background . Proposed view remains a poor Commune Garbage strewn across quality view. Mod agricultural land.

11(V24) Negru Voda, near the 43.8218 28.204 133 6,049 H Agricultural land, trees in the The cluster of wind turbines can high small minor to stadium and houses 931 9356 centre (locust and plum trees) be seen in the skyline at far moderate Many and a white abandoned water distance. They coincide well generally with the location of the R clump of vegetation.

Many

W

Few

Key Viewer type: H = housing (residential); R = recreational; T = road users; W = workers. Viewer numbers: Residential and Recreational: Many >50; Mod 15-50 ; Few 0-15 , Road users and Workers: Many >1000, Mod >500, few <500. Viewer sensitivity: High, Medium, Low Magnitude of Change: Large, Medium, Small, Imperceptible Significance of Impact: NS = Not Significant, Minor, Moderate, Major.

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9.1.17 Impacts during decommissioning

At the end of the operational lifetime of the wind farm, unless a new permission is sought, the turbines and other structures will be removed, returning the landscape and longer distance views of the site to largely their present condition. During decommissioning, there will be short term landscape and visual impacts from plant and activities on the site including:

• site compounds, offices and temporary fencing; • machinery and material storage; • plant and vehicle movements; • tall cranes; and • site lighting in winter months. Decommissioning is expected to take less time than construction and to cause short term moderate impacts during its duration, reducing to minor over the period to completion of restoration.

Some evidence will remain in close views during the post-decommissioning restoration period, but as with the post-construction restoration, over time the site will return to a more natural appearance. Full restoration of replanted areas could take several years, particularly in areas of more sensitive vegetation. The only structures remaining on site will be the underground turbine foundations and these could have a minor impact as a result of the different appearance of surface vegetation in the longer term.

9.1.18 Special requirements of RCAA(59)

The Romanian Civil Aeronautic Authority (RCAA) requires the following modifications(60) to the wind turbines:

(59) Romanian Civil Aeronautic Authority

(60) Modifications required by Approval no. 14805/749 dated 8 July 2009 released by the RCAA for the Chirnogeni Wind Farm project as part of the construction permit application documents

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• wind turbines including tower, nacelle and blades shall be painted in white colour; • turbine towers within the project site shall be provided with light marking during daytime with white-coloured lights having a maximum intensity of 20,000 cd and lamps accepted by the Romanian Civil Aeronautic Authority; • turbine towers within the project site shall be provided with light marking during night-time and during weather conditions limiting visibility (fog, rains and snow) at maximum intensity using flashing white-red and/or red lights and lamps accepted by the Romanian Civil Aeronautic Authority; • the developer shall send the RCAA a written notification informing the the start of the construction works at least 60 days prior to the planned date and shall specify the estimated period necessary for the project elements to be installed to the maximum approved height; • in case construction works do not start within a year since the RCAA approval was issued (8 July 2009), if the developer changes or changes are made to the project design and layout, the developer is required to apply for a new RCAA approval. This is strictly non negotiable and is due to the location of the international airport ‘Mihail Kogalniceanu’ at approximately 30 km northeast of the project site.

The requirement for a white colour finish to all the above ground components of each wind turbine is unusual. Current best practice guidance suggests that grey (RAL 7038) is the most appropriate colour for minimising visual impacts. However, there are a few situations where the colour grey can be prominent for example against a very clear blue sky. Also when the sun is behind the turbines, the colour is irrelevant as all features will appear very dark. Therefore, it is considered that using white for the turbines will increase their visibility but not increase the degree of significance of impact already reported. In some weather conditions such as snow, the white turbines may be less visible than grey versions.

With regard to adding lights to the turbines, primarily this is to highlight the location of the turbines during the night time or when visibility is poor. On both these occasions, visibility of the turbines will not be an issue for sensitive visual receptors. The luminosity of the type of light fitting usually used to assist night time visibility does not normally cause nuisance or glare issues. The nearest residential receptors to the wind farm are approximately 2.8 kilometres distance to the nearest turbine. Lux levels or degrees of luminance

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reduce considerably over distance as intensity decreases by a factor of ¼ as the distance is doubled.

At 2.8 kilometres distance it is considered that typical aeronautical light fittings whilst visible will not cause additional visual impact.

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10 SOCIAL AND ECONOMIC ENVIRONMENT

10.1 INTRODUCTION AND SCOPE

This chapter addresses social, economic and health impacts in the local community. Section 10.4 provides a summary of local economic, social welfare and cultural conditions and resources in the area. Impacts and their mitigation are discussed, first for construction in Section 10.6 and then for operation in Section 10.7.

The study focuses on impacts to the Chirnogeni and Independenta Communes (see Section 10.3), who are most likely to experience impacts from the project. Impacts on employees brought to the area by the company and its contractors, and other migrants electing to move to the area, are not considered except where relevant to impacts on original inhabitants.

The assessment considers the following types of potential impacts during construction and operation.

• impacts on land use and local activities; • impacts on community facilities including recreation; • employment generation, economic impacts and capacity building; • impacts on livelihoods; • impact on the health and wellbeing of local communities; • impacts on infrastructure and services; and • impacts on cultural heritage such as archaeological monuments. As noted in Chapter 2, the expected operating life of the project is at least 20 years and closure and decommissioning will be considered in a general sense in the management plan. Nonetheless, EPGE will consult widely in the run-up to closure when it does occur and is committed to an orderly process complying with best practice as it applies at the time, in terms of minimising impact on employees and the community.

10.2 SOURCES OF INFORMATION

The following sources of information were used for the collection of social and health baseline information:

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• An archaeological baseline survey performed by the experts of the National History and Archaeology Museum of Constanta in April- May 2009. • Archaeological repertory of Romania, archive of the Vasile Pârvan Institute of Archaeology, website(61). • Various research papers on the archaeology and cultural heritage monuments in Dobrogea region and the Chirnogeni area, which served as scientific support for the desktop survey. • Various consultation meetings conducted with the Mayor of Chirnogeni Commune and the Mayor of Independenta Commune as well as with the local community of the two communes. Discussions with the two mayors provided information about planned future projects, as part of the Communes’ development plans. The two mayoralties plan to access funds and plant forest belts which will not impact the Project area. The two mayors were not aware of major infrastructure or utility projects to be planned in the area. • A questionnaire was prepared and sent to the Independenta and Chirnogeni Mayoralties in order to collect socio-economic baseline data such as: the incorporated/unincorporated land areas of the two communes, types of crops grown in the agricultural fields, total population of the communes, age and gender structure of the population, religious and ethnic structure of the communes, main economy, presence of education, health care and entertainment facilities. The questionnaire was sent to the communes in February 2009 and was successful in gathering information on land areas and use, structure of the population, access to health care services, education and entertainment as well as main activities of the rural economy (see Annexes 22 and 23 – Socioeconomic questionnaires for Chirnogeni and Independenta Communes). • Socio-economic statistical data from the Local Statistical Bureau Constanta, Local Environmental Agency of Constanta and Regional Environmental Agency Galati, Local Labour Inspectorate from Constanta, Local Agency

(61) http://www.cimec.ro/scripts/ARH/RAR-Index/sel.asp

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for Professional Training and Employment Constanta, Constanta County Concil, Chirnogeni website.

10.3 AREA OF INFLUENCE AND BOUNDARIES

Primary area of influence. This area encompasses all project impacts on local resources and receptors(62) and includes the areas within the boundaries of Chirnogeni and Independenta Communes (see Figure 10.1). This primary area of influence is the focus of the impact assessment. For the purposes of the Project the primary area of influence has been further divided into:

• Fenceline settlements. Those settlements located in close proximity (less than 3 km) or ‘on the fenceline’ of the planned project footprint (in the case of this project this mainly includes Chirnogeni Village); and • Non fenceline settlements. Those settlements located within the primary area of influence but not in close proximity to the planned Project footprint, relative to the fenceline settlements (in the case of this Project this includes Viroaga, Plopeni, Movila Verde, Independenta, Cerchezu and Negru Voda as indicated in Table 10.1 below). • Secondary area of influence. This regional level study area includes larger scale economic and infrastructure impacts. This area contains Constanta County. • Tertiary area of influence. This area considers the wider, national and international scale impacts of the Project.

Table 10.1 Site Neighbours

Village Commune Approximate Orientation distance from the site boundary* Viroaga Cerchezu 3.7 km southwest Chirnogeni Chirnogeni 2.4 km east

(62) Population, flora and fauna that may experience effects as a results of the development of the project

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Village Commune Approximate Orientation distance from the site boundary* Plopeni Chirnogeni 4 km north Movila Independenţa 5 km north-north- Verde west Independenţa Independenţa 5 km northwest Cerchezu Cerchezu 6.5 km southwest Negru Vodă Negru Vodă 5.7 km southeast Note: distances are measured from the site boundary (safety area) to the closest property within a village/town.

10.4 SOCIOECONOMIC BASELINE

10.4.1 Local Context

The Project is located in Constanta County in the Dobrogea region, southeast of Romania. Each county in Romania is subdivided into towns and communes (comprising several villages). The communes located within the Project area are shown in Figure 10.1 below. The Project is located partly in Independenta commune and partly in Chirnogeni commune as shown in Figure 10.1.

Constanta County Council is the local body which represents the government, coordinating the work of the Commune and Municipal Councils to carry out public services for the county. County Council members are elected by the inhabitants of the county. Each Commune is governed by a Mayor whose decisions are endorsed by the Commune Council. The number of members of the Commune Council depends on the total population of the commune and is established by the Romanian Law on Public Administration no. 215/2001. Consequently, based on the criteria laid down in this law, each Commune Council in Chirnogeni and Independenta is formed of 13 members. The Mayor and the members of the Commune Council are elected every four years by democratic vote of the commune inhabitants.

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Figure 10.1 Commune Boundaries within the Project Area (Annex 1)

Site Location Independenţa Commune Chirnogeni Commune

Cerchezu Commune Negru Vodă Town

10.4.2 Demography

According to the Constanta County Directorate of Statistics, data available on 1 July 2007 revealed that Constanta County had a population of 718,330 with an average density of 101 inhabitants per km2. Data made available by the two Mayoralties in February 2009 indicated the total population of Independenta and Chirnogeni Communes together was 7, 041(63) of which 44% were male and 56% female.

(63) Data collected via the questionnaire issued to the Commune Halls, February 2009 (Annexes 22 and 23 – Socioeconomic questionnaires for Chirnogeni and Independenta Communes)

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The majority of the population of the Independenta and Chirnogeni Communes (February 2009) are Romanian (approximately 84%). Tartars (Mongolian Turkish population) make up 3% of the commune population and Turkish approximately 13%. Fantana Mare village located within Independenta Commune is comprised of an entirely Turkish population, which can read and understand both Turkish and Romanian.

Many Turkish and Tartars moved into the Dobrogea region during the period of Ottoman rule (1396 – 1912). This ethnic distribution still exists today.

In Independenta, the female population makes up 48% of the 0-14 years category of age, 49.5% of the category 15-59 years and 58% of the population over 60 years.

In Chirnogeni, the female population outnumbers the male population in all age categories as it represents 50.8% of the population between 0-14 years, 54.4% of the population aged between 15-59 years and 56% of the population older than 60.

10.4.3 Religion

Approximately 83% of the population in both communes are Orthodox Christian, 16% are Muslim and the remainder are mainly Christians from other denominations(64).

One Orthodox church is located in each of the villages within both of the communes and there is a mosque located in Independenta village. Chirnogeni Village has a Catholic and an Adventist church.

10.4.4 Languages

The official language (Romanian) is spoken across the country and is the main language of the project area. However, English is understood and spoken

(64) Data collected via the questionnaire issued to the Commune Halls, February 2009 (Annexes 22 and 23 – Socioeconomic questionnaires for Chirnogeni and Independenta Communes)

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predominantly by people in the educated classes across Romania and within Constanta. According to statistical data for 2007, the study of English, regularly as first foreign language, begins at the ages of 6-7 and continues throughout the entire education process. French, German and Russian are usually studied as second foreign languages starting at the ages of 10-11 during secondary education. Sometimes either French, German or Russian may be included in the curriculum as first foreign language rather than English. In Independenta and Chirnogeni Communes, English and French are taught as foreign languages during primary and secondary cycles of education. However, foreign languages are spoken very little in rural areas in Romania.

10.4.5 Housing

The urban areas of Constanta County such as the city of Constanta and towns like Navodari, , and others are predominantly characterized by high rise apartment blocks, most of which were built in the period 1960 – 1990. Some of these buildings are in advanced state of decay and only a small share of the apartment blocks are newly built and observe modern standards.

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Figure 10.2 Typical Apartment Blocks in the City of Constanta

The suburbs of Constanta City and the rural areas display a predominance of one-storey houses made of compacted dirt or bricks. The houses in the Chirnogeni and Independenta Communes, as well as in the villages under their administration, are single storey, built of compacted dirt on small plots of land and painted mostly in green and blue. A high number of these

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constructions are now neglected and decaying. No apartment blocks are to be found in these areas.

Figure 10.3 Typical House in Chirnogeni Commune

10.4.6 Infrastructure

Chirnogeni and Independenta Communes are located on the county road (DJ 392) and commune road (Dc 16) which branch off the National Road 38 connecting Constanta and Negru Voda towns.

The main roads which exist in the Project area are presented in Table 10.2:

Table 10.2 Roads in the Project Area

Road Name of the localities linked by the road Distance to the project site Code (km) DN 2A Giurgeni Bridge - Hârsova – Constanta 48 DN 3 Ostrov - Constanta 15 DN 3C Belt West Constanta - Ovidiu 44

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Road Name of the localities linked by the road Distance to the project site Code (km) DN 22 Mihai Viteazu - Ovidiu 44 DN 22A Hârsova - Limit Tulcea County 85 DN 22c Cernavoda - Medgidia - Basarabi 36 DN 38 Constanta - Negru Voda - Frontier 13 Bulgaria DN 39 intersection Cumpana - Mangalia - Vama 35 Veche

Two road bridges exist within the county which cross the River Danube, (Giurgeni - Vadu Oii and Fetesti - Cernavoda). The International Airport ’Mihail Kogălniceanu’ is located approximately 25 km from Constanta. Constanta County also has the main sea harbor facilities in Romania. Two of them are close the project area: Constanta and Mangalia. Furthermore, the navigation on Danube Channel is a transportation option between inland Europe and the Black Sea.

10.4.7 Education

The Romanian legal framework provides 10 years of state paid basic education up to the age of 16 years. Children start school at the age of 6. Education is compulsory for the following age groups:

• primary education for pupils aged 6 – 10 (grades I-IV); and • lower secondary education for pupils aged 10 – 16 (grades V-X). In general, primary schools are present in every community, even in rural areas where the school population is lower.

According to the 2007 National Human Development Report, Romania has an increasing Human Development Index (HDI)(65) as a result of 17 years of reform.

(65) HDI is measured by the following parameters: life expectancy; education – measured by adult literacy and enrolment at schools; and standard of living – measured by purchasing power.

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In terms of gross enrolment ratio and adult literacy, Romania comes close to the EU average and has a rising trend since 1995 (from 20.9% in 1995 to 47.5% in 2005). Despite this increase of education index for Romania, there is still a problem with absenteeism at schools in rural areas. This is generally due to low income (according to a World Vision study conducted in Romania in 2006 which focused on the access of rural children to high school education). Although education is free-of-charge, families are required to purchase textbooks, clothes, footwear and/or school uniform, make school contributions, provide transportation costs etc. These costs are difficult to meet for some families. The study also found that there is a trend for children in rural areas to leave school after completing the ten-year compulsory education and help with the family business (mostly farming).

Data collected from the Independenta and Chirnogeni Communes via the questionnaires indicates that each of the villages within the two communes has one general compulsory school providing primary and lower secondary education. Enrolment in education in the Chirnogeni Commune is high with 96% of children aged between 0-14 years registered. Overall access to compulsory education in Independenta Commune is lower, with only 7.5% of the children aged between 0-14 years enrolled in the educational system. High levels of absenteeism from school are also recorded.

10.4.8 Employment

The project is located partly within the ‘unincorporated area’(66) representing the administrative territory of Independenta Commune, Movila Verde village and partly within unincorporated agricultural fields representing the administrative territory of Chirnogeni Commune and incorporated fields as part of the territory of Chirnogeni Village. The project area includes private property land owned by natural and/or legal entities and public land which belongs to Independenţa and Chirnogeni Communes. The current land use is agricultural and includes arable land and land used for commune and

(66) In law, an unincorporated area is an area of land that is not a part of any municipality. In Romania, the counties control the unincorporated land areas within their boundaries. For this specific case, the Constanta County council is responsible for the administration and control over the unincorporated areas selected for the Project development.

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exploitation roads. The local population is predominantly involved in agriculture which includes arable and livestock farming.

The local community generally farm their own land or lease it to larger farms. The larger farms cultivate large areas of land with cereal crops and provide landowners with a percentage of the yearly crops, consisting of either financial compensation or corresponding amount of the crops.

Other forms of employment are only represented within Independenta Commune where only 5.8% of the local population works in the local administration, education and healthcare sectors.

Detailed employment figures with regard to Independenta and Chirnogeni Communes are presented in Table 10.3.

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Table 10.3 Employment Figures for Independenta and Chirnogeni Communes as of January 2009

2003 2004 2005 2006 2007 2008 2003 2004 2005 2006 2007 2008

Independenta Chirnogeni

Average number of employees - 165 157 171 222 220 229 211 171 188 186 194 200 TOTAL

Agriculture 68 58 52 105 109 110 92 65 89 84 83 83

Industry 7 7 9 7 6 6 17 17 15 16 17 17

Processing industry 2 2 3 3 2 2 5 4 3 3 3 3

Energy, gas, water production, waste 5 5 6 4 4 4 12 13 12 13 14 14 management

Construction - - 11 5 4 4 7 7 6 6 8 8

Commerce 28 27 27 29 25 27 12 12 12 14 15 12

Transport 4 2 2 2 2 3 13 4 3 2 2 2

Public administration 9 12 13 13 13 14 14 14 15 14 14 14

Education 40 41 48 53 53 53 35 35 37 38 42 48

Health and social care 5 5 5 4 4 4 12 6 6 5 5 5

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In 2008(67), approximately 50% of the 229 employed individuals in Independenta Commune were working in the agricultural sector. The second major sector providing jobs was education which employed approximately 48% of those employed. 2% were working in the commercial sector, public administration, constructions etc.

Also, in 2008(68), there were approximately 200 employees in Chirnogeni Commune, out of which 43% work in agriculture, 22% in education and the remaining in different industry sectors, construction, utility supply operation, commerce and public administration.

10.4.9 Unemployment

Statistical data available as well as the data provided by the Chirnogeni Mayor in June 2009 revealed an unemployment rate of 6.5% for Chirnogeni Commune. No data on the unemployment rate for Independenta Commune was available. However, data regarding the total number of registered unemployed individuals in Chirnogeni and Independenta Communes, available at the Constanta Local Employment Agency, are given in Table 10.4 below.

Table 10.4 Unemployment statistics for Independenta and Chirnogeni Communes (beginning of 2010)

Commune Active population* Total number of Unemployed individuals in unemployed % out of the total active individuals population

Chirnogeni 2041 57 2.8

Independenta 1897 28 1.5

*population between 18 and 62 years old

(67) Statistical data for 2008 included in the Independenta Commune Factsheet published on the website of Constanta County Coucil on 18th of June 2011.

(68) Statistical data for 2008 included in the Chirnogeni Commune Factsheet published on the website of Constanta County Coucil on 18th of June 2011.

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Source: Constanta Local Employment Agency, http://www.constanta.anofm.ro/pages/Statistica/stat3.htm

This approximate unemployment figure may not reveal the full number of people seeking work, but only those who are registered as unemployed. Many residents do not register in labour offices, because there are no job opportunities in rural areas and the registration process is lengthy and costly. Due to these and other factors, many rural people and especially women fall outside the employment statistics.

Statistics valid at the end of March 2011 indicated a 5.2% unemployment rate in Constanta County. According to the official data available, the unemployment rate has decreased in the last year. Table 10.5 presents unemployment rates in Constanta County for the past 5 years.

Table 10.5 Unemployment rates in Constanta County for the past five years

Year 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 (end of quarter 1)

Unemployment 8.2 10.9 6.8 5.6 5.0 4.3 3.1 2.5 4.5 6.1 5.2 rates in Constanta County (%)

10.4.10 Poverty

Despite the rise of the HDI, Romania remains the poorest country in the European Union in terms of broad GDP per capita with the exception of Bulgaria. According to the UNDP 2007/2008 human development data(69), Romania had US $9.060 GDP per capita and was ranked 63rd in the world. The

(69) Source http://hdrstats.undp.org/2008/countries/country_fact_sheets/cty_fs_ROM.html

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2008 statistical update available at the same source shows an increased GDP per capita to 10.433 US $ and places Romania one place higher in the hierarchy.

There are no official data available about the poverty rate in Constanta County. However, official documents with regard to the poverty rate at regional level are available. According to these, Constanta County is part of the South-Eastern Development Region of Romania, which is considered to be the third poorest regions of the country, after the North-Eastern and South- Western regions(70).

The project area is relatively close to the city of Constanta and this provides a good position for development. This might influence the poverty level of the target region.

10.4.11 Health

Health Care System in Romania

In Romania, the Constitution guarantees the right to health care which is predominantly state-financed. The health system started a process of reform in 1990 to transition towards a social insurance system. Currently, the system is complex and includes the National and County Social Health Insurance Houses which have contractual relationships with service providers such as occupational physicians, family physicians, hospitals and other providers. People who pay their contributions to the Social Health Insurance Fund benefit from free health care services, such as hospital accommodation or certain medication treatment. Those who do not have a social heath care insurance need to pay for all heath care services. Pupils, students up to age 26 and retired people are considered to be insured by the state as they do not have their own sources of income to contribute to the health care budgets.

(70) According to the official data from Romanian Commission for Social Risk analysis, http://www.presidency.ro/static/CPARSDR_raport_extins.pdf

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In 2006 expenditure on health in Romania was 5.7% of the national GDP (WHO Statistical Information System) and total health expenditure on health per person per year was approximately USD $315.

Health Infrastructure

Independenta Commune has one pharmacy located in Independenta village, which serves the inhabitants of all the villages within this commune. 43.5% of the total population of the Commune are registered with a family doctor as the national healthcare insurance policy requires. There are two health care units in two of the villages which belong to Chirnogeni Commune, namely Chirnogeni and Plopeni.

In Chinogeni Commune each of the villages has a pharmacy. 98% of the population in Chirnogeni Commune is registered to a family doctor as the national healthcare insurance policy requires.

Health Status

Life expectancy has been improving in Romania in recent years. Life expectancy for females in 2000 was 75 years, 76 in 2006 and 76.16 in 2009. Life expectancy for males in 2000 was 68 years, 69 in 2006 and 68.95 in 2009(71).

The leading causes of death for all ages in Romania in 2002 are presented in Table 10.6.

Table 10.6 Leading Causes of Death in Romania (all ages)

Causes of death Deaths (thousands of Deaths (%) people) Ischemic heart disease 60 24 Cerebral vascular disease 52 20 Hypertensive heart disease 16 7

(71) WHO Statistical Information System and in the CIA Factsheet for Romania updated in April 2009.

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Causes of death Deaths (thousands of Deaths (%) people) Cirrhosis of the liver 10 4 Trachea, bronchus and 8 3 lung cancers Lower respiratory 6 3 infections Chronic obstructive 5 2 pulmonary disease Colon and rectum cancers 4 2 Stomach cancer 4 2 Breast cancer 3 1 Source: Death and DALY estimates by cause, 2002, Health Statistics Information published on WHO.

Based on the data made available by the physicians at the Independenta and Chirnogeni Health Care Unit, leading causes of death in the two Communes are known to be:

• Hypertensive heart disease: responsible for the death of approximately 30% of the overall local population in the villages of both Independenta and Chirnogeni Communes. • Cerebrovascular disease: responsible for the death of approximately 20% of the local population in each commune. • Diabetes: responsible for the death of approximately 5% of the local population in each commune.

Table 10.7 Key Health Indicators

Indicator Romania Constanta (Eurostat, 2000) Life expectancy at birth – All population 72.45 years - (data not available) (2009) Life expectancy at birth – Females (2009) 76.16 years 65.2 years Life expectancy at birth – Males (2009) 68.95 years 75.7 years Birth Rate per 1000 population (2008) 10.61 births 10.3 births Death Rate per 1000 population (2008) 11.84 deaths 9.6 deaths Adult mortality rate from 15 to 60 years old 95 deaths - per 1 000 population, Females Adult mortality rate from 15 to 60 years old 218 deaths - per 1 000 population, Males Infant mortality rate per 1000 live births 22.9 deaths 22.3 (2009) both sexes

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Indicator Romania Constanta (Eurostat, 2000) Maternal mortality rate per 100000 live 24 - birth (2004) Under 5 mortality rate per 1000 live births 16 - (2006) Contraceptive Prevalence rate (2004) 70 - Prenatal Care (2004) 76 - Attended births (2004) 99% - Children 12-23 months immunized with 97% - MCV (2007) Children under 5 who are under weight 3.5 - (2002) Source: CIA, UNDP, WHO and CAPMAS (the years stated indicate the latest data available). 2009 data for Romania was available from the Romania Factsheet published on the CIA website and updated on 23 April 2009. At the level of Constanta County, data referring to 2000 were accessed on the Eurostat website, as published in March 2004, based on the information released by INS Romania in the edition 2002 of the publication “Romania 2000 - Regional Profiles”.

10.4.12 Land Use and Property

The main land use of the South Dobrogea Plateau is agriculture as shown in Figure 10.4 (Annex 8 – Land Use Map). The land occupied by agriculture in the region is estimated at approximately 378,000 ha (80.5% of the total area in South Dobrogea region). Of the agricultural land in the region 83.5% is arable, 3.8% is vineyards and 0.7% orchards. According to the questionnaire completed by the representatives of both Mayoralties (see tables below), the agricultural land on which project will be developed is currently cultivated for sunflowers.

The total land needed for the construction of the Wind farm was purchased from 20 separate plot owners. The price negotiated by EPGE with each plot owner was 2,200 EUR (9,200 RON)/ha (without transaction costs) or 2,300 EUR (9,900 RON)/ha (including transaction costs). All land was purchased through fair and negotiated transactions. If an agreement could not be reached with the owner, another plot was selected. None of the plot owners were forced into selling their land.

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Figure 10.4 Land Use Map (Annex 8)

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Table 10.8 Land Use in Independenta Commune

Village Total Unincorporated area Incorporated Arable Vineyard Forest Grazing Unproductive area (ha) area (ha) area (ha) (ha) (ha) fields (ha) land(ha) (ha) Independenta 6,673 6,487 186 6,256 - - 164 67 Movila Verde 4,661 4,530 131 4,072 4 - 356 98 Fantana Mare 1,013 983 30 719 - - 193 71 Olteni 4,034 3,967 67 3,194 - 77.5 618 77.5 Tufani 1,409 1,318 91 931 - - 309 78

Table 10.9 Predominant crops in Independenta Commune

Village Corn (ha) Wheat (ha) Rape (ha) Sun flower Barley Oat Alfalfa Herbs (ha) (ha) (ha) (ha) (ha) Independenta 450 2,856 350 1,800 1,205 262 307 180 Movila Verde 200 2,000 450 1,000 600 100 100 - Fantana Mare 75 300 50 200 30 24 40 - Olteni 140 1,000 250 1,200 250 84 90 180 Tufani 95 352 50 400 25 4 5 -

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Table 10.10 Land Use in Chirnogeni Commune

Village Total area (ha) Unincorporated area Incorporated area Arable area (ha) Vineyard Grazing (ha) (ha) (ha) fields (ha) Chirnogeni 5,616 5,455 161 4,984 340 292 Credinta 928 896 32 818 2 108 Plopeni 4,516 4,390 126 3,956 4 556

Table 10.11 Predominant crops in the Chirnogeni Commune and associated villages

Village Corn (ha) Wheat (ha) Rape (ha) Sun flower (ha) Forage crops (ha) Chirnogeni 280 2,500 750 900 554 Credinta 38 270 20 225 265 Plopeni 220 1,900 500 600 736

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10.4.13 Recreation and Community Facilities

Recreational facilities are typically sparse in Romanian rural areas. Communities usually have a community centre which comprises a building under the ownership and administration of the Mayoralty. This is used to host local activities, events and meetings. Each of the villages within the Independenta and Chirnogeni Communes has one such community centre. One library is located in Independenta village.

10.4.14 Archaeology and Cultural Heritage

Introduction

No museums or tourist attractions are known to be located within the two communes. The baseline has been informed by conducting an archaeological desk top and field survey of the Project site, (undertaken by the Museum of National History and Archaeology Constanta). The main Romanian legislative documents which relate to archaeology and the protection of cultural heritage and a brief summary of the legal requirements are described in Table 10.12 below.

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Table 10.12 Archaeological and Cultural Legal Requirements

• Government Ordinance (GO) 43/2000 on the protection of the archaeological heritage and designation of certain archaeological sites as areas of national interest, republished;

• Law 378/2001 for the approval of GO 43/2000 on the protection of the archaeological heritage and designation of certain archaeological sites as areas of national interest;

• Law 462/2003 for the amendment of GO 43/2000 on the protection of the archaeological heritage and designation of certain archaeological sites as areas of national interest;

• Law 258/2006 for the amendment of GO 43/2000 on the protection of the archaeological heritage and designation of certain archaeological sites as areas of national interest;

• GO 13/2007 to complete art. 5 of the GO 43/2000 on the protection of the archaeological heritage and designation of certain archaeological sites as areas of national interest;

• Law 208/2007 for the approval of GO 13/2007 to complete art. 5 of the GO 43/2000 on the protection of the archaeological heritage and designation of certain archaeological sites as areas of national interest.

• Order 2483/2006 with regard to approving the list of areas having a priority archaeological interest;

• Order 2392/2004 on setting up Archaeological Standards and Procedures;

• Standards and procedures for archaeological research, set up by Order 2392/2004; and

• Law 150/1997 for the ratification of the European Convention on the protection of archaeological heritage, adopted at La Valetta on 16 January 1992.

Archaeological monuments in Romania are protected by Law 150/1997 as mentioned in Table 10.12 above. The main restrictions required by the legal requirements regarding the protection of the archaeological heritage are as follows.

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• Preliminary archaeological research is required for projects which require an EIA. This exercise should aim to identify, describe and assess the direct and indirect impacts of the proposed investment on the archaeological heritage. • A construction permit is only granted following approval from the Ministry of Culture who enforce conservation of archaeological features. • Costs of archaeological investigations requested for the construction permit are borne by the project developer. • Any chance finds during excavation works must be reported to the relevant authorities within 72 hours of discovery and fenced off from the area regulated by the construction permit and investigated/excavated (during this time it is protected as an archaeological site from disturbance). Once investigated, the land may be discharged as an archaeological site and return to its prior use. The certificate of discharge is issued after completion of the investigations by the Constanta Directorate for Culture, Religious Affairs and National Cultural Heritage of Constanta County.

Archaeological Sites

A desk based assessment of the project site involved consultation of archive and library documentation regarding the historical-archaeological evolutions of the project area. Aerial photographs of the site were also reviewed.

The library documentation reviewed did not reveal any information related to the history of the area with regard to archaeology. Furthermore, according to the archaeological experts, the site is not included in the “List of sites in Dobrogea Region known/assumed to have archaeological value”.

The archaeological field survey of the project site comprised walking the project site looking for indications of archaeological monuments and cultural artefacts.

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The archaeological baseline survey identified the presence of 12 tumuli(72) present within the Project site as shown in Figure 10.5 (Annex 24 – Location of the identified archaeological monuments).

Figure 10.5 Location of the Tumuli identified on the project site (Annex 24)

The construction of tumuli as family tombs started in the Bronze Age (approximately 16th- 15th B.C.E.(73)) as part of the funeral tradition of the time and was continued until the Middle Ages (9th - 12th Century C.E.(74)). Tumuli

(72) A heap of earth or stones placed over a grave.

(73) Before common era.

(74) Common era

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are burial mounds composed of earth, which may have one or several burial chambers as internal structures. They vary in size and may contain prehistoric burials of unknown date of type, which have been covered by heaps of earth.

According to the Romanian Archaeology Law no. 422/2001, these tumuli are not considered to be monuments of particular archaeological importance and no buffer area needs to be allocated by the developer around such discoveries.

As shown in the Figure 10.5, one of the tumuli identified on site will be impacted by the installation of the underground electrical cables between the turbines T5 and T13. The applicable mitigation measures will be discussed in the Section 10.6.8.

The archaeological baseline survey also identified the presence of ceramic fragments at the north-western border of the Project site. The characteristics of these fragments led the archaeological experts to the conclusion that an ancient settlement dating from the Roman Age (2nd – 4th Century C.E., could be located partially within the Project site boundary. A castrum(75) also dating from the Roman Age was identified in the southern part of the project site and an antique road going from north to south was observed in the area of plot A11/12/21.

Table 10.13 shows the distance between turbines and the discoveries identified during the archaeological baseline survey.

Table 10.13 Distance between discoveries identified on site and Project turbines

Turbine no. Distance to the nearest Orientation tumulus/antique road (m) T1 250 (to tumulus) northwest T2 375 (to tumulus) Northwest T3 440 (to tumulus) north, northwest T4 250 (to tumulus) Northeast T5 217 (to tumulus) north, northwest

(75) A castrum is a round-shaped fortification usually built at the top of a hill.

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T5 100 (to tumulus) East T5 230 (to tumulus) south, southeast T6 223 (to tumulus) East T10 215 (to tumulus) East T10 218 (to tumulus) East T13 260 (to tumulus) West T14 580 (to tumulus) South-southeast T21 204 (to tumulus) southeast T27 180 (to tumulus) southwest T27 290 (to antique road) southwest T28 270 (to tumulus) northwest T28 180 (to antique road) West T31 300 (to antique road) West

Based on the map shown in the Figure 10.5 and information included in the Table 10.13, it may be concluded that the discoveries on the site during the surface investigation will not be impacted by the turbines layout.

The table below presents other known archaeological sites located in the vicinity of the Project area (in the non-fenceline area) based on the information included in the archaeological survey and in the List of Historical Monuments published on the website of the Romanian Ministry of Culture(76), none of which are directly affected by the project.

Table 10.14 Known Archaeological Sites within close Proximity of the Project Area

Code(77) Name and short Location / Address Date description CT-I-s-B- Settlement of the Northeast of the Late Bronze 02623 Coslogeni type. Chirnogeni village, along Age, Other discoveries both sides of the road centuries

(76) http://www.cultura.ro/sectiuni/Patrimoniu/Monumente/lista/constanta.pdf , List of Historical Monuments published by the National Institute of Historical Monuments on the website of the Romanian Ministry of Culture.

(77) The code is assigned only to those monuments which are included in the List of Historical Monuments. Monuments which do not have a code have been identified by the archaeological experts in the baseline archaeological survey.

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Code(77) Name and short Location / Address Date description made in the village of linking Chirnogeni and XIII – XI Chirnogeni include Plopeni villages. B.C.E. coins dating from the period between centuries XVII and XVIII C.E. CT-I-s-B- Rural Roman Mocanilor Hill, on the Roman 02642 settlement western slope of the hill, Age, 300 m northeast of centuries III Credinta village, – IV B.C.E Chirnogeni Commune, CT-I-s-B- Archaeological site in Plopeni village, Chirnogeni - 02735 Plopeni village Commune, 6 km west from Credinta village, in between Credinta and Plopeni CT-I-s-B- Incineration Plopeni village, Chirnogeni Century X 02735.01 necropolis Commune B.C.E., early Middle Ages CT-I-s-B- Medieval fortification 3 km north of Plopeni Centuries 02735.02 village, Chirnogeni IV – XI C.E., Commune; 6 km west from Roman – Credinta village. Byzantin Ages Tumuli On the territory of Plopeni - village, Chirnogeni Commune. Traces of a Getic Approximately 1.2 km Centuries settlement south from the road IV – III connecting villages Plopeni B.C.E. and General Scarisoreanu. Other discoveries: On the territory of Plopeni antique and medieval village, Chirnogeni coins, military pole. Commune. Antique coins Movile Verde village, discovered and Chirnogeni Commune tumuli pointed out on the territory of Movila Verde. Numerous tumuli Independenta village, pointed out and Independenta Commune. antique sculptures discovered in the area

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Code(77) Name and short Location / Address Date description of Independenta village. CT-I-s-B- Getic incineration Northeast edge of village Centuries 02658 necropolis Fantana Mare village, IV – III, Independenta Commune. B.C.E. Latčne CT-I-s-A- Group of mounds Territory of Fântâna Mare Antiquity 02659 village, Independenta Commune. Other discoveries: Fantana Mare village, - numerous antiques Independenta Commune. traces on the western hill, potential Roman- Byzantin castle; the Muslim cemetery displays architectonic elements of antique monuments signalling a Roman settlement area in the region. CT-II-m-B- Geamie (a type of Fantana Mare village, XIXth 02881 Muslim Mosque) Independenta Commune. Century, C.E. CT-I-s-B- Religious complex 1.5 km to the southeast of Centuries 02651 Dumbrăveni village, X-XI C.E., Independenta Commune, Early near the Valley Caşirului Medieval (Periş), and between Age. villages Dumbrăveni and Olteni. Source: National Institute of Historical Monuments: List of Historical Monuments, Available at: http://www.cultura.ro/sectiuni/Patrimoniu/Monumente/lista/constanta.pdf

10.5 IMPACT METHODOLOGY

This section aims to identify and assess the potential impacts the proposed project may have on socio-economic receptors such as people, health and cultural resources Impacts are assessed by comparing the baseline conditions (i.e. the situation without the project) with the conditions that will prevail if the project is constructed and operated.

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There are therefore four key stages in the assessment:

1. Identifying the baseline conditions without the project and the sensitivity and importance of the receptors and resources at risk. 2. Predicting the magnitude of impact on these receptors and resources, including the nature, scale, extent and duration of change, and in the case of non-routine impacts, their probability or frequency of occurrence. 3. Evaluating the significance of impacts so that decision-makers understand the weight that should be given to them in reaching decisions about the Project. 4. Investigating options for mitigation of significant adverse impacts and agreeing measures to be incorporated into the project proposals with the proponent. This impact assessment will address a variety of different types of impacts namely:

• Beneficial (positive) and adverse (negative) impacts. • Duration: impacts arising permanently as a consequence of the development of the site (e.g. loss of existing land uses), temporarily during the construction period (e.g. noise from earthmoving), and over the long term during the operation of the facility (e.g. visual impacts on nearby residents). • Primary and secondary: impacts arising as the consequences of sequences of cause and effect in the environment. • Direct or Indirect: impacts arising directly from the project or indirectly as a consequence of other changes stimulated by the project (e.g. from an influx of population). • Cumulative: impacts arising in combination across the project and cumulatively with other changes taking place in the locality at the same time.

10.5.1 Evaluation of Significance

The significance of an impact will depend on its predicted magnitude (scale, extent and duration), and on the value or importance of the affected receptors or resources. The significance of a potential impact will therefore be assessed according to the following criteria:

Nature: The type of impact for example either positive or negative and whether the impacts is direct or indirect.

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Duration: The temporal scope of the potential impact and considers It considers permanent impacts arising from development of the project (e.g. loss of environmental resources), short term temporary impacts that will occur during construction (e.g. noise and traffic), and long term impacts that will arise during the operation of the facility (e.g. landscape and visual impacts, noise from the turbines etc).

Scale: The geographical coverage of the ESIA takes into account the following factors:

• the physical extent of the works to be undertaken within the project site boundary; and • the nature of the baseline environment and the manner in which impacts are likely to be propagated beyond the site boundary. The latter depends on the type of impact: so for example, effects on buried archaeology are likely to be confined to those areas physically disturbed by construction works, whilst effects of noise could extend to neighbours outside the site boundary and visual impacts to residents could impact over long distances.

Table 10.15 Impact Significance for Negative Socio-economic Impacts

Impact Magnitude Impact Severity Low Medium High

Low Negligible Minor Moderate

Medium Minor Minor Moderate

High Moderate Moderate Major

Table 10.16 Impact Significance for Positive Socio-economic Impacts

Impact Magnitude Impact Severity Low Medium High

Low Negligible Minor Moderate

Medium Minor Minor Moderate

High Moderate Moderate Major

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10.5.2 Mitigation and Management

A principal objective of ESIA is to identify ways of reducing the impacts of development. This socio-economic assessment will aim to identify all potential impacts. For each potential impact key management and mitigation measures will be proposed. The objective of these measures will be to reduce the impact of any potential negative impacts and enhance the impact of any potential positive impacts on social receptors.

10.6 CONSTRUCTION IMPACTS

10.6.1 Introduction

This section describes the social and health impacts associated with project construction activities. These may include the following:

• impacts to Land Use; • employment generation: direct, indirect and induced; • impacts to the local economy from the housing of construction workers; • impacts to health from the influx of migrant workers; and • loss or damage to public assets such as infrastructure, public buildings, archaeology and cultural heritage.

10.6.2 Impacts to Land Use

The project site, under the scope of this assessment, was estimated to be 16.9 km2 composed of both the project footprint, the wind safety area and a development buffer area.

The project footprint is 0.228 km2 of the total project site.

The total permanent built-up area, which was rezoned to ‘industrial use’, is 0.124 km2 split as follows:

• 0.120 km2 for the turbine foundations and safety, permanent crane pads, access and exploitation roads;

• 0.004 km2 for the 20/110 kV Project Substation. This area represents only 0.73% of the 16.9 km2 project site. The lands where the turbines and the Project Substation 20/110 kV will be located are owned by EPGE and leased by EPWP6. The rest of the project site includes privately

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owned land and public land which belongs to Independenţa and Chirnogeni Communes. According to the Urban Certificate no. 173 dated 29 April 2009 issued by the Constanta County Council, the current land use is agricultural (arable). During construction a temporary construction camp (Annex 2 – Site Layout Map) for 50 laborers will be constructed within the project site. It is estimated that the construction camp will be 5,000 m2 (approximately 50 m by 100 m).

Temporary access restrictions are planned during construction to allow the upgrading of existing tracks and existing exploitation roads to allow permanent access to the site and to accommodate underground lines liking all the turbines and the anemometry masts. Whilst access will not be actively encouraged through the site, these tracks will equally not be obstructed by the wind farm development during operation.

Table 10.17 Summary of Impact Characteristics

Summary Construction Project Aspect/ activity Purchase and use of land Impact Type Direct Stakeholders/ Receptors Independenta Commune , Movila Verde Village and Affected Chirnogeni Commune.

Agriculture is the dominant land use in the South Dobrogea composing 80.5% of total land area. Agriculture is also very important in the Independenta and Chirnogeni Communes who are involved arable farming and livestock farming. The Project Site is currently zoned as agricultural and used as arable land with exploitation roads. According to the questionnaire completed by the representatives of both Mayoralties (see tables below), the project footprint is currently cultivated for sunflowers.

The project will therefore result in the following disturbances to land use:

• Reduction in available agricultural land including the project footprint, construction camp and other activities; and • A restriction of or reduction in access to certain agricultural areas due to construction activities and road upgrades. The total land used during construction will only be a small portion of agricultural land in the area however construction activities will have an impact on those communes and villages using the land for agricultural purposes.

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Table 10.18 Assessment of Impact

Impact Severity - Low

• Nature: The impact is a negative direct impact occurring as a result of primary project activities. • Impact Extent: The local communes are currently using the Project Site for agricultural purposes and will be impacted by the loss of land, therefore the impact extent is local. • Impact Duration: the majority of access limitations and land used for construction will only last for the construction period and will therefore be short-term, however the project footprint will remain re-zoned which will be throughout construction and operation and therefore long-term. Agricultural use can, however, be reinstated after construction. • Ability to Adapt: medium

Probability – The Project will definitely need to rezone land for industrial purposes, construct a construction camp and upgrade roads therefore the occurrence of the impacts is Highly probable

IMPACT SIGNIFICANCE –MINOR NEGATIVE IMPACT

Table 10.19 Summary of Impact for construction

Impact Construction

Severity Low Nature Negative, Direct Extent Local Duration Short-Term Ability to adapt Low negative Probability. Highly Probable SIGNIFICANCE (pre-mitigation). MINOR

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Mitigation

Objective

To manage and mitigate the direct loss of access to and use of agricultural land.

Measure

• Ensure the area impacted during construction is limited and that where ever possible access to agricultural land is not restricted. Where access to land is restricted those communes using the land are informed in good time of this restriction through the correct channels. • Methods will be put in place to remove vegetation and soils whereby they can be stored and replaced during operation. Access by construction labourers to land not directly affected by the project will be restricted so as not to disturb arable land. • Where possible, construction will avoid the crops growing season. However, should crops be damage during this period, compensation will be provided and land will be reinstated according to the provisions of the Compensation Action Plan. • On completion of the construction works all equipment and construction related facilities will be removed and the area will be returnied to its prior use.

10.6.3 Employment: Direct, Indirect and Induced

Table 10.20 Summary of Impact Characteristics

Summary Construction Operation Project Aspect/ activity Employment Employment Impact Type Direct and Indirect Direct and Indirect Stakeholders/ Receptors Local and regional Local and regional Affected communities communities

Direct Employment

Construction is scheduled to start in the first quarter of 2012 for a period of 18 months this will result in direct employment creation. Due to the technical

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nature of the project and the lack of skills levels in local communities, as shown in Sections 10.4.7 and 10.4.8, it is likely that skilled and semi-skilled labour will be sourced nationally and internationally. Consequently unskilled and to some extent semi-skilled labour will be employed locally (from Independenta, Chirnogeni Communes or Constanta County). It is estimated that a total construction workforce of 50 workers will be employed of which 30% (15 workers) are estimated to be local. 2009 statistics, as shown in Section 10.4.2, estimated Constanta County’s population at around 718,330 and an estimated combined population of Independenta and Chirnogeni at around 7,041. This translates to a generation of local employment for less than one percent of Constanta County’s population and around 0.2% of Independenta and Chirnogeni’s population. Employment for locals will have a noteworthy effect on those who are employed however this will be only a very small percent of the total population.

Indirect and Induced Employment

Indirect employment will be created through employment in the projects supply chain this can be described as:

• in businesses providing the Project with goods and services (usually referred to as indirect employment); and • in businesses supplying direct and indirect employees with goods and services (usually referred to as induced employment). Induced employment will also be created through increased employee spending in the economy. There are no generic data from which to estimate levels of indirect and induced employment in Romania(78)and local effects will depend on the nature of the local economy, its ability to supply the needs of the Project and its employees, and the ways in which those employees choose to spend their earnings.

(78) In a developed economy such as the UK it has been estimated than 1 direct job can yield up to 1.4 additional jobs in an area through indirect and induced employment, but this relationship is unlikely to hold true in less developed economies such as Romania.

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As described in Sections 10.4.2 and 10.4.8, local communities, namely Independenta and Chirnogeni, are relatively small farming communities. Enterprises in these villages are likely to consist mainly of small and micro sized organisations who are unlikely to have experience in the supplying these goods and services. All major construction supplies (such as turbine components) will be imported from Europe(79). This, in conjunction with the technical nature of procurement requirements and the short 18 month construction timeframe, means that indirect and induced employment is likely to be extremely limited, particularly in the local area due to limited size and capacity.

The provision of approximately 15 local jobs will provide some level of benefit to the local economy, although this is likely to be very limited. This induced employment is likely to take the form of increased spending on goods and services. Due to limited local employment creation combined with the short construction period this impact will be small and is likely to include use of local companies for taxi and minibus services, catering, office supplies, travel agents and printing. EPGE will also source concrete and aggregate from a local supplier (within Constanta).

(79) The turbine components will be delivered by ship from Nordex, the German wind turbine manufacturer, to Constanta harbour and transported to the site by Restricted Access Vehicles (RAV), longer than 19 m or heavier than 42.5 tons.

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Table 10.21 Assessment of Impact

Impact Severity - Low

• Nature: This will be a positive direct, indirect and induced impact. • Impact Extent: Of the 50 construction labourers only around 15 will be locally employed this is will likely be from Independenta, Chirnogeni and Constanta and therefore the impact will be local. • Impact Duration: The impact will occur during the construction period of 18 months and will therefore be of a short-term impact. • Ability to Adapt: Due to the short-term of the project phase, the technical nature of the project and the low skills levels in the local villages it is likely that ability to adapt will be low.

Probability – This will be highly probable as employment is an essential aspect of the project and, should the appropriate skills be available locally, it would be more economically viable to employ people locally.

IMPACT SIGNIFICANCE – MINOR POSITIVE IMPACT

Table 10.22 Summary of Impact for construction

Impact Construction

Severity Low

Nature Positive, Direct, indirect and induced

Extent Local

Duration Short-Term

Ability to adapt Low

Probability. Highly Probable

SIGNIFICANCE (pre-mitigation). NEGLIGIBLE

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Mitigation

Objective

The project will aim to maximise local employment during construction.

Measures

• Prioritise employment of local labour by setting criteria for prioritising, firstly labour from Independenta and Chirnogeni and secondly from Constanta County; and • clearly advertise criteria for skills and experience needed for available jobs through local media.

10.6.4 Impacts on Housing

The housing of construction workers is the responsibility of the contractor by whom they are employed, and is therefore not dealt with directly by EPGE. It is estimated that approximately 30% of construction workers are local and therefore will already have accommodation in the neighbouring villages. For workers employed from outside the area, the contractor will organise accommodation containers to be located within the temporary construction compound. The accommodation containers will provide housing conditions complying with all applicable health and safety regulations and norms as identified in the technical construction documents. Any impact on the local housing situation in the local communities is expected to be negligible.

According to the International Labor Organization (ILO), the accommodation for workers has to follow some basic health standards and any employer should try to offer proper accommodation by creating sufficient space for people, adequate facilities and environment for resting and spending spare time etc. below presents ILO recommendations on this matter.

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Table 10.23 ILO workers’ housing recommendations

• It is generally not desirable for employers to provide housing for their workers directly and employers should use alternatives where possible. If there are no alternatives, specific attention should be paid to renting arrangements, workers ‘rights and housing standards. In addition, the possibility of workers-occupants acquiring, for a fair price, ownership of housing provided by the employer should also be examined. • Renting arrangements should be fair. Adequate and decent housing should not cost the worker more than a reasonable proportion of their income and should never include a speculative profit. • The employer should be entitled to repossess the accommodation within a reasonable time in the event of termination of the worker’s contract of employment and the worker should be entitled to a reasonable period of continued occupancy when he ceases to exercise his employment. • During the time workers spend in the workers’ accommodation they should enjoy their fundamental human rights and freedom of associations in particular. Workers’ accommodation arrangements should not restrict workers’ rights and freedom. • Housing standards should include special attention to the following: - minimum space allocated per person or per family (floor are; cubic volume; or size and number of rooms); - supply of safe water in the workers’ dwelling in such quantities as to provide for all personal and household uses; - adequate sewage and garbage disposal systems; - appropriate protection against heat, cold, damp, noise fire, and diseases-carrying animals, and, in particular, insects; - adequate sanitary and washing facilities, ventilation, cooking and storage facilities and natural and artificial lighting; - a minimum degree of privacy both between individual persons within the household and for the members of the household against undue disturbance by external factors; - the suitable separation of rooms devoted to living purposes from quarters for animals. • Where accommodations are provided for single workers or workers separated from their families, additional housing standards should be considered: - a separate bed for each worker; - separate gender accommodation; - adequate sanitary conveniences; - common dining rooms, canteens, rest and recreation rooms and health facilities, where not otherwise available in the community.

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10.6.5 Impact on Livelihoods

Table 10.24 Summary of Impact Characteristics

Summary Construction Project Aspect/ activity Employment: direct, indirect and induced Impact Type Direct, indirect and induced Stakeholders/ Receptors Local Communes, potentially Constanta County Affected

The project is likely to have two impacts on the livelihoods and local communities. Firstly people from the local communes use this land for agricultural purposes either renting the land or farming it directly. A significant proportion of people from both Independenta and Chirnogeni Communes are employed in the agricultural sector, as discussed in Section 10.4.8. Land previously zoned as, and used for, agricultural purposes will now be rezoned for industry. This may have an impact on the livelihoods of those people who previously farmed the land, however due to the small scale of the project and the availability of agricultural land in the area this is unlikely to be a significant impact. This impact is also discussed in Section 10.6.2 of this impact assessment.

The second effect the Project may have on livelihoods in the local area is through an increase in income generated through direct, indirect and induced income. This will therefore offer the opportunity to around 15 local people increased household income and consequently standard of living. In relation to the size of Independenta and Chirnogeni Communes 15 people is a very small percentage and although the impact may be significant to those specific individuals it is not significant in relation to the population as a whole.

The procurement of local goods and services will benefit those supplying the Project however this may result in an increase in demand for certain supplies resulting in an increase in prices and a decrease in availability. Those disadvantaged and vulnerable households could be adversely affected by any price fluctuations and local procurement may therefore increase vulnerability. Due to the small scale of the project and the lack of enterprises in the local communes it is likely that the majority of goods and services will not be procured locally and therefore this impact is unlikely to be significant.

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Table 10.25 Assessment of Impact

Impact Severity - Low

• Nature: This will be a positive direct, indirect and induced impact for those employed by the Project or supplying to the Project, however for those vulnerable households and those no longer with access to agricultural land this will be a negative direct and indirect impact. • Impact Extent: Of the 50 construction labourers only around 15 will be locally employed this is will likely be from Independenta, Chirnogeni and Constanta and therefore the impact will be local. • Impact Duration: The impact will occur during the construction period of 18 months and will therefore be of a short-term impact. • Ability to Adapt: Due to the short-term of the project phase, the technical nature of the project and the low skills levels in the local villages it is likely that ability to adapt will be low.

Probability – the Project will definitely employ locally and definitely rezone local agricultural land however both will be limited and therefore the probability of the impact occurring will be probable.

IMPACT SIGNIFICANCE – MINOR POSITIVE IMPACT

Table 10.26 Summary of Impact for construction

Impact Construction (Negative Construction (Positive impact on livelihoods) impact on Livelihoods)

Severity Low Low Nature Negative, Direct and Positive, Direct, indirect and indirect induced Extent Local Local Duration Short-Term Short-Term Ability to adapt Low Low Probability. Highly Probable Highly Probable SIGNIFICANCE (pre- MINOR MINOR mitigation).

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Mitigation

Objective

Increase the positive impacts the Project may have on livelihoods and reduce any negative impacts.

Measure

Amount spent in the local communes in terms of procurement.

10.6.6 Impacts on Health

The introduction of temporary construction labour for development projects is usually associated with an increase in vulnerability and susceptibility of local communities to social pathologies, including drug and alcohol abuse, increased incidence of sex workers, teenage pregnancies, and domestic violence as well as the import of diseases.

Table 10.27 Summary of Impact Characteristics

Summary Construction

Project Aspect/ activity Construction of the project and associated arrival of construction labour.

Impact Type Negative, indirect impact

Stakeholders/ Receptors Affected Independenta and Chirnogeni Communes

The Project is relatively small and an estimated construction staff of 50 will be employed, around 35 of which will non-locals. There is no evidence that migrant workers have introduced similar difficulties associated with import of diseases in the past and due to the relatively small scale of the project and construction staff it is likely that the impact on host communities will be limited. Smoking, alcohol and drug abuse are not generally considered to be significant problems in the area and the Project is not expected to have any impact on this issue.

There will be an increase in traffic and heavy vehicles during construction. During peak construction there will be up to 58 heavy vehicle movements per day and up to 44 light vehicle movements. This increase in traffic may result

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in an increase in road traffic accidents as local villages may not be aware of the associated dangers. This impact could be exacerbated if construction vehicles are on the roads after dark or during peak hour traffic. Chapter 7 of the ESIA describes mitigation measures to be applied for the increase in road traffic.

There will be a risk of increased injuries through accidents on the construction site and the following key health and safety risks have been identified for construction and future operations:

• falling from height; • falling objects; and • lifting operations - cranes/forklifts, and • contractor’s activities and their management.

Table 10.28 Assessment of Impact

Impact Severity - Moderate

• Nature: This will be a negative indirect impact. • Impact Extent: The impact will be restricted to local communes and therefore the extent is local. • Impact Duration: The impact will occur during the construction period of 18 months and will therefore be of a short-term impact. • Ability to Adapt: High

Probability –As there will be around 35 non-local labourers housed in a construction camp the likelihood of the impact occurring is probable

IMPACT SIGNIFICANCE – MODERATE NEGATIVE IMPACT

Table 10.29 Summary of Impact for construction

Impact Construction

Severity Moderate Nature Negative, indirect Extent Local Duration Short-Term

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Impact Construction

Ability to adapt High Probability. Probable SIGNIFICANCE (pre- MINOR mitigation).

Mitigation

Objective

To limit any health impacts and to ensure road and other safety for the local communities.

Measure

• Traffic: EPGE will consult with the local authority to discuss the implications of increased traffic to the project area. A Traffic Management Plan will be prepared and agreed in consultation with the local authority and implemented by the construction contractor. This is likely to set out: the general measures used to mitigate the environmental impact of traffic associated with construction activities; and provide information on the more detailed site specific measures to be employed during construction • On-site Accidents: In order to minimise accidents, EPGE will consider transporting equipment and construction materials to the site outside of rush hour periods. According to the baseline traffic data on the sector Techirghiol- Agigea, rush hour period was recorded between 0800- 0930 and 1700-1800. The transportation of over-size loads will comply with all applicable regulations and conditions stipulated in the relevant permit and will be accompanied by appropriate safety vehicles. Construction personnel will be trained with regard to health and safety risks associated with the construction of wind farms and necessary measures to avoid incidents. For each of the risks identified above, the Health and Safety Action Plan which will be developed by EPGE will foresee control measures and identify further requirements. As part of Engineering Procurement and Construction Contract (EPC) specific

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operation procedures (SOP) are being developed for each. The contractor will also provide construction workers with adequate personal protective equipment and instruct them how to use it.

10.6.7 Impacts on Infrastructure

Construction of the project will require the use of certain infrastructure namely local roads, water and electricity. Drinking water will be provided by tanker and chemical toilets will be used. All waste will be transported off site to registered waste facilities.

Table 10.30 Summary of Impact Characteristics

Summary Construction

Project Aspect/ activity Construction activities and utilisation of a construction camp. Impact Type Negative, indirect impact Stakeholders/ Receptors Affected Local Communes and villages

The main access to the project site is currently via the National Road DN 38 Constanţa – Mangalia and the County Roads DJ 391 and DN 39 via the commune road Dc 16. During peak construction there will be up to 58 heavy vehicle movements per day and up to 44 light vehicle movements. This may increase the volumes of the traffic and cause disruption to traffic flow. These local roads are unlikely to have been constructed to withstand heavy vehicle traffic and therefore could result in the degradation of road surfaces. EPGE will upgrade the existing Commune roads and existing exploitation roads and cover them with gravel during construction phase as well as constructing a network of new access roads located within the project site (these will be constructed of aggregate materials). This upgrade will benefit the local residents who use the roads to access agricultural areas. Construction of the Project will therefore lead to the long-term improvement of local infrastructure by the upgrade of existing roads and the construction of a network of new roads to provide access to the turbines as follows:

• the upgrade of approximately 1.3 km of asphalt road leading to the pig farm; • the upgrade of approximately 26 km of existing roads; and

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• the construction of approximately 12.5 km of new roads to provide access to the turbines. The construction of the Project will require temporary restriction of the local traffic to allow the transport of turbine components, this is assessed in Chapter 7.

EPGE does not plan to upgrade any of the national or county roads however these will still be used during the construction phase by light and heavy vehicles to access the site. It is likely that the large number of vehicles over the 18 month period will result in a reduction in quality of road surface. This could have additional knock-on effects such as damage to motor vehicles, creation of road accidents and the increase in costs to both national government and county management.

During construction EPGE will tanker in water for any requirements for the construction camp. This will be sourced from a local specialised company in Constanta and will not place additional pressure on local water services. Electricity for construction will provided via one generator with a power of 125 kW to supply the projects electrical needs. The Construction of the Project is therefore unlikely to place additional demands on local infrastructure.

Table 10.31 Assessment of Impact

Impact Severity - Low

• Nature: This will be a negative indirect impact for impact on the national and county roads and a positive indirect impact on commune roads. • Impact Extent: As national, county and commune roads will be used to transport material the extent of the impact will be local, regional and national. • Impact Duration: The impact will occur during the construction period of 18 months and will therefore be of a short-term impact. • Ability to Adapt: medium

Probability – EPGE will definitely need to transport construction material via the road and have committed to upgrading local commune roads therefore the likelihood of the impact is probable

IMPACT SIGNIFICANCE – MINOR POSITIVE AND NEGATIVE INDIRECT IMPACT

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Table 10.32 Summary of Impact for construction

Impact Construction (Use of Construction (Upgrade and national and County roads) use of commune roads)

Severity Moderate Moderate Nature Negative, indirect Positive, indirect Extent Regional and national Local Duration Short-Term Short-Term Ability to adapt Medium Medium Probability. Probable Probable SIGNIFICANCE (pre- MINOR MINOR mitigation).

Mitigation

Objective

To ensure additional pressure is not placed on local infrastructure and to mitigate any impacts on infrastructure arising from the Project. To ensure that resource use is monitored and managed acceptably.

Measure

• Traffic: EPGE will consult with the local authority to discuss the implications of increased traffic to the project area. A Traffic Management Plan will be prepared and agreed in consultation with the local authority and implemented by the construction contractor. This is likely to set out: the general measures used to mitigate the environmental impact of traffic associated with construction activities; and provide information on the more detailed site specific measures to be employed during construction • Resource use: All water will be transported onto site by tanker and all waste (water, sewage, general waste) will be collected and transported to registered waste sites for disposal.

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10.6.8 Impacts on Archaeology and Cultural Practices

Table 10.33 Summary of Impact Characteristics

Summary Construction Project Aspect/ activity Construction activities Impact Type Negative, direct impact Stakeholders/ Receptors Affected Local Communes and villages

According to the information collected from the local commune administration, the Project will have no impact on the local community way of life or on sites of importance to them.

Based on the locations of the discoveries identified on site, illustrated in the map shown in the Figure 10.5, the construction works for the installation of the underground electrical cables between turbines T5 and T13 will potentially affect one of the tumuli, as discussed in Section 10.4.14. According to the Romanian Archaeology Law no. 422/2001, these tumuli are not considered to be monuments of particular archaeological importance and no buffer area needs to be allocated by the developer around such discoveries.

It is anticipated that following consultation with the authorities and the implementation of appropriate mitigation measures, no significant impacts will occur to archaeological sites.

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Table 10.34 Assessment of Impact

Impact Severity - Low

• Nature: This will be a negative direct impact on archaeological sites. • Impact Extent: Tumili are not considered to be of archaeological importance and therefore any loss due to the Project will be of local extent. • Impact Duration: Any impact to archaeological sites due to the project will be permanent of nature. • Ability to Adapt: N/A

Probability – It is highly probable that the Project will disturb one Tumuli.

IMPACT SIGNIFICANCE – MINOR NEGATIVE DIRECT IMPACT

Table 10.35 Summary of Impact for construction

Impact Construction

Severity Low Nature Negative, direct Extent Local Duration Permanent Ability to adapt N/A Probability. Highly Probable SIGNIFICANCE (pre-mitigation). MINOR

Mitigation

Objective

To ensure that all potential impacts to archaeological and cultural heritage are limited and managed.

Measure

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• EPGE will consult with the Constanta County Directorate for Culture, Religious Affairs and Cultural Heritage in order to agree appropriate mitigation measures to avoid or reduce any potential impact to this tumulus. Mitigation measures may include the supervision of excavation works in area of this tumulus by an archaeological expert. • Any chance finds during excavation works will be reported to the Constanta County Directorate for Culture, Religious Affairs and Cultural Heritage within 72 hours of discovery and fenced off from the area regulated by the construction permit and investigated/excavated (during this time it is protected as an archaeological site from disturbance).

10.7 OPERATIONAL IMPACTS

10.7.1 Introduction

This section describes the social and health impacts associated with project operational activities. These may include the following:

• impacts to land use; • employment generation: direct, indirect and induced; • impacts on livelihoods; • impacts on health; • impacts on infrastructure; and • impacts on archaeology and cultural practices.

10.7.2 Impacts on Land Use

As discussed in Section 10.6.2 the Project Site consists of 16.9 km2 of land owned by Independenta and Chirnogeni Communes and parcels of land owned by EPGE. The Project Site also consists of a buffer area which needs to be allowed between the Project turbines and turbines which other developers may plan to construct in the area. Of the total Project Site (16.9 km2) less than 1 km2 (0.124 km2) will be rezoned for industrial purposes and will no longer be used for agriculture. This will be a long-term loss of land currently used for farming activities. The actual area lost to agriculture will be small.

The impact generated by the Project on land use is not considered to be significant as farming will be possible on the land within the Project site (outside the safety zone of each turbine) which is not necessary for the

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operation and maintenance activities. No homes or businesses will be displaced by the Project.

Table 10.36 Assessment of Impact

Impact Severity - Low

• Nature: This will be a negative direct impact. • Impact Extent: The loss of land will have an effect on local communes and will therefore be a local impact. • Impact Duration: The loss of agricultural land will be for the life of the Project and will therefore be a long-term impact. • Ability to Adapt: As the size of land being rezoned is small and the rest of the project site will be available for agriculture the ability to adapt is considered Medium

Probability – An area of land will definitely need to be rezoned for industrial purposes where no agriculture may take place therefore the impact is Definite

IMPACT SIGNIFICANCE – MINOR NEGATIVE IMPACT

Table 10.37 Summary of Impact for operation

Impact Construction

Severity Low Nature Negative, direct Extent Local Duration Long-term Ability to adapt Medium Probability. Definite SIGNIFICANCE (pre- MINOR mitigation).

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Mitigation

Objective

To manage and mitigate the direct loss of access to and use of agricultural land.

Measure

• Ensure that access to land used for agriculture is limited for safety and security reasons and that local communes are consulted regarding a reduction in access prior to operations. • Ensure all land used temporarily during construction is fully rehabilitated and returned to its use prior to opeartions.

10.7.3 Revenue Generation for Local Government

Table 10.38 Summary of Impact Characteristics

Summary Construction

Project Aspect/ activity Renting land for operations Impact Type Indirect Stakeholders/ Receptors Affected Constanta County

The Project Site is currently used as agricultural land by the local communes. Prior construction the project footprint will be rezoned from agriculture to industrial. EPGE will pay annual taxes for the land it owns for the lifetime of the wind farm. These taxes will go directly to the budgets of the local communes.

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Table 10.39 Assessment of Impact

Impact Severity - Low

• Nature: This will be a positive indirect impact. • Impact Extent: Taxes will be paid directly to the budget of local communes and therefore the extent of the impact is local. • Impact Duration: The impact will occur during operation of the Project which at a minimum is expected to extend for 20 years and therefore the impact is long-term. • Ability to Adapt: high

Probability –EPGE purchased this land and will need to pay annual taxes to the local communes and therefore probability of the impact occurring is highly probable

IMPACT SIGNIFICANCE –MINOR POSITIVE IMPACT

Table 10.40 Summary of Impact for operation

Impact Construction

Severity Low Nature Positive, indirect Extent Local Duration Long-term Ability to adapt High Probability. Highly Probable SIGNIFICANCE (pre- MINOR mitigation).

Mitigation

Objective

The EPGE will ensure that the agreed payments to government are made in a timely and transparent manner.

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Measures

• Ensure that sound financial management systems are put in place within the wind farm and EPGE.

10.7.4 Operational Employment

Table 10.41 Summary of Impact Characteristics

Summary Construction

Project Aspect/ activity Employment

Impact Type Negative, indirect impact

Stakeholders/ Receptors Affected Independenţa, Chirnogeni Communes and Constanta County

Direct Employment

The life of the Project is expected to be at least 20 years during which time a small workforce will be required to maintain activities and ensure non-stop coverage. EPGE estimates that the workforce during operations will be a total of nine people, four of which to perform maintenance activities and five to ensure non-stop coverage of the dispatch tasks. It is anticipated that these workers will be employed locally and trained accordingly by the Specialists of the Design Company. This will give long-term income stability to those full- time employees and will have a significant effect on their lives. Within the local economy however this is a small number of people at less than 1 % of Independenţa and Chirnogeni Communes.

Indirect and Induced Employment

Indirect employment will occur through increased spending due to an increase in income and income stability of those employed by EPGE. Due to the small number of people likely to be employed during operations, a total of nine, this is unlikely to result in any significant indirect benefit.

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Table 10.42 Assessment of Impact

Impact Severity - Low

• Nature: This will be a positive direct, indirect and induced impact. • Impact Extent: Employment will likely be from the local communes and therefore the extent of the impact is local. • Impact Duration: The impact will occur during operation of the Project which at a minimum is expected to extend for 20 years and therefore the impact is long-term. • Ability to Adapt: high

Probability –EPGE aims to employ locally during operations and therefore the probability of the impact occurring is highly probable

IMPACT SIGNIFICANCE – NEGLIGIBLE POSITIVE IMPACT

Table 10.43 Summary of Impact for operation

Impact Construction

Severity Low Nature Positive, direct, indirect and induced Extent Local Duration Long-term Ability to adapt High Probability. Highly Probable SIGNIFICANCE (pre- NEGLIGIBLE mitigation).

Mitigation

Objective

The project will aim to maximise local employment during construction.

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Measures

• prioritise employment of local labour by setting criteria for prioritising, firstly labour from Independenta and Chirnogeni and secondly from Constanta County; and • clearly advertise criteria for skills and experience needed for available jobs through local media.

10.7.5 Impacts on Livelihoods

Table 10.44 Summary of Impact Characteristics

Summary Construction

Project Aspect/ activity Employment: direct, indirect and induced Impact Type Direct, indirect and induced Stakeholders/ Receptors Local Communes, potentially Constanta County Affected

Similar to the impact on livelihoods during construction, as shown in Section 10.6.5, the Project will have two impacts on livelihoods both positive and negative.

The reduction of available agricultural land due to rezoning will have an impact. During operation only the Project footprint will be unavailable for agriculture; however the impact will be reduced from the construction phase and will unlikely be significant.

The impact on livelihoods through an increase in income generated through direct, indirect and induced income is likely to be minimal during this phase. It is estimated that nine local people will be employed during operations a very small number of the total population of Independenta and Chirnogeni Communes. The procurement of local goods and services is also likely to be minimal during operations and unlikely to have a impact on local inflation or communes.

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Table 10.45 Assessment of Impact

Impact Severity - Low

• Nature: This will be a negative direct for those who no longer have access to agricultural land and a positive direct and indirect impact for those employed by the Project or supplying the Project. • Impact Extent: potential impacts will be felt by the local communes and therefore be of local extent. • Impact Duration: The impact will occur during operation of the Project which at a minimum is expected to extend for 20 years and therefore the impact is long-term. • Ability to Adapt: Medium

Probability – As very few local people will be employed the impact on livelihood is low. As only a small amount of land will be used during operation the probability that agricultural activities will be impacted in medium.

IMPACT SIGNIFICANCE – NEGLIGIBLE NEGATIVE and POSITIVE INDIRECT IMPACT

Table 10.46 Summary of Impact for operation

Impact Construction (negative Construction (positive impact on livelihoods) impact on livelihoods)

Severity Low Low Nature Negative, direct Positive, direct and indirect Extent Local Local Duration Long-term Long-term Ability to adapt Medium Medium Probability. Medium Probable Low Probable SIGNIFICANCE (pre- NEGLIGIBLE NEGLIGIBLE mitigation).

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Mitigation

To ensure that the benefits to livelihoods in the communities around the project is maximised.

Measure

• ensure that the all full time employment is given to local community members; and • provide training to enable local community members (skilled and semi- skilled workers) to take advantage of the employment.

10.7.6 Impacts on Health

Table 10.47 Summary of Impact Characteristics

Summary Construction

Project Aspect/ activity Operation of the wind farm and employment of foreign labour Impact Type Negative, indirect impact Stakeholders/ Receptors Affected Independenţa, Chirnogeni Communes and Constanta County

Energy producing facilities often have adverse effects on human health for various reasons namely the creation of pollution and influx of foreign workers resulting in the increase in social pathologies. In this instance, however, it is expected that all employees recruited for operations will be from local communes. As a result there will be no foreign labourers employed during operation and unlikely to have any resultant increase in social pathologies or import of new diseases to the area. This also means that there will be no added burden on local health facilities in the local communes.

The operation of the wind farm will have no negative impact on air quality.

On the contrary, the wind farm will displace 104,279 tonnes of CO2 per year, which could otherwise be produced by non-sustainable sources such as the burning of fossil fuels.

During operation, the vehicle movements to the site are estimated to be at maximum 4 light vehicle movements (8 trips) per day. Traffic emissions will

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therefore be negligible and have no adverse effects on air quality and human health.

The Project is unlikely to introduce any risks to public health and safety as operations will be mostly automatic and clean. Operations personnel will be trained on safety issues associated to the operation and maintenance of wind turbines.

Table 10.48 Assessment of Impact

Impact Severity - Low

• Nature: This will be a negative indirect impact. • Impact Extent: potential impacts will be felt by the local communes and therefore be of local extent. • Impact Duration: The impact will occur during operation of the Project which at a minimum is expected to extend for 20 years and therefore the impact is long-term. • Ability to Adapt: High

Probability –As there are unlikely to be any foreign employees during operations and only nine staff employed in total the probability of the impact occurring is Low

IMPACT SIGNIFICANCE – NEGLIGIBLE NEGATIVE IMPACT

Table 10.49 Summary of Impact for operation

Impact Construction

Severity Low Nature Negative, indirect Extent Local Duration Long-term Ability to adapt High Probability. Low Probable SIGNIFICANCE (pre- NEGLIGIBLE mitigation).

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Mitigation

To limit the health implications, spread of disease or increase in social pathologies due to the project and to manage this spread where they do occur.

Measure

EPGE will consult with the competent authority to discuss the implications of increased traffic to the project area during operation. Any traffic management measures that the competent authority may request will be considered and included in the Traffic Management Plan prepared for construction.

10.7.7 Impacts on Infrastructure

The operation of the Project will not require water supply to the site. Electricity for the operation of the wind farm will be self sufficient. Therefore, supplies utilities to the Project are not expected to adversely affect availability in the local area.

10.7.8 Impacts on Archaeology and Cultural Practices

There will be no direct impacts on archaeological sites during operation of the wind farm.

Table 10.50 Summary of Socio-economic Impact Significance

Impact Construction Operation Land Use Revenue Generation for Local N/A Government Employment: Direct, indirect and induced Livelihoods

Health Infrastructure N/A

Archaeology and Cultural N/A Practices

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Table 10.51 Significance of color coding of socio-economic impacts

COLOR USED IMPACT SIGNIFICANCE IMPACT MAGNITUDE FOR CODING

NEGLIGIBLE NEGATIVE IMPACT

MINOR NEGATIVE IMPACT

NEGLIGIBLE POSITIVE IMPACT

MINOR POSITIVE IMPACT

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11 OTHER OPERATIONAL IMPACTS

11.1 INTRODUCTION AND SCOPE

The operation of wind farms raises the potential for a number of other specific impacts relevant to this type of development, which are examined in this chapter. These are:

• electromagnetic interference (see Section 11.2); • shadow flicker (see Section 11.3); and • ice throw (see Section 11.4).

11.2 ELECTROMAGNETIC INTERFERENCE (EMI)

11.2.1 Introduction

This section examines the potential effects that the wind farm may have on the surrounding environment, due to electromagnetic interference (EMI). Wind turbines can potentially disrupt electromagnetic signals used in a range of telecommunication, navigation and radar services. This section also describes the mitigation measures that can be put in place to reduce any impacts.

Wind turbines may cause EMI via three principal mechanisms namely, near field effects, diffraction and reflection/scattering(80). Near field refers to the potential of a wind turbine to cause interference due to electromagnetic fields emitted by the turbine generator and switching components. Diffraction occurs when the wind turbine not only reflects but also absorbs a telecommunications signal. Reflection and scattering occur when a wind

(80) Bacon, D.F. (2002) “Fixed-link wind-turbine exclusion zone method: A proposed method for establishing an exclusion zone around a terrestrial fixed radio link outside of which a wind turbine will cause negligible degradation of the radio link performance.

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turbine either obstructs or reflects a signal between a transmitter and receiver (81).

The nature and amount of EMI from each three mechanisms depends on:

• the location of the wind turbine relative to the transmitter and receiver; • the characteristics of the rotor blades; • the signal frequency; • receiver characteristics; and • the radio wave propagation characteristic in the local atmosphere. In Romania, the National Authority for Communications (ANCOM) is the government agency with central responsibility for protection of the radio spectrum, including the assessment of electromagnetic interference from developments in the vicinity of a radio facility. Key consultee comments regarding potential impacts of EMI on local services are outlined below.

Table 11.1 Summary of Consultees and Comments

Organisation Comment County Police Inspectorate They consider that the project will not influence any activity of the Police department with regard to radio systems. Civil Romanian Aeronautical Authority The RCAA will consider the project (CAA) following the application for a permit. This will involve the preparation of an official request letter, together with a Technical Memorandum which should contain information about the site. Usually this permit is obtained prior to the completion of the EIA procedure.

(81) IFC (2007) Environmental, Health, and Safety Guidelines for Wind Energy

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Organisation Comment National Authority for Communications ANCOM consider that the project should (ANCOM) not apply for a prior agreement unless other stakeholders require for it.

11.2.2 Assessment of Impacts

Introduction

An initial desktop review of telecommunication infrastructure and related users located in the vicinity of the proposed wind farm identified the following:

• licensed radio communication systems (police, fire fighter, ambulance); • mobile phone services provided by a range of companies; • television broadcasting using transmission towers and repeater stations; and • aircraft navigation systems and radio towers managed by Romanian Civil Aeronautical Authority and the Ministry of Defence, located approximately 30-40 km to the northeast of the project site (in the vicinity of the Mihail Kogalniceanu Commune).

Radio Communication

Broadcast radio transmissions are received at radio receivers after radio signals have travelled through free space and often through structures. Because of this method of transmission and reception, it can be concluded that the proposed wind farm would have no detrimental effects on national or local radio in the vicinity of the proposed development.

Mobile phone interference occurs when the turbines are located within the immediate vicinity or ‘near field’ of an antenna. The closest mobile phone mast is located In Independenta village, at approximately 15 km away to the west from the project site.

Consultation undertaken with the County Police Inspectorate has confirmed that they consider that the project will not influence any activity of the Police department.

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No significant impacts on radio reception or mobile phone services are anticipated.

Television Broadcast Systems

For television broadcast systems, a wind farm located between a television transmitter and a receiver aerial may cause loss of picture detail, loss of colour or a buzz on sound. Viewers situated adjacent to a wind farm may experience a delayed image or ‘ghost’ on the picture, liable to flicker as the blades rotate. In some cases, a wind farm can also affect the re-broadcast link (RBL) feeding the transmitter. Impacts to television broadcast systems due to the operation of the turbines is such that it can easily identified. Therefore if impacts are experienced, appropriate highly effective mitigation will be implemented by EPGE and may include the following.

• modification to or provision of a receiving aerial; • improvement of an existing antenna system; and/or • provision of a satellite receiving antenna. Currently the TV broadcasting in the project area is almost entirely cable systems, therefore it is unlikely that any significant impacts will be experienced.

Aircraft Navigation Systems

There is a potential for rotating turbine blades to generate interference to air traffic control and defence radar displays. This may affect wind turbine developments as much as 75 km away from a radar. The most effective way to ensure that the interests of all parties are balanced is through a process of informal pre-planning consultation.

The Civil Romanian Aeronautical Authority (CAA) were consulted in a preliminary stage of the EIA procedure regarding potential impacts from the project on aircraft navigation systems at Mihail Kogalniceanu Airport which is located approximately 30 km away to the northeast of the site. They consider that this issue will be subject to a separate approval which and have stipulated the following conditions:

• the wind turbines including the tower, nacelle and blades will be painted in white;

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• the turbine towers must be lit during the daytime with white coloured lights with a maximum intensity of 20,000 cd (in accordance with the requirements of the Romanian Civil Aeronautic Authority); • the turbine towers must be lit during at night and during weather conditions which create limited visibility (fog, rain and snow). The lights should flash white-red at maximum intensity (in accordance with the requirements of the Romanian Civil Aeronautic Authority). According to the feature of the turbine design the radar interference will be minimised. This issue has been considered also with the layout of the turbines, being a dense cluster of turbines, as opposed to a long string of turbines (which would present a wider spectrum of interference to any radar)

A relevant Air Traffic Services will be notified of the wind farm plans and construction schedule prior to construction.

11.3 SHADOW FLICKER

11.3.1 Introduction

Shadow flicker is a flickering or strobing effect that moving shadows of rotating blades can cause when perceived by humans. Shadow flicker is not cast when the sun is obscured by clouds/fog or when the turbine blades are not rotating. This effect can be a nuisance but it should be stressed that the frequencies involved mean it is unlikely to cause epileptic seizures, an effect that can be caused by strobing.

The probability of shadow flicker occurring and the extent of its effect depend on different factors such as the direction and distance of the residential property in relation to the turbine, turbine hub height and rotor diameter, speed of blade rotation, time of year, and the proportion of daylight hours in which the turbines are in operation.

Shadow flicker intensity is can be determined as the difference in brightness at a certain location in the presence and absence of a shadow.

The following physical circumstances need to apply simultaneously before shadow flicker can occur:

• the building must be within 10 turbine diameters of the turbine; • the sun must be shining;

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• the wind turbine must be operating (wind speeds must therefore be at least about 3.4m s-1); • the moving shadow cast by rotating blades must be seen from within a building, particularly when viewed through a narrow window; • the orientation of the turbine and its angle of elevation to the observer must coincide with the angle and the position of the sun in relation to the building so that the shadow falls onto the building; and • since the origin of the effect is the sun, dwellings that may be affected must lie to the north of the point where the sun rises and sets. Where these circumstances pertain the exact position of shadows can be calculated very accurately for each sensitive location for the key times of day and year to determine the potential for shadow flicker.

11.3.2 Assessment of Impacts

The turbines which EPGE will use will have a rotor diameter of 90 m. A dwelling would therefore need to lie within 900 m of the project site boundary in order to experience shadow flicker.

It should also be noted that the project turbines will operate at a rotational speed of 9.6-16 rpm. This is considered to be relatively slow and reduces the flickering effect significantly. The frequency at which shadows pass over any point is referred to as the ‘blade passing frequency’. Frequency measurement data obtained from assessment studies for turbines which have similar rotational speed to the project turbines indicate that there will be a blade passing frequency of approximately 0.3 Hz to 0.975 Hz. Conclusions made by Clarke (1991)(82) indicate that blade passing frequencies which can cause shadow flicker nuisance and disturbance to humans exceed 2.5 Hz.

The nearest property to the wind farm is located at approximately 1.6 km to the southeast of the site boundary (the distance measured from the property

(82) Clarke, A.D. (1991) A case of shadow flicker/flashing: Assessment and Solution, British Wind Energy Association Annual Conference

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to turbine 31 – the closest turbine to the former pig farm situated near Chirnogeni) – See Annex 1 - Site Location Map. Overall, no significant impacts to residential properties are anticipated with regard to shadow flicker due to the distance between the proposed turbines and the inhabited areas.

Shadow flicker has also been raised as a possible problem for drivers of vehicles. The nearest minor road to the project site is the Commune Road Dc 16 Plopeni-Chirnogeni-National Road DN 38, which is located approximately 3.1 km to the east from the nearest turbine (no. 27). The nearest main road is the National Road 38 Constanta – Negru Voda, which is located approximately 4.9 km to the southeast from the nearest turbine (no. 32). Both these roads lie outside the zone potentially affected by shadow flicker and therefore no impacts are anticipated to occur.

11.4 ICE THROW

11.4.1 Introduction

Wind farms operating in cold climates may suffer from icing in certain weather conditions and a failure in the rotor blade or ice accretion can result in the ‘throwing’ of a rotor blade or ice from the wind turbine, which may affect public safety.

The accumulation of ice is highly dependent on local weather conditions and the turbine’s operational state. Any ice that is accumulated may be shed from the turbine due to both gravity and the mechanical forces of the rotating blades. An increase in ambient temperature, wind, or solar radiation may cause sheets or fragments of ice to loosen and fall, making the area directly under the rotor subject to the greatest risks. In addition, rotating turbine blades may propel ice fragments some distance from the turbine— up to several hundred meters if conditions are right. Falling ice may cause damage to structures and vehicles, and injury to site personnel and the general public, unless adequate measures are put in place for protection.

11.4.2 Assessment of Impacts

The climate in Constanta County is generally considered to be continental temperate (warm summers and cooler, wetter winters). The proximity of the Black Sea (approximately 35 km to the east of the site) and the River Danube (approximately 45 km to the north- west of the site) has a moderating influence on the temperature with annual 24hr average temperatures ranging

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from 0.7°C in January to 22.2°C in July(83). The temperature can reach a minimum average of between -2 and -3°C in January(84).

Ice throw is only deemed a potential problem where there is the possibility of human receptors being in close proximity to the turbines. Whilst there are no recorded rights of way on site, the area is used by farmers and there are 5 turbines located within 100m distance to the existing paths and tracks on the site.

Experience from other operated wind farms indicates that the resultant risk from icing is very low. EPGE have taken steps to reduce an potential impact from ice throw in the design of the project as follows.

• The siting of the turbines is a safe distance from residential buildings, roads and public areas. • Regular maintenance will be undertaken of the turbines. • Warning signs will be erected in appropriate places to alert the site personnel and public of the risk. • Monitoring of temperature and icing at the site anemometry mast, as well as early operational experience will input into a detailed risk assessment. • Automatic shutdown of the turbines will occur should site personnel or the nacelle-mounted ice sensor detect ice accumulation. • Site access will be restricted while ice remains on the turbine structure and safety measures will be taken such as the remote shutting down the turbine and the use of personal protected equipment should access be necessary for site personnel. With the implementation of the above mitigation measures during the design and operational phase of the project, any potential impacts will be reduced to negligible.

(83) www.worldclimate.com

(84) http://www.climate-charts.com/Locations/r/RO15480.php

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12 CUMULATIVE IMPACT ASSESSMENT

12.1 CUMULATIVE LANDSCAPE AND VISUAL IMPACTS

12.1.1 Introduction

The preceding sections of this report have addressed the impacts of Chirnogeni Wind Farm in isolation. Legislation requires EIA to also address the cumulative impacts of a proposal together with other projects present, as well as those under development or planned in the area.

Following consultations with the relevant authorities, at the time of writing this assessment, there were 16 proposed wind farm projects located within 30 km of Chirnogeni Wind Farm 80 MW (including those referred to under section 12.2.2). Out of these, two have been brought to the attention of the planning authorities and are at the scoping stage in the planning process.

In line with requirements agreed by European Bank for Regional Development, an assessment of possible cumulative landscape and visual impacts for the Chirnogeni Wind Farm 80 MW was conducted, taking into account the two wind farms referenced in Table 12.1 below. Design data available for both of these wind farm projects was limited to the number of wind turbines and the position of each. Data on the height of the wind turbines was not available for either of these projects. The cumulative assessment therefore assumes that the wind turbines associated with these schemes will be of the same height as Chirnogeni Wind Farm which is 145 m to the tips of the blades.

Details of the two wind farm projects considered are presented in Table 12.1 below. Data on the number of turbines and the distance to Chirnogeni Wind Farm are also provided.

Table 12.1 Proposed wind farms considered for the scope of the cumulative landscape and visual impact assessment

Name No. of Status Location and distance from Turbines Chirnogeni

Deleni 123 Scoping 14,9 km NNW

Pecineaga A 31 Scoping 17,8 km E

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The cumulative assessment assumes that Deleni Wind Farm and Pecineaga A Wind Farm will both be present in the landscape alongside Chirnogeni Wind Farm.

Methodology

Cumulative landscape and visual effects may result from additional changes to the baseline landscape or visual amenity caused by the proposed Chirnogeni Wind Farm in combination with both Deleni and Pecineaga A Wind Farms.

The assessment identifies the additional contribution of the Chirnogeni Wind Farm to the magnitude of change experienced as a result of the two other wind farms in the study area. The magnitude of cumulative change arising from the proposed Chirnogeni Wind Farm is assessed as large, medium, small or imperceptible, based on an interpretation of the following (largely quantifiable) parameters, to take account of cumulative change:

• number of proposed wind farms and wind turbines visible; • distance to proposed wind farms; • direction and distribution of proposed wind farms; • landscape setting, context and degree of visual coalescence of proposed wind farms; and • proportion of developed/undeveloped skyline occupied by proposed wind farms. The principle of magnitude of cumulative change makes it possible for the proposed wind turbines to have a major visual effect on a close receptor while having only a minor cumulative effect from the same viewpoint. For example, a major visual impact may be experienced at a viewpoint located close to Chirnogeni Wind Farm where the wind turbines are seen as large elements in the view however if, for example, there is another wind farm present in the landscape visible from this same viewpoint and it is located closer to the viewer than Chirnogeni and is a bigger scheme comprising many more turbines, then Chirnogeni may be seen to contribute a small amount to an already developed skyline. Thus a small magnitude of cumulative change would be assessed to arise on a viewpoint of high sensitivity thereby resulting in a minor cumulative effect.

The significance of any identified cumulative landscape or visual effect has been assessed as major, moderate, minor or not significant in relation to the

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sensitivity of the receptor and the predicted magnitude of cumulative change as outlined above.

• Major - substantial additional change in conjunction with other developments affecting the character or views of the landscape or the elements within. • Moderate - additional change in conjunction with other developments affecting the character or views of the landscape or the elements within. • Minor - slight change in conjunction with other developments affecting the character or views of the landscape or the specific elements within. • Not significant – no or minimal perceptible additional change in conjunction with other developments affecting the character or views of the landscape or the specific elements within.

Residual Cumulative Effects - Cumulative Zones of Visual Influence within 30 km

The assessment considers the potential for cumulative impacts within a 30 km radius area from the centre of the Chirnogeni Wind Farm. The theoretical cumulative zone of visual influence (ZVI) comprises those parts of the ZVIs for the other two wind farms (Deleni and Pecineaga A) which overlap with the 30 km ZVI for Chirnogeni Wind Farm. The ZVIs for the other two wind farms cover an area of 30 km radius, in line with best practice guidance.

The individual cumulative ZVIs for each of the two wind farms, Deleni and Pecineaga A together with Chirnogeni are presented in Annex 27 - Zone of visual influence map: Chirnogeni and Deleni combined visibility and Annex 28 - Zone of visual influence map: Chirnogeni and Pecineaga A combined visibility.

A combined cumulative ZVI showing the wind farms theoretically visible in addition to Chirnogeni over the study area is presented in Annex 29 - Zone of visual influence map: Chirnogeni, Deleni and Pecineaga A combined visibility. This cumulative visibility analysis takes account of both wind farms Deleni and Pecineaga A.

12.1.2 Residual cumulative effects on landscape character

Residual cumulative impacts on landscape character will arise when Chirnogeni Wind Farm can be seen from a given landscape along with other wind farms included in the cumulative assessment such as Deleni and Pecineaga A.

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The combined cumulative ZVI (Annex 29 - Zone of visual influence map: Chirnogeni, Deleni and Pecineaga A combined visibility) illustrates in red, the areas where both Deleni and Pecineaga A Wind Farms are theoretically visible in addition to Chirnogeni. The figure illustrates in yellow, the areas where Chirnogeni Wind Farm and one other wind farm is theoretically visible. This could be either Deleni or Pecineaga A. Finally the colour green identifies areas where only Chirnogeni Wind Farm is visible and therefore in these areas, no cumulative impacts on landscape character are predicted to arise.

In reality, the areas where either of these wind farms will be visible along with Chirnogeni Wind Farm is likely to be less than that illustrated on the figures owing to the visual screening provided by intervening vegetation and buildings. The data used to calculate the ZVIs does not taken into account small changes in topography or existing vegetation.

Residual Cumulative Impacts on the large flat plateau or plains landscape character type.

A limited area of flat farmland (characterised as large flat plateau or plains) located west of the settlement of Pecineaga will be affected in terms of cumulative impacts arising from the visibility of two wind farms in addition to Chirnogeni Wind Farm. This area, indicated red in Annex 29 - Zone of visual influence map: Chirnogeni, Deleni and Pecineaga A combined visibility comprises open relatively flat farmland with little vegetation. The Chirnogeni Wind Farm will be visible from many areas within this open farmed landscape along with Deleni and Pecineaga A. The affected landscape is located over 10 km away from Chirnogeni Wind Farm and represents a small portion of the overall large flat plateau or plains landscape type within the 30 km radius study area. Within this confined area, however the proposed Pecineaga A Wind Farm if built, will be visible at short range and will be a prominent new feature comprising 31 wind turbines which will be visually prominent in this area. The proposed Chirnogeni Wind Farm will be located at least 15 km from this affected landscape and will be a small feature affecting the setting of this area. The proposed Deleni Wind Farm if built, will be seen from this landscape as a small to medium sized feature in the distance as it is located at least 20 km away from this landscape. The wind turbines will therefore be seen as small elements in the far distance. Despite the scale of the Deleni Wind Farm, comprising 123 wind turbines, it will be seen as a small to medium sized development located 20 km from the viewer in the farmland in the vicinity of the Pecineaga settlement.

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In regard to the large flat plateau or plains landscape type, throughout the 30 km radius study area, approximately half of this landscape will be affected by the cumulative impacts arising from the visibility of Chirnogeni Wind Farm along with Deleni Wind Farm. Given the scale of the Deleni scheme, comprising 123 wind turbines compared with the 32 wind turbines proposed for Chirnogeni, the Chirnogeni Wind Farm is seen to contribute a small amount to the overall developed skyline.

Taking all of the above into account, the Chirnogeni Wind Farm will cause a small to medium magnitude of cumulative change to this landscape of low sensitivity resulting in a minor cumulative impact on landscape character. This minor cumulative impact reflects the smaller scale of the Chirnogeni Wind Farm compared with Deleni and indeed the fact that it is located far (approx 10 km) from the other wind farms Deleni and Pecineaga A. Also this minor cumulative impact reflects how visually exposed the receiving landscape is and the widespread locations from which Chirnogeni will be visible albeit often as a small development in the distance.

Residual Cumulative Impacts on the Steppe vegetation and woodland landscape character type.

This woodland character type is eroded in many places, replaced with farming landuses. In the location where this remains, in the vicinity of Negru Voda, cumulative impacts will theoretically arise according to the combined cumulative ZVI (Annex 29 - Zone of visual influence map: Chirnogeni, Deleni and Pecineaga A combined visibility). However, these will be very limited and in reality, none of the wind farms will be visible owing to the visual screening provided by the vegetation present.

Taking the above into account, a not significant magnitude of cumulative change is predicted to arise in this landscape of low sensitivity resulting in a not significant cumulative impact on the character of this landscape.

Residual Cumulative Impacts on the Valleys with Lakes landscape character type.

The valley landscapes within the 30 km study area are located in the vicinity of Dumbraveni and Negresti. Also a valley landscape associated with a river catchment to the Black Sea is located east of the Albesti settlement.

Owing to the low lying topography, limited parts of these valley landscapes will be subject to cumulative impacts. In the areas affected, the impacts will arise from the visibility of Chirnogeni along with Deleni.

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The valley landscapes are located at least 10 km from the Chirnogeni Wind Farm and given its size, 32 wind turbines compared with the 123 wind turbines associated with Deleni, a small magnitude of cumulative change is predicted to arise in this landscape of low sensitivity resulting in a not significant cumulative impact on landscape character.

12.1.3 Residual Cumulative Effects on Views and Visual Amenity

Two types of cumulative visual impact are considered in the assessment: combined and successive(85). These terms are defined below:

• Combined visual impacts occur where a static observer is able to see two or more developments from one viewpoint within the observer’s arc of vision at the same time; and • Successive visual impacts occur where two or more wind farms may be seen from a static viewpoint but the observer has to turn to see them.

(85) Guidance taken from Cumulative Effect of Wind Farms, Scottish Natural Heritage, issued 13/04/05.

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Box 12.1 Illustration of Combined and Successive Cumulative View

To assess if the views are combined or in succession a viewing arc model is created.

If the viewer is standing stationary, with Chirnogeni as the focus of the view, any wind farm within 90 degrees either side of the centre of the view is considered to cause a combined cumulative impact. Anything behind this 180 degree arc is considered to cause a successive cumulative impact, as the viewer has to turn around to see it (ie it is behind the viewer).

Source: SNH

12.1.4 Assessment of Residual Combined and Successive Visual Impacts

The assessment of combined and successive impacts was assisted by the preparation of cumulative photowirelines, which are wire lines of the turbines superimposed onto photographs, for three selected viewpoints:

• Viewpoint V09, West of Chirnogeni Commune (2.7 km to nearest Chirnogeni wind turbine); • Viewpoint V20, Cobadin Commune (18 km to nearest Chirnogeni wind turbine); and

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• Viewpoint V24, Negru Voda (6.05 km to nearest Chirnogeni wind turbine). These viewpoints were selected as representative of cumulative views likely to be experienced by significant numbers of people from sensitive locations, at different distances and directions from Chirnogeni Wind Farm and taking into account the visibility of the Chirnogeni site and the number of wind farms theoretically visible.

These cumulative viewpoints are presented in Annex 30 - Cumulative photowirelines. Each comprises a set of up to four views covering the compass quadrants in which Chirnogeni together with any of the other wind farms listed in the table above is theoretically visible. Wind farms over 30 km away are not shown on the cumulative photowires. The proposed Chirnogeni Wind Farm has been illustrated in red and the other wind farms are indicated in blue.

The following section includes the assessment of impacts on each of the selected viewpoints for cumulative assessment. The Cumulative Zone of Visual Influence maps illustrated in Annexes 27, 28 and 29 reveal that cumulative visual impacts will arise for the Chirnogeni Wind Farm as a result of its visibility along with Deleni Wind Farm in the landscape at each of the three viewpoints referenced above. Pecineaga A Wind Farm is not visible from any of these viewpoints.

In the case of each of the viewpoints, the viewer will see both Chirnogeni and Deleni in the combined view. This means that the viewer, when stationary at this viewpoint, can view both wind farms simultaneously without having to turn around (refer to Box 12.1).

Viewpoint V09 – West of Chirnogeni Commune

At viewpoint V09, the viewer will clearly see the proposed Chirnogeni Wind Farm located 2.7 km away. The proposed Deleni Wind Farm will be scarcely visible as it is almost fully screened from view by buildings and dwellings and is located 9.7 km to the north west of the viewer. In the foreground, large pylons and powerlines detract attention away from the horizon and distant views. A very small part of the tips of the proposed wind turbines will be visible above the line of existing structures. However, these will be very difficult to see.

From this particular viewpoint, Chirnogeni Wind Farm will be the only visible and indeed noticeable wind farm which will be seen whilst the other two

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wind farms will be fully screened from view (Pecineage A) or barely perceptible at all (Deleni).

Given this result, the cumulative visual impact of Chirnogeni with the other two proposed wind farms will not arise.

Viewpoint V20 – Cobadin Commune

At viewpoint V20 viewers located at the edge of the settlement of Cobadin will see the Chirnogeni Wind Farm located 18 km away. The wind turbines will be seen as very small elements spread out over a part of the open flat farmed landscape. Similarly the Deleni Wind Farm will be visible 10.7 km away from the viewer. Both wind farms will be clearly visible as small elements in this flat open exposed landscape. Pecineaga A Wind Farm will be screened from view by nearby dwellings.

Cumulative visual impacts will arise as a result of the visibility of Chirnogeni Wind Farm along with Deleni Wind Farm from this viewpoint location. Chirnogeni Wind Farm is a relatively small scheme, comprising 32 no wind turbines compared with Deleni Wind Farm which has 123 no. wind turbines. The comparative scale of the two schemes is apparent in the cumulative photowireline which illustrates that Chirnogeni Wind Farm occupies a small proportion of the horizon whilst Deleni Wind Farm occupies a considerably wider proportion of the skyline.

Taking all of these factors into account, the Chirnogeni Wind Farm will cause a small magnitude of cumulative change on this viewpoint of high sensitivity resulting in a minor cumulative impact.

Viewpoint V24, Negru Voda

At this location, near the settlememnt of Negru Voda, the Chirnogeni Wind Farm will be clearly visible as a small element spread out across the horizon 6.2 km away. The Deleni Wind Farm will also be visible located at a large distance (25.8 km) from the viewer. At this distance, whilst technically visible, it will be barely perceptible and only in clear weather conditions. The Pecineaga A Wind Farm is screened from view by intervening vegetation and topography.

To conclude, Chirnogeni Wind Farm will be clearly visible whilst the Deleni Wind Farm will be barely visible as it is located so far from the viewer. In this regard, the Chirnogeni Wind Farm, if built will not be seen to be visually

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associated with the Deleni Wind Farm from this viewpoint. Chirnogeni Wind Farm would have to be located nearer to the proposed Deleni Wind Farm in order to be seen to contribute to wind farm development in the landscape as seen from this viewpoint. For these reasons, cumulative visual impacts will not arise at this viewpoint.

12.2 ASSESSMENT OF CUMULATIVE IMPACTS ON FLORA AND FAUNA

12.2.1 Introduction

EC Directive (85/337/EEC) (as amended) “The EIA Directive” requires that in addition to undertaking an Environmental Impact Assessment of the project in isolation, cumulative impacts that may arise directly or indirectly from interaction with other projects must also be considered(86). Reference to cumulative assessment is also made within the Habitats Directive (92/43/EEC) although this tends to be more strictly associated with appropriate assessment procedures.

For the purpose of this assessment, projects within a radius of 20 km of the Chirnogeni Wind Farm have been considered, as well as larger scale spatial and temporal references (e.g. migratory flyways), where appropriate.

It should be noted from the outset that the assessment of cumulative impacts is hampered by the lack of information available on other projects, although such difficulties are common throughout the EU, and are not specific to Romania(87).

(86) EC DG XI Environment, Nuclear Safety & Civil Protection. Guidelines for the Assessment of Indirect and Cumulative Impacts as well as Impact Interactions. May 1999

(87) Cooper, L. M & Sheate, W.R. 2002. Cumulative effects assessment: A review of UK environmental impact statements. Environmental Impact Assessment Review Volume 22, Issue 4, August 2002, Pages 415-439

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12.2.2 Description of Projects considered for the scope of the cumulative assessment

The Chirnogeni Wind Farm will consist of 32 turbines covering an area of 16.9 km2 of which the operational footprint (i.e. the land required for the turbines and infrastructure) will be 0.124 km2 (i.e. approximately 0.73% of the total wind farm area).

Dobrogea has some of the highest wind potential in Europe and consequently there has been a significant interest in wind generating capacity. Within 20 km of the Chirnogeni Wind Farm, there are four proposed wind farms and these are listed in Table 12.2.

Table 12.2 Wind farms within 20 km of the Chirnogeni Wind Farm

No. Location Name of the developer No of Current status in turbines/ the Romanian total legal EIA power procedure (MW)/ distance to the target site

1 Movila Verde S.C. GAMESA 17 turbines ENERGY ROMANIA 34 MW S.R.L. Approx. 9 km

2 Amzacea A S.C. SORGENIA 12 turbines ROMANIA S.R.L. 30 MW

Approx. 17 km Prior scoping 3 Amzacea B S.C. SORGENIA 16 turbines phase ROMANIA S.R.L. 40 MW

Approx. 17 km

4 Olteni S.C. ELNIVA S.R.L. 5 turbines

10 MW

Approx.15 km

Within the 20 km cumulative impact search radius, the four additional wind farms will add a total of 50 additional turbines. This will mean that within the

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64 km2 of the cumulative impact search area there will be a combined total of 82 turbines. It has not been possible to ascertain the land take of the other projects but assuming a similar land requirement for turbines and associated infrastructure at the other projects to that required at Chirnogeni Wind farm (i.e. 12.4 ha or 0.38 ha per turbine). This would give a total land take of 31.16 ha (0.3116 km2), less than 0.5% of the 64 km2 search area within a 20 km radius of Chirnogeni Wind farm.

Turbines are likely to be between 2 to 3 MW output and therefore of similar design and height to that at Chirnogeni Wind farm, with a tower height of approximately 100 metres and turbine blades of 43 metres giving an approximate tip height of 143 metres.

The ecological effects of the Chirnogeni Wind farm have been dealt with in this ESIA (see section 8) and in summary no significant impacts on flora or fauna have been predicted for the following reasons:

• The largely disturbed and agricultural nature of the site indicates low botanical diversity. • For the same reasons, the terrestrial fauna is unremarkable and with the exception of populations of Annex IV reptiles (Podarcis tauricus and Lacerta viridis) - Habitats Directive, associated with field margins and irrigation channels, no significant ecological constraints were identified. • Bird studies, although limited in scope, methodology and timing, indicate limited spring migration and a breeding bird community that comprises mainly common and widespread species. The exception to these are the presence of five Annex I bird species (Coracias garrulous, Anthus campestris, Lanius minor, Circus aeruginosus and Falco vespertinus). The ESIA has concluded that significant impacts on these latter species are unlikely given the large area available within and adjacent to the wind farm, although there is potential for Falco vespertinus in particular to lose one pair through collision. This would equate to 0.07% of the Romanian breeding population. • Migrant species are believed to use routes that avoid the proposed wind farm area. However, the bird survey did not cover the migration period and further survey work is required (see section 8.3.7). • The limited amount of bat survey effort indicated that seven species of bat were recorded feeding over the open fields. Overall the open nature of the habitat, absence of roost sites within the wind farm boundary, and the low number of bat contacts led to the judgement that the area was of low conservation value for bats. It is acknowledged however that no

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assessment of potential migration has been undertaken and that further survey work is required at the appropriate season. • Impacts on protected sites and their qualifying features was considered unlikely due to the distance from them (the nearest is Dumbrăveni-Urluia Valley-Lake Vederoasa SCI 5 km to the north) and absence of connectivity with such sites. Given these conclusions, cumulative impacts on flora or entomological features are not anticipated to be significant. Similarly, impacts on breeding birds are limited and spatially discrete. Bats and migratory birds, by virtue of their potential to encounter a number of wind farms are the species where cumulative or in-combination impacts related to other projects may arise or where uncertainty about such impacts may exist. Given that some of these species are also features of protected areas, impacts on protected areas also require consideration.

Impacts arising from Chirnogeni Wind farm on Annex IV reptiles are regarded as low (although any mitigation will require to take into account the strict protection of both the species and their breeding and resting places). Cumulatively, the land take from the other proposed wind farms may have a potential effect if populations within the 20 km radius are particularly important, although such an effect at the favourable conservation status of the species level is unlikely as within Romania these reptiles are regarded as relatively common and widespread.

12.2.3 Cumulative Impacts on Bats

There is no information obviously available on the other sites impacts on bats. Olteni and Movila Verde wind farms are both situated within one kilometre of Dumbrăveni-Valea Urluia-Lacul Vederoasa, whilst Olteni is also within three kilometres of Dumbrăveni SPA. Both these protected sites contain extensive woodland habitats likely to support bats, with Dumbrăveni-Valea Urluia- Lacul Vederoasa having two bats listed as qualifying features.

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Mere presence is insufficient grounds to predict impacts however foraging and migratory behaviour have been used as indicators of sensitivity to wind farms(88). Species that hunt over open ground by aerial hawking such as the Nyctalus, Eptesicus and some of the Pipistrellus species have been shown to be particularly vulnerable, although many of the broad winged gleaning species such as the Myotis and Rhinolophidae appear to be much less at risk. Species that undertake migrations are also known to be seasonally more vulnerable, and this can include species whose normal flight behaviour is low risk such as Miniopterus schreibersii (one of the qualifying features of the Dumbrăveni- Valea Urluia-Lacul Vederoasa SCI).

Currently few impacts are predicted from Chirnogeni Wind farm on bats, primarily because of the poor quality of habitat and correspondingly low number of bats present. Further work on migration is required however, as this is currently poorly understood. It is possible that Olteni and Movila Verde may have greater impacts on bat populations as, unlike Chirnogeni, they are near wooded high quality bat habitat. Even at these wind farms appliying the minimum 200m offset from woodland edge recommended by Eurobats (Rodrigues et al 2008) is likely to reduce the impact of turbines on bats.

In order for cumulative impacts to be established, it would be necessary to have data on migration of bats through this region in general, and through the proposed wind farms in particular. On balance it is unlikely that Chirnogeni Wind farm will contribute significantly to bat mortality given the low levels of activity recorded during the survey conducted in June 2009. Even if there were a measurable impact on bats, the Chirnogeni wind farm would likely have a less significant effect than other wind farms that are closer to habitats that are more suitable for bat use.

However in the absence of data from the migration period it is not possible to accurately predict if seasonal impacts might arise in combination with other wind farms.

(88) Rodrigues, L., L. Bach, M.-J. Dubourg-Savage, J. Goodwin & C. Harbusch (2008): Guidelines for consideration of bats in wind farm projects. EUROBATS Publication Series No. 3 (English version). UNEP/EUROBATS Secretariat, Bonn, Germany, 51 pp

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12.2.4 Cumulative Impacts on Migratory Birds

In general both this ESIA and others for Romanian wind farms have tended to rely on desktop studies to assess migration impacts. The failure to carry out more detailed surveys of the kind routinely required in other EU countries (e.g. vantage point counts) has attracted growing critiscm(89). It also appears to ignore published information that refers to autumn raptor migration through the Dobrogian plain(90), or the presence of various migratory raptors and other migratory species within SPAs in the area, again many of these forming part of the qualifying features of such sites as Dumbrăveni.

It is difficult to undertake a cumulative impact assessment of migratory birds in the absence of such data, although even where such surveys may have been carried such information does not appear to be readily available.

Despite this, there are general factors regarding these sites that do suggest that impacts will be limited, not least the fairly uniform terrain and the absence of significant features such as rift valleys and rocky outcrops. The total number and dispersed nature of the various wind farms means the total swept area is small in comparison to the airspace available, and their distribution is such that large gaps of several kilometres exist between them reducing any barrier effect.

Despite the attention given to wind farm related bird kills, the majority of installed wind farm capacity kills relatively few birds (the National Wind Coordinating Committee estimate that wind farms are responsible for 0.01- 0.02% of all avian fatalities in the USA) compared to many other anthropogenic activities and structures. There is growing evidence that birds demonstrate high levels of avoidance of turbines(91) (although where avoidance becomes displacement this can be as important an impact as

(89) Birdlife International, Romanian Ornithological Society, & Eco Pontica Foundation. Dobrogea’s Natura 2000 sites (including Danube Delta), Romania: Inadequate implementation of the EU Nature Directives is resulting in site deterioration and species disturbance November 5th 2009

(90) Roberts, J. 2000. Romania: A bird watching and wildlife guide Burton Expeditions, Somerset.

(91) Whitfield, D.P. & Madders, M. 2006. Deriving collision avoidance rates for red kites Milvus milvus. Natural Research Information Note 3. Natural Research Ltd, Banchory, UK

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mortality through collision). Migration altitudes for many birds are well in excess of the height of turbines, and for passerines Newton(92) reviewed a number of radar studies and concluded that birds were flying 1.5-3 km above ground level. Extensive studies of raptors in Israel and the Middle East indicate that flight heights can be as much as 2.5 km above ground level, although early in the day, particularly if birds had roosted locally, they could be as low as 400m above ground level(93).

Issues such as autumn feeding on the ground by migratory raptors attracted to ploughing (Roberts 2000) and the presence of migratory raptors in large forest areas such as Dumbrăveni are issues that may increase local sensitivity to turbines, although this latter is less of an issue for Chirnogeni Wind farm, as the SPA is over 12 km distant.

Whilst on balance the conclusion from the cumulative impact assessment is that no significant effect on the favourable conservation status of migrants is anticipated, such a determination will be more robust after vantage point surveys are undertaken in autumn (as already indicated in section 8.3.7) using a recognised methodology (e.g. SNH 2005).

12.2.5 Cumulative Impacts on Protected Areas

Of all the wind farms considered Chirnogeni has the least proximity to protected areas. The key concerns relating to effects on protected areas would therefore require that Chirnogeni contributed to negative effects on the mobile qualifying features of these protected areas (i.e. bats and birds). Whilst each individual wind farm may not kill sufficient birds and/or bats to significantly affect the favourable conservation status of the qualifying features, in combination there is a possibility that they may do so.

(92) Newton, I. 2010. Bird Migration. New Naturalist. Collins.

(93) Shirihai, H., Yosef, R., Alon, D., Kirwan, G.M. & Spaar, R. 2000. Raptor Migration in Israel and the Middle East. Tech. Publ. Int. Birding & Res. Centre in Eilat, Israel.

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For the reasons outlined in sections 12.2.3 and 12.2.4 impacts on bats and birds are not anticipated to be significant at Chirnogeni, although confidence in these predictions would be improved by further survey work.

Whilst it could be reasonably anticipated that wind farms in proximity to protected areas are the most likely to have an impact on the qualifying features of such areas data is lacking. However, as noted above the total number of turbines and the overall land take is relatively small, and no wind farm approaches within 1 km of protected areas. For these reasons impacts on the qualifying features of the protected areas are thought to be unlikely, although the robustness of such predictions is low.

12.2.6 Conclusion

Overall cumulative impacts are anticipated to be most likely where they relate to mobile populations, particularly migrant birds and possibly bats. In general the land use, topography, and limited size of the wind farms concerned, coupled with little evidence of key migratory routes would suggest that cumulative impacts are unlikely to be significant.

Caution regarding the robustness of this determination is required however as no information was available on the impacts of the other wind farms, and most of this had to be inferred from location and number of turbines. In addition, there appears to be little specific information on either bird or bat migration through the Chirnogeni Wind farm site or indeed within the 20 km cumulative impact assessment radius, and this is a further limitation to the assessment process. Such information would be valuable in increasing the robustness of the assessment.

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13 ENVIRONMENTAL AND SOCIAL MITIGATION PLAN (ESMP)

13.1 INTRODUCTION

EPGE is committed to high standards of environmental and social performance for its operations. This Chapter provides an outline of how the Project is to be managed with respect to Environmental, Health and Safety and Social issues. It presents an outline of the Environmental, Health and Safety (EHS) Management System that is being developed for the project and its associated design, construction and operational EHS management procedures.

EHS and social management issues at various stages in the life of the project from detailed design through to operation, will be governed or guided by a number of ‘standards’, including:

• those contained in legislation; • those established by industry codes of practice; • those required by EPGE EHS policy; and • those that are specific to the EPGE Project including commitments made in the ESIA, commitments made during consultations, and measures as may be set out in environmental consents or licences for the project. Relevant environmental legislation is presented in Section 1.3.

13.2 EP GLOBAL ENERGY

EP Global Energy (EPGE) is the ultimate parent company of EP Wind Project (ROM) SIX SRL (EPWP6), part of The Paraskevaides Group. EPGE is a private development company active in the power generation field, with its head office in Cyprus and five regional offices (Cyprus, Greece, Albania, the United Arab Emirates, and Romania: Bucharest and Constanţa). EPGE proposes to carry out several development projects in power production in Romania in the near future.

The company’s team consists of specialists with experience in the development and implementation of projects, starting from the phase of pre- planning and marketing to construction and commissioning and operation. Partnerships at the local level are an important element in the company’s strategy, based on long-term relationships developed by The Paraskevaides Group in the past 60 years.

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EPGE’s mission is to create a fair value for shareholders by developing a portfolio of investment targets both in the production of renewable energy (power produced from wind, solar or hydro sources) and conventional energy (power produced from natural gas).

Electricity generated by the Chirnogeni Wind Farm (80 MW) will contribute to the Romanian Government goals to boost renewable energy and modernize existing electricity lines, strengthening the renewable energy industry in Romania. In order to achieve its objectives, EPGE established a local development office for EP Wind Project (ROM) SIX SRL (EPWP6) based in Constanţa.

Human resource (HR) policy

At this moment, EPGE is operating at minimum level in Romania, having only a small number of employees. The company is currently preparing documentation related to HR policy. For the moment, the corporate HR policy is in use.

The HR policy should establish the framework for recruitment, temporary work, unemployment, local labour, forced labour, child labour. Also, the HR policy should establish the internal organisational chart, the tasks and responsibilities of each manager and operational procedures for each activity, as well as the set up of an internal grivannce mechjanism for employees.

Labour and working conditions for employees

In Romania, EPGE has offices in Constanta and Chirnogeni. EPGE considers that the Chirnogeni office will become the main headquarter, and will support EPGE employees in conducting daily activities and coordinating the implementation of the Chirnogeni Wind Farm 80 MW (during construction and operation).

Grievance mechanism for employees

During the implementation of the Chirnogeni Wind Farm 80 MW, as EPGE will develop its offices in Chirnogeni and Constanta, the company will set up a grievance mechanism for its employees, as part of the HR policy. This will be part of EPGE’s grievance mechanism for external and internal stakeholders.

Subcontractors management

The construction of the Chirnogeni Wind Farm 80 MW will be mainly performed by EPGE subcontractors. Having this in mind, it is essential to prepare a procedure for subcontractor management in order for EPGE to

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make sure that all the requirements (both socio-economic and environmental) will be correctly and effectively implemented.

13.3 PURPOSE OF THE ENVIRONMENTAL AND SOCIAL MITIGATION PLAN (ESMP)

The broad purpose of the ESMP is:

• to provide a mechanism for ensuring that measures to mitigate potentially adverse environmental and social impacts are implemented; • to ensure that standards of good construction practice are adopted throughout the construction of the Project; • to provide a framework for mitigating impacts that may be unforeseen during construction and operation of the Project; • to provide assurance to third parties that their requirements with respect to environmental and social performances will be met; • to provide a framework for compliance auditing and inspection to enable EPGE to be assured that its aims with respect to environmental and social performances are being met; • ensure appropriate stakeholder engagement; • minimize risks of injuries or illness to construction workers and wind farm operators. A key element will be the implementation of this ESMP which incorporates all the mitigation measures identified through this ESIA report.

The ESMP will continue to be developed as the Project proceeds through the detailed design, construction and operational phases, to reflect the results of any discussions with regulators and stakeholders and to include details of any conditions imposed by any other environmental licences obtained for the Project.

13.4 ROLES, RESPONSIBILITIES AND REPORTING

13.4.1 EPGE’s role during construction and operation

As project proponent, EPGE has responsibility for:

• monitoring contractor performance;

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• monitoring the subcontractors activities in order to assure that all environmental and socio-economic legislation and conditions established in the Engineering, Procurement and Construction (EPC) contract will be fully complied with; • handling issues as they arise; and • acting as a point of contact for consultation and feedback with the public and other interested stakeholders.

13.4.2 Contractors’ role during construction and operation

The contractors will be responsible for the following:

• ensuring compliance with all relevant legislation (including waste management), as well as with the environmental and social mitigation measures contained in this ESMP; • training of the construction staff to raise the EHS consciousness and assigning a responsible manager on site in order to contribute to the project’s environmental and social performance; • ensuring the implementation of environmental or other codes of conduct required by EPGE. This ESMP as part of the ESIA Report including the impact assessment and mitigation measures, as well as monitoring activities proposed for the construction phase will be presented to the construction contractors in order to be aware of the environmental and social requirements of the Project.

The contractors’ performance in complying with the ESMP will be monitored and audited by an independent auditor, following an audit program developed as part of the EHS management system.

13.5 TRAINING

EPGE will provide training to all employees involved in day to day construction and operational activities and to all contractor personnel working at the site. Training will aim to ensure that site personnel:

• understand the ESMP and how it will be implemented on site; • understand the environmental sensitivities of the area in which the Project will be constructed and operated; • know how to deal with unauthorised visitors to the site and with enquiries by the public;

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• know how to deal with unforeseen EHS incidents; and • are aware of the roles of the contractors staff, the EPGE Project Manager and the EPGE Project EHS Officer with respect to environmental and social issues. EPGE will keep records of the training given to individual staff. Assessment of the effectiveness of the training programme is included as part of the audit procedures for the ESMP by EPGE. It consists of randoms interviews of site staff throughout the duration of the contract.

The contractor is required to ensure that the personnel of subcontractors go through the training program and consider this in the agreements with the subcontractors.

13.6 INSPECTION AND AUDITING

As mentioned above, a program of inspections and audits by EPGE will be implemented during construction and will continue with operation of the Project. These are aimed to assure EPGE that contractors are complying with the ESMP and consequently with relevant national and international EHS regulations during the lifetime of the Project.

The inspections and audits will focus on the quantified and unquantified information contained in this ESIA Report, in order to ensure that the construction and operation of the Project meets acceptable EHS and social standards. These will be based on the available information (requirements stipulated in relevant permits, technical studies prepared in the pre- construction phase) and observations and do not include additional sampling or data collection.

Where problems are identified by either EPGE or contractors, corrective actions will be identified by the EPGE Project EHS Officer and must be undertaken by the contractors or EPGE as appropriate. These could take the form of, for example, further direct mitigation, changes to procedures or additional training.

13.7 CONTINGENCY PLANNING FOR EMERGENCIES AND ENVIRONMENTAL INCIDENTS

Although a serious incident is very unlikely to occur during the construction and operation of the Project, it is necessary to have procedures in place to deal with emergencies and incidents. Environmental incidents are considered to be

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unexpected events which lead to, or could lead to, adverse effects on people, property or environmental resources such as habitats or watercourses.

EPGE will be developing an Emergency Preparedness and Response Plan which sets out the measures to be taken to minimise the risk of an incident and the measures required to prepare for and respond in the unlikely event that an incident does occur during construction (such as a fuel spillage from vehicles) or operation (such as oil leaks from the gearbox or fire of the electrical components). The procedures will include provisions for incident reporting. EPGE will make provisions for keeping anti-pollution control/clean up materials on site in case of an incident.

13.8 ONGOING STAKEHOLDER ENGAGEMENT

Stakeholder engagement refers to a process of sharing information and knowledge, seeking to understand the concerns of others and building relationships based on collaboration. Public consultation and disclosure (PCD) are essential for effective ESIA and Project delivery.

Consultation is an inclusive and culturally appropriate process that provides stakeholders with opportunities to express their views. These are then considered, responded to and incorporated in decision making processes at each stage of project development. Effective consultation requires the prior disclosure of relevant and adequate project information to enable stakeholders to understand the risks, impacts and opportunities of the project.

For the purposes of this Project, a Stakeholder Engagement Plan (SEP) has been prepared as a standalone document. Within this document, a stakeholder engagement strategy has been developed and divided into four phases, each having slightly different objectives.

• Phase 1: Screening and scoping – The screening and scoping phases aim to identify the stakeholders, introduce the Project and generate feedback on the scope, approach and key issues. Consultation during this phase has been conducted with government bodies, representatives of the local administrations, NGOs and members of the public. • Phase 2: Preparation of the ESIA report – This phase aims to provide information on the Project, whilst also obtaining baseline information about the Project area from local communities, local economic operators and NGOs, as appropriate. • Phase 3: ESIA disclosure – This phase consists in the finalization of the ESIA report and aims to study the impacts and mitigation measures

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envisaged as part of the Project. Studies will look to identify any local benefits that can be delivered through the Project and ensure that measures to be implemented are appropriate to the local situation. All stakeholder groups will be consulted during this phase. In this phase the ESIA findings will be subject to public disclosure as part of the Project financing process. • Phase 4: Ongoing Engagement – This phase will be taken forward by the project partners during construction, operation and final decommissioning of the Project. Stakeholders’ participation will be fundamental to the success of the Project implementation and stakeholder feedback will be a key component in monitoring the success of the mitigation measures.

13.9 GRIEVANCE PROCEDURE

EPGE will implement a grievance procedure in accordance with EBRD requirements which will enable any complaints to be made direct to a nominated Romanian speaking member of staff. Details of the telephone number and complaints procedure will be distributed to residential properties in the vicinity of the works. The telephone will normally be answered in person and details taken of the complaint, source, its location and date/time of offending use. To ensure that those without access to a phone are able to make use of this procedure, appropriate means of access will be arranged. Copies of the contact form in Romanian language will be made available at the municipalities in the Project area (at the Mayor’s offices) and on EPGE website. For this same purpose, EPGE has already set up a post box where these forms can be sent (Address: Post Box 103, Post Office 1, Constanta City, Constanta County, Romania).

All complaints will be investigated by the EPGE Project Manager and appropriate action taken as necessary. Records of all complaints and corrective actions will be maintained on site. All complaints will be reported, on receipt, to the EPGE Project Manager.

13.10 ENVIRONMENTAL AND SOCIAL MITIGATION PLAN

This section presents the ESMP for the Project, setting out all the environmental, health and safety and social commitments with which EPGE will comply during construction and operation of the Project established through the ESIA. These are organised under seven topics as detailed in the Table 13.1:

• General EHS and social aspects;

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• Traffic and Transport; • Soils, Geology, Land Use and Water Resources; • Noise and Vibration; • Air Quality; • Ecology and Nature Conservation; • Landscape and Visual; and • Socioeconomics.

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Table 13.1 Environmental and Social Mitigation Plan

ESIA Topic Mitigation Measure Design/Construction /Operation/ Monitoring Decommissioning General EHS and Develop and enforce a clear and effective EHS and social Prior to construction Regular auditing social aspects management procedure Develop and enforce a clear and effective organizational Prior to construction Regular auditing chart, including allocation of tasks and job description for each employee Develop and enforce a human resource policy at the level Prior to construction Regular auditing of the Romanian entity and assure that it is implemented correctly by contractors and subcontractors Create a monitoring procedure for EHS and social impacts Prior to construction Regular auditing during of the Project construction and operation Traffic and Transport A Construction Traffic Management Plan will be developed Prior to construction Regular auditing during in order to provide a framework for the management of construction construction traffic impacts of the development. Obtain necessary permits. Routes for abnormal loads will be arranged and agreed Prior to construction Regular auditing during with the authorities, local police and emergency services. construction Where oversized vehicles require a police escort, local police dictate the timing of delivery. All abnormal loads will be suitably marked to warn other road users. The developer will ensure a permanent consultation with Construction Regular auditing during landowners and users and access will be maintained at all construction times where required.

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ESIA Topic Mitigation Measure Design/Construction /Operation/ Monitoring Decommissioning The developer/principal contractor will hold regular Construction Not required consultations with the local authorities regarding the management of construction. The developer/principal contractor will provide minibuses Construction Regular auditing during to transport workers from the construction base. construction In order to identify whether any damage has occurred the Prior to and after construction Not required developer proposes a joint site inspection with the Administration for Roads and Bridges prior to and after the project’s transport activities to survey the existing road conditions on the selected route. The procedures and actions to be taken in case of damage to the local road infrastructure by construction traffic will also be detailed in the transport management plan. Soils, Geology, Land Best practice soil handling techniques will be implemented Construction Regular auditing during Use and Water including the following measures: construction Resources • Topsoil stripping will be limited to the footprint of the turbine locations, the access roads and underground transmission line. • Topsoil and soil will be stored separately in a designated area of the construction compound, in such a way that it is not mixed with subsoil or trafficked on by vehicles. • Following reinstatement, any surplus (uncontaminated) soil will be spread over fields subject to agreement with the landowner/occupier and/or used for landscaping within the project area.

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ESIA Topic Mitigation Measure Design/Construction /Operation/ Monitoring Decommissioning • Stockpiles will be a maximum of 2 m high to avoid compaction from the weight. • The construction working area will be reinstated as far as practicable to the same condition as before. • After the installation of the cable for the underground transmission line, the stored soil and topsoil will be used as backfill for the trenches and the area will be restored to its initial condition. In order to minimise potential impacts (such as: Construction Regular auditing during contamination of soil during construction through direct construction spillage of materials), refuelling of vehicles or equipment will be restricted to the construction camp which will be located on impermeable hardstanding. The contractor will also develop procedures for Construction Regular auditing during emergency/ spill response, and for the storage and construction handling of hazardous fuels, construction materials and wastes. Cut off ditches will be used to prevent water from entering Construction Regular auditing during excavations. construction The condition of any field drains on or in close proximity to Prior to construction Not required the site will be surveyed prior to construction to enable an assessment to be made of any damage created during construction and for reinstatement (such as adding or replacement of field drains) to be targeted appropriately. Excavation activities will be restricted during periods of Construction Regular auditing during intense rainfall, and temporary bunding will be provided construction

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ESIA Topic Mitigation Measure Design/Construction /Operation/ Monitoring Decommissioning to reduce the risk of sediment, oil spills to the natural field drainage system. Clean-up plans will be implemented in order to minimise Construction Regular auditing during risks linked to the use of materials such as paints or oil. construction Full reinstatement will take place of land drainage features After construction Regular auditing during disturbed during construction. construction and after A water pipeline survey needs to be conducted within the Prior to construction Not required project area in order to avoid unexpected events. In case this survey identifies any pipelines the Areal Centre Mangalia shall be urgently notifed and the costs related to the diversion of the pipes shall be incurred by the developer. Moreover, in such a case further specific conditions to protect the pipelines shall be discussed on the spot. Noise and Vibration Construction will be sufficiently distant from dwellings to Construction Regular auditing during avoid noise impacts on residents. construction Working hours will be restricted to 0700 to 1900 Monday to Construction Regular auditing during Friday and to 0700 to 1300 on Saturdays. construction Best practice housekeeping measures will be implemented Construction and operation Regular auditing during (for example regular maintenance of equipment) also for construction and soil protection. operation during maintenance activities Air Quality Water suppression or dust extraction equipment will be Construction Regular auditing during fitted to drilling and grinding equipment where necessary. construction Measures will be taken to prevent the deposit of mud and Construction Regular auditing during dirt on public roads. construction

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ESIA Topic Mitigation Measure Design/Construction /Operation/ Monitoring Decommissioning Containers for dusty materials will be enclosed or covered Construction Regular auditing during by suitable tarpaulins to prevent escape of dust during construction loading and transfer from site. Lorries carrying dusty materials to or from the site will be Construction Regular auditing during sheeted. construction Speed limits will be set to minimise disturbance to exposed Construction Regular auditing during running tracks. construction All quality protection measures will be contained within Construction Not required the Construction Method Statement. Most of these measures will also be included in the Traffic Management Plan. Ecology and Nature During construction works, construction dust will be Construction Regular auditing during Conservation mitigated as far as reasonable practical therefore mitigating construction any potential impacts to flora. A construction Environmental and Social Management Construction Regular auditing during Plan will be developed and implemented, containing construction practices for activities such as refuelling of vehicles and machinery. If clearance activities are planned for the winter months an Construction 15 days monitoring experienced ecologist will check the site prior to any works during construction for hibernation sites. If a site to be disturbed supports hibernation by one of the protected specie, the site cannot be disturbed until after this season. Prior starting the construction of the wind farm, checks for Prior construction 15 days monitoring prior Habitat Directive Annex IV species will be undertaken by construction an experienced ecologist at all laydown sites, compounds,

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ESIA Topic Mitigation Measure Design/Construction /Operation/ Monitoring Decommissioning tower bases and particularly along the 110 kV underground transmission line extending to 25 m either side of the cable trench. If Annex IV species will be found and appropriate working method to minimize harm by creation of suitable habitat outside of the working width of the underground transmission line will be undertaken. These actions will be conducted following the consultation of the relevant authorities. If for imperative reason construction works has to take Construction Regular auditing during place during the breading season, survey will be construction undertaken to identify and mark bird’s nests and no work will be allowed in the vicinity of such sites until the young have fledged. Additionaly, in order that construction does not cause adverse impacts to ground nesting birds, clearance activities will be undertaken outside of the bird breeding season (May – June).. Birds and bats will be monitored during migration and Operation Regular auditing during breading /young-raising seasons during construction and operation and annual for at least two years of operation, in order to verify reporting to EBRD potential significance of impacts and to determine the need for operating parameters to reduce impacts. Additionaly, regular searching will be undertaken for both bird and bat corpses using internationally described protocols to monitor mortality. Landscape and The installation of permanent tracks will take the shortest route to Design and construction Not required Visual the turbine where practical.

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ESIA Topic Mitigation Measure Design/Construction /Operation/ Monitoring Decommissioning Signs will be provided for health and safety purposes and Design and construction Not required will be located on the turbine doors. Advertising and brand names will not be permitted on the Construction Not required turbines. The project construction will limit land clearance and Design and construction Regular auditing during occupation to the minimum necessary for the works. construction The topsoil will be spread and turf will be replaced, or Construction Regular auditing during reseeding and planting will be conducted as soon as construction possible after sections of work are complete. Movement of vehicles will be confined to construction Construction and Regular auditing during routes, thus avoiding soil compaction from vehicles decommissioning construction and tracking over farmland areas, and consequent impacts on decommissioning vegetation. A similar approach will be adopted to mitigate significant impacts during decommissioning. The construction site lighting will be restricted outside Construction Regular auditing during normal working hours to the minimum required for public construction safety and security. There will be no external lighting, except for the special Operation Regular auditing during requirements from Romanian Civil Aeronautic Authority operation described in the Section 9.1.18. The turbines and all other aboveground structures will be Decommissioning Regular audits during removed at the end of the operational lifetime of the wind decommissioning farm. Socio-economics The site will be kept clean and tidy to prevent weeds from Construction and operation Regular auditing during growing and spreading over neighbouring arable land. construction and operation

Access of construction workers to land not directly affected Construction Regular auditing during

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ESIA Topic Mitigation Measure Design/Construction /Operation/ Monitoring Decommissioning by the project will be restricted so as not to disturb arable construction land. The area impacted during construction will be limited and Construction Regular auditing during wherever possible access to agricultural land will not be construction restricted. Where possible, construction will avoid the crops growing Construction Regular auditing during season. However, should crops be damage during this construction period, compensation will be provided and land will be reinstated according to the provivisions of the Compensation Action Plan. 30% of the construction workforce for the project Construction Not required comprising unskilled and to some extent semi-skilled labour will be employed locally (from Independenta and Chirnogeni Communes or Constanţa County). Also EPGE will provide training to enable local community members to take advantage of the employment. Construction personnel will be trained by the construction Construction Regular auditing during contractor with regard to environmental, health and safety construction risks associated with the construction of wind farms and necessary measures to avoid incidents and increased the project’s environmental performance. Concrete and aggregate materials for the construction Construction Regular auditing during phase will be sourced from a local supplier in Constanţa construction County. The accommodation containers will provide housing Construction Regular auditing during conditions compliant with all applicable Romanian health construction

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ESIA Topic Mitigation Measure Design/Construction /Operation/ Monitoring Decommissioning and safety regulations and norms as identified in the technical construction documents, as well as international best practices. A Traffic Management Plan will be developed to set out Construction Regular auditing during general measures to mitigate traffic-related environmental construction impacts associated to construction and include information on more detailed site specific measures as required. Additionaly this plan will establish routes that avoid sensitive areas (pedestrian areas, schools, clinics, etc.), air quality protection measure and also will require driver training. Transportation of over-size loads will comply with all Construction Regular auditing during applicable regulations and conditions stipulated in the construction relevant permit and will be accompanied by appropriate safety vehicles. Construction works will include supervision by an Construction Regular auditing during archaeological expert to avoid or reduce any potential construction impacts to the tumulus. All land used temporarily during construction will be fully Construction Regular auditing during rehabilitated and returned to its use prior to start of construction operation. Development of clear land acquisition procedure for cases Prior to construction Regular auditing when more land will be bought. This procedure will be based on open negotiation and market value. Maintenance and operation staff will be employed locally Operation Not required to the extent possible (from Chirnogeni and Independenta Communes or Constanta County) and trained accordingly

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ESIA Topic Mitigation Measure Design/Construction /Operation/ Monitoring Decommissioning to enable employees to take advantage of the employment. All health and safety applicable regulations will be During construction and operation Regular auditing during enforced. construction and operation Establish and enforce code of conduct for non-local Prior to construction Regular auditing workers to reduce adverse impacts on local community. Prepare a cultural heritage chance finds procedure During construction Regular auditing and assure training for all contracts and subcontracts (through entire contracting supply chain). Stakeholder engagement and consultations/communication of the stages of the Project will be ensured with the local communities as described in the SEP.

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13.11 OUTSTANDING ACTIONS

The following outstanding actions are still needed to verify the conclusions of the impact assessment and requirements for any additional mitigation:

• birds survey to be conducted during the autumn migration period to supplement the spring migration survey already completed.

14 REQUIREMENTS STIPULATED BY OTHER REGULATORY ACTS

According to the Romanian Construction Law, construction permits may only be obtained for land within areas rezoned, if necessary, and considered ‘buildable’, within the relevant administrative units and according to the approved function ‘as stipulated in the Urban Certificates (UC) for Zoning/Construction’.

For this reason, the first stage in any project is to obtain an UC to rezone the land, which is issued by the local or county public authority according to jurisdiction (who are considered the competent authority for this procedure).

This document informs the applicant of the permitted uses of the land from a legal, commercial and technical view. This document is for information only, and does not permit the right to construct. It provides a checklist of authorisations and approvals required in order to rezone the affected land. After this stage, a new UC (for construction) is required as part of the application to obtain a construction permit for the project.

Depending on the project type, proposed activity, location, dimensions and local regulations and restrictions, excepting the environmental agreement, other approvals and agreements may be required in the UCs: approvals of utility providers who must confirm whether the proposed capacities can be met, Fire protection approval, Civil protection approval, Sanitary approval, Other approvals and agreements (e.g.: Ministry of Transport Approval, Ministry of Culture Approval, Ministry of Internal Affairs, Romanian Intelligence Service, Civil Aeronautics Authority, State Inspectorate in Constructions, Ministry of Administration and Interior, Ministry of Telecommunication, National Road Authority, Romanian Railways, Biodiversity approvals, etc.).

These approvals can be requested at the competent authorities in parallel and can be obtained during the EIA Procedure (EIA Procedure for obtaining the environmental agreement for construction is the longer one). They may include specific requirements which the developer must consider and comply with for the implementation of the Project.

Having obtained all the approvals required by the UC for construction, the developer can apply for the construction permit which is mandatory for the beginning of construction or demolition of an industrial unit, building or other permanent structures.

The responsible authorities for the issue of the Construction Permit are the authorities who have issued the Urban Certificates, respectively: the mayor of the municipalities, towns or communes or in some specific cases the President of the County Council (e.g: if the future plant should be located on the territory of more than one administrative area).

The approval of the County Council is also necessary for Issue of a Construction Permit for plants which will be built in the communes’ area (rural area).

At the time this ESIA was revised, two Urban Certificates had been obtained for the Project according to the legal procedures mentioned above:

• Urban Certificate for rezoning no. 173 dated 29 April 2009; • Urban Certificate for construction no. 74 dated 23 May 2011. The following acts were required by the Urban Certificate for rezoning. Their specific requirements for the approval of the Zoning Urban Plan are presented in the following chapters. At the time of writing this ESIA, the acts required by the Urban Certificate for Construction had not been obtained by the developer. The following authorities should be approached for this purpose:

• ENEL Distributie Dobrogea; • Romanian National Land Improvement Administration (NLIA), Local Branch Dobrogea, Constanta Sud Administration Unit; • Romanian Ministry of National Defence; • Romanian National Gas Transport Company; • Constanta Directorate for Culture, Religious Affairs and National Cultural Heritage of Constanta County; • Romanian Civil Aeronautic Authority; • Constanta Cadastre and Real Estate Publicity Office.

14.1 SITE APPROVALS BY ENEL

According to the requirements of the Site Approval no. 9010171 dated 4 June 2009 issued by ENEL Distributie Dobrogea, all digging works in the area of the underground cable routes shall be performed manually, with technical assistance from ENEL Distributie Medgidia and in compliance with applicable health and safety regulations. The constructor shall be liable for any damages to the existing electrical installations, for the consequences resulting from the

lack of energy supply to the local consumers and for electrical or any other types of accidents.

The safety areas of underground electrical cables shall be kept clear of construction materials, excavated soil or other equipment. Construction machinery shall observe the minimum distances to the elements of electrical networks under voltage.

This Site Approval was valid until 29 April 2010 and shall not be construed as a Technical Connection Agreement.

ENEL Distributie issued a similar Site Approval no. 496 dated 11 June 2009, which was valid until 29 July 2009. This Site Approval does not include any specific requirements for the Project due to the fact that ENEL Distributie Eforie does not own any electrical distribution networks on the Project site.

14.2 APPROVAL OF THE ZONING URBAN PLAN BY THE ROMANIAN NATIONAL LAND IMPROVEMENT ADMINISTRATION

According to the Approval no. 2931 dated 8 July 2009, the Romanian National Land Improvement Administration (NLIA), Local Branch Dobrogea, Constanta Sud Administration Unit informs:

• the project site is part of the irrigation capacity of the Local System Rasova – Vederoasa, Plot SPP Zambila, SPP Liziera, SPP35 Vederoasa, SPP36-2 Vederoasa under the administration of the Local Branch Dobrogea, Constanta Sud Unit; • by plotting and subsequently rezoning the site, the irrigation capacity is reduced by 14.2 km2. The Romanian National Land Improvement Administration, Local Branch Dobrogea, Constanta Sud Administration Unit approves the Zoning Urban Plan for the rezoning of the project site provided that:

• the permanent rezoning of the areas affected by land improvement works shall be done by means of an Order of the Manager of the Agriculture and Rural Development Directorate; • for the rezoning of the areas required for the project, the developer shall submit new application documents to obtain the NLIA approval. These application documents shall include the approval of the Zoning Urban Plan;

• the application documents to obtain the construction permit shall include the project construction documents in order to allow the NLIA to establish the safety areas and other conditions which are specific to land improvement works. Also, for the 14.2 km2 area a service agreement with the NLIA is required; • any land improvement works to be affected during the construction of the project shall be restored by the developer; • no constructions (buildings, installations, enclosures etc.) shall be carried out to a length of 3 m to CP1-SPP Zambila, CP1-SPP Liziera, CP1-SPP35 Vederoasa, CP2-SPP35 Vederoasa, CP1-SPP36-2 Vederoasa and the antennas corresponding to these pumping stations; • the NLIA personnel and equipment shall be allowed access to the site in order to maintain and repair land improvement works under the NLIA administration. This approval is valid for 12 months, until 8 July 2010, and shall not be construed as the NLIA land rezoning approval.

14.3 APPROVAL OF THE ZONING URBAN PLAN BY THE ROMANIAN MINISTRY OF NATIONAL DEFENCE

The Romanian Ministry of National Defence issued the approval D/1316 dated 27 July 2009 of the Zoning Urban Plan for the project provided the following conditions are met:

• the proposed turbine locations and the technical implementation solutions are observed; • the project location shall comply with the provisions of Annex 14 of the International Standards and Recommended Practices, article 7 of the Technical Norm M34/1980 on the limits of the safety areas for aeronautical sites and article 11 of Decree 95/1979, as follows: The light marking during night time shall be carried out by red lights operating continuously or intermittently, placed to ensure visibility from any direction and mark the site and the size of the obstacles in horizontal and vertical plane – requirements of article 12 of the Technical Norm M34/1980; for a safety operation, groups of two lamps supplied with power from a double network shall be used; the limits of the radiation angle for all lamps shall be from zenith to 25° below the horizon at all directions;

the maximum height of the obstacle shall be mandatorily light marked during night-time with a red-coloured light with an intensity and interval higher than the obscure one - – requirements of article 13 of the Technical Norm M34/1980; • the developer shall provide the Military Topographical Directorate within the Ministry of Defence with the data concerning the locations of the turbines so that these can be included in the air navigation maps, scale 1:250,000 and 1:500,000; • the constructor shall inform the Staff of the Air Force with regard to the date when construction works will start and the date when the wind farm shall be put into operation; • military operations, land areas, buildings or installations under the administration of the Ministry of National Defence are not to be affected in any way by the Project; • this approval is not to be used as part of the application documents for the construction permit, for which a new approval is required after the submission of the technical details for permitting the construction;

14.4 APPROVAL FROM THE COUNTY WATER SUPPLY OPERATOR REGIA AUTONOMA JUDETEANA DE APA (RAJA) – AREAL CENTRE MANGALIA

According to the approval no. 3970 dated 29 May 2009, RAJA Mangalia does not own any water supply pipelines on the project site. However, in order to avoid unexpected events, it requires that pipeline surveys are conducted. In case these surveys identify any pipelines the Areal Centre Mangalia shall be urgently notifed and the costs related to the diversion of the pipes shall be incurred by the developer. Moreover, in such a case further specific conditions to protect the pipelines shall be discussed on the spot.

14.5 APPROVAL FROM THE TELECOMMUNICATION OPERATOR ROMTELECOM

According to the Technical Approval 669/1 July 2009, the Telecommunication operator Romtelecom does not own or operate any telecommunication networks on the project site. However, the approval requires that for the excavation works in the area of the national, county and commune roads (for the installation of cables and construction of access roads, technical assistance from Romtelecom experts be contracted.

This approval is valid for one year since its release (until 1 July 2010). After this period, in case the project has not been implemented, a new approval is required.

14.6 APPROVAL FROM THE ROMANIAN NATIONAL GAS TRANSPORT COMPANY TRANSGAZ

According to the Approval 13634/489/23 June 2009, the Romanian National Gas Transport Company approved the Zoning Urban Plan for the Project, provided the following conditions are met:

• Prior to starting works, the Local Transit Unit Constanta shall be contacted in order to establish the access areas, working ares, specific safety measures and ensure the supervision of the works. • The distances between the gas transport pipelines and the closest turbines (as specified on the map approved by the company) shall be observed, as follows: 101 m distance between T8 and the transport pipeline T I having a nominal diameter Dn 1000 mm; 272 m distance between T18 and the transport pipeline T I having a nominal diameter Dn 1000 mm; 211 m distance between T32 and the transport pipeline T II having a nominal diameter Dn 1200 mm; 414 m distance between T31 and the transport pipeline T II having a nominal diameter Dn 1200 mm. • The areas where the gas pipelines intersect the access roads and the existing exploitation roads, the pipelines shall be protected by culverts and metal tubes (according to Romanian standard STAS 9312-87). The length of the culverts, respectively of the metal tubes, shall mandatorily exceed the width of the transport vehicles used. The angle of intersection between the axis of the pipeline and the axis of the road shall be as close to 90° as possible but not below 60°. • Specific technical documents for the protection of the gas pipelines shall be prepared by specialized companies and submitted for approval to Transgaz. • The developer shall pay all the costs for the pipeline protection works and shall provide unconditional access to the pipelines in case of interventions. • A minimum 6 m distance shall be kept between the gas pipeline and the access roads. • A minimum 20 m distance shall be kept between the substation and the gas pipeline.

• In the 6 m safety area to the left and right of the pipeline axis, excavation and subsequent backfilling works shall be performed manually thus avoiding the accidental hitting of the pipelines and their corrosion-proof insulation. • The contractor shall take all necessary safety measures specific to works involving risks of fire and explosion around gas pipelines. This approval is valid for 12 months since its release. However, the final approval shall be obtained only after the completion of the works to protect the gas transport pipelines.

14.7 ADDITIONAL AUTHORITIES APPROACHED DURING THE ZONING URBAN PLAN APPROVAL PROCESS

During the process of having the Zoning Urban Plan for the Project approved, the developer approached the following auhorities, which gave their approval without further specific conditions:

• The Romanian Civil Aeronautic Authority issued an approval on 8 July 2009 whose specific conditions are detailed in Section 9.1.18; • The Romanian Intelligence Service issued the Site Approval no. 61092 dated 25 June 2009 based on the information include in the Urban Certificate no. 173 dated 29 April 2009 issued by Constanta County Council; • Constanta Directorate for Culture, Religious Affairs and National Cultural Heritage of Constanta County issued the approval no. 847 dated 6 July 2009 of the Zoning Urban Plan for the Project. This approval was valid until 6 July 2010 and could not be used as part of the construction permit application documents for which a new approval is required. • Local Public Health Directorate Constanta issued the approval no. 2956 dated 12 June 2009 of the Zoning Urban Plan provided the noise limits at the neighbouring communes are complied with. • The Ministry of Administration and Interior gave its principle approval of the Zoning Urban Plan for the Project on 9 July 2009. This approval was based on the information included in the Urban Certificate no. 173 dated 29 April 2009 issued by Constanta County Council. • The Romanian National Power Grid Company Transelectrica - Local Branch Constanta released the official letter no. 4307 dated 15 June 2009 stating that it does not own any installations on the project site.

• The County Water Supply Operator Regia Autonoma Judeteana De Apa (RAJA) – Areal Centre Eforie released the official letter no. 52/1803 dated 3 June 2009 approving the selected site and stating that it does not own any water supply networks on the project site located in the unincorporated area of Chirnogeni Commune.

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