Prepared For: Consultancy Contract C26157REV/JPNS- 2013-02-01 Kazakhstan Renewable Energy Financing Facility (KazREFF) - Strategic Environmental Review
Renewable Project Environmental Review Report - Wind
June 2014
ERM Japan Ltd. The Landmark Tower Yokohama 19th Floor, 2-2-1 Minatomirai, Nishi-ku YOKOHAMA 220-8119 Japan www.erm.com
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Contents
1.0 INTRODUCTION 1
2.0 RESOURCE AVAILABILITY AND POTENTIAL 2
2.1 RESOURCE AVAILABILITY 2
2.2 RESOURCE POTENTIAL 6
2.3 TRANSMISSION CAPACITY AND CONSTRAINTS 6
2.3.1 Existing Conditions 7
2.3.2 Anticipated Development 10
2.4 EXISTING PROJECTS 11
2.5 KNOWN PROPOSED PROJECTS 11
3.0 AVAILABLE AND PRACTICAL TECHNOLOGIES 14
3.1 COMPONENTS 14
3.1.1 Met Mast/Towers 15
3.1.2 Wind Turbines and Foundations 16
3.1.3 Support Buildings 17
3.1.4 Access Roads 18
3.2 GRID CONNECTIVITY 18
3.3 SITE DESIGN AND CONFIGURATION 20
3.3.1 Wind Farm Layouts 22
3.3.2 Construction 23
3.3.3 Commissioning, Operation, and Maintenance 24
3.3.4 Decommissioning 24
3.4 DEVELOPMENT COSTS 25
3.5 SUPPLY CHAIN IN KAZAKHSTAN 25
4.0 ENVIRONMENTAL AND SOCIAL CONSTRAINTS 27
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5.0 KAZREFF PROJECT APPRAISAL - ENVIRONMENTAL AND SOCIAL PERFORMANCE REQUIREMENTS 31
5.1 EBRD REQUIREMENTS 31
5.1.1 Category A 32
5.1.2 Category B 33
5.2 KAZAKHSTAN REQUIREMENTS 33
5.3 KAZREFF APPRAISAL PROCESS 35
5.3.1 Initial Screening 36
5.3.2 Documentation Review and Approval/Feedback 36
6.0 APPENDICES 38
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1.0 INTRODUCTION
This Renewable Project Environmental Review (RPER) Report for Wind in Kazakhstan is one of four separate reports (other RPER reports were prepared for solar photovoltaic, small hydropower, and biogas) that have been prepared by Environmental Recourses Management (ERM) for the European Bank for Reconstruction and Development (EBRD). These RPER reports are prepared to support the Kazakhstan Renewable Energy Financing Facility (KazREFF) Strategic Environmental Review (SER) and provide a resource to provide guidance to developers and their consultants, as well as technical evaluators of proposed renewable projects, by identifying areas of good potential and the nature and scale of technologies that can be applied in different parts of Kazakhstan.
The source documents which have informed this RPER report are as follows:
• ERM KazREFF Strategic Environmental Review, Final Inception Report, 29 May 2013; • ERM KazREFF Strategic Environmental Review, Draft Scoping Report, 21 May 2013; • Mercados Energy Markets International, Kazakhstan Renewable Energy Market Study, Draft Final Report, July 2013 (ÅF-Mercados EMI (2013)); • United Nations Development Programme/Global Environment Facility, Kazakhstan- Wind Power Market Development Initiative, 2006 (UNDP 2006); • Black and Veatch, Renewable Energy in Ukraine Technical Report: Wind, 1 September 2011 (Black and Veatch 2011).
These sources have been supplemented by additional research carried out by ERM and additional sources of data identified in the text.
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2.0 RESOURCE AVAILABILITY AND POTENTIAL
This section of the report identifies the characteristics of the wind rich resource areas of the country and the regions of Kazakhstan where wind farm development is technically feasible. It also assesses the nature and extent of constraints to wind farm development.
2.1 RESOURCE AVAILABILITY
Kazakhstan is the world’s ninth largest country being some 2.7 million km2 in extent. Figure 1 shows the different oblasts of Kazakhstan. The western regions are dominated by extensive lowlands that include Aral and Caspian Seas, while the centre of the country is characterised by rolling hills with peaks up to 1,565 m. The south eastern and south western parts of the country are bordered by mountain ranges. Approximately 10 per cent of the country is occupied by mountains (Figure 2). The expanse of land and terrain within Kazakhstan indicates the potential wind resource that could be available for exploitation.
Figure 1 Location Map
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Figure 2 Topography Map
Kazakhstan is not wind resource limited (i.e. it will not be the availability of suitable wind regimes that will limit the amount of wind turbines deployed). Neither is it limited by available land. On the contrary, large swaths of the country have a very significant wind resource.
A wind atlas of Kazakhstan was developed as part of the United Nations Development Programme/Global Environment Facility (UNDP/GEF) Kazakhstan wind power market development initiative and is presented in Figure 3. The atlas shows the long-term average wind speed at 80 m above ground level, at 9 km resolution for much of the country, and at 100 m resolution for nine areas of particular interest. Green areas show areas of lower wind speeds and red areas show areas of high wind speed. It should be noted that the wind atlas shows the average wind speed of the various areas of Kazakhstan. Periods during which wind speed generation is higher are not taken into account. Studies have shown that wind speeds in Kazakhstan are higher in the winter months of December to January1.
A typical wind turbine can produce power at a minimum wind speed of 3.5 m/s, with the maximum wind speed for producing power being 25 m/s2. The optimum speed for power generation is typically 14 m/s. The UNDP/GEF atlas identifies that 50,000 km2 of territory across nine of the country’s 14 oblasts have a good wind resource (7—8 m/s). The north contains the highest wind power generation potential with Aqmola and North Kazakhstan oblasts averaging wind speeds of 8 m/s. Almaty Oblast
(1) Almaz Akhmetov (2012) Potential of Wind Power in Kazakhstan, LAP Lambert Academic Publishing AG & Co KG (2) http://webarchive.nationalarchives.gov.uk/+/http://www.berr.gov.uk/files/file17821.pdf
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(southern Kazakhstan) also contain areas of very good (8—9 m/s) wind speeds and contains exceptional wind speeds (>9 m/s) in mountainous areas. The atlas also identifies significant wind resources in west Kazakhstan with the areas with greatest potential located in Mangistau Oblast. The Eastern Oblast of Kazakhstan has the least potential for wind farm development with average wind speeds of 5 m/s. However, development is still possible in this oblast as a typical wind turbine can still operate in these conditions.
Table below highlights the wind power generating capacity of the three regions of Kazakhstan with the most potential for wind farm development. This potential in relation to transmission capacity and constraints is discussed in Section 2.3.
Table 1 Regional Wind Farm Potential
Transmission Region Wind Farm Potential (MW)3
West 2,200
North 11,878
South 3,162
Total 17,240
Source Åf-Mercados EMI (2013)
3 Unit of power equal to one million watts. (MBt in Russian)
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Figure 3 Wind Atlas for Kazakhstan Map
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2.2 RESOURCE POTENTIAL
Due to Kazakhstan’s wind energy potential and the increased demand for electricity in the country, a programme for wind farm development was created in by the Ministry of Energy and Mineral Resources (MEMR) with the support of United Nations Development Program (UNDP). The Kazakhstan – Wind Power Market Development Initiative” project began in December 2004 and finished in June 2011. The Project has been financed by the Global Environment Facility (GEF) with the Implementing Agency being the UNDP and the MEMR — now the Ministry of Industry and New Technology (MINT) — of the Government of the Republic of Kazakhstan (RoK) as the Executing Agency4.
This programme as well as other initiatives, was used by the RoK government as a basis for a series of actions and targets for wind development from 2015 to 2030 which encourages the construction of wind farms generating a capacity of 250-300 MW by 2015 and a capacity of up to 2,000 MW by 2030. If capacity is constructed according to these timescales the electricity generated would amount to 1TWh5 by 2015 and up to 5 TWh by 2030.
Kazakhstan has very large coal, oil, gas and uranium resources that are all being actively exploited. The country is the third largest producer of crude oil in Central Asia, behind Russia and China and has the third largest reserves outside of the OPEC member countries. One result of the abundance of energy resources has been the lack of a driver for developing wind energy on the basis of a scarcity of indigenous energy resources. Nevertheless, other drivers needed to be (and were) identified such as the need to reduce greenhouse gas emissions, to strengthen local power supply and to act as an economic stimulus6.
2.3 TRANSMISSION CAPACITY AND CONSTRAINTS
To realise the wind energy potential of Kazakhstan wind farm locations will need to be in proximity to existing transmission lines and the existing electricity grid will need to have adequate capacity to receive the power generated. Sites that are situated a great distance from load centres or major transmission lines face greater development costs and are generally less favourable than sites with better access to these facilities. Larger projects are able to locate farther away from transmission while smaller projects are
4 Lessons learnt from the UNDP-GEF project “Kazakhstan — Wind Power Market Development Initiative, UNDP Kazakhstan, 2011. 5 Unit of energy equal to 1000 watt hours. 6 Lessons learnt from the UNDP-GEF project “Kazakhstan — Wind Power Market Development Initiative, UNDP Kazakhstan, 2011.
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located closer to transmission, due to economies of scale of larger projects to absorb higher transmission costs7.
2.3.1 EXISTING CONDITIONS
The grid in Kazakhstan is state-owned and operated by the Kazakhstan Electricity Grid Operating Company (KEGOC). There are also 21 regional energy companies (RECs) that distribute electricity on a regional monopoly basis. Due to the size of Kazakhstan the network is characterised by long distance transmission. The Kazakhstan transmission network dates back to the Soviet era and has a history of underinvestment. However at present it has sufficient capacity and no voltage problems. The majority of the population is connected to the grid, less than 5 per cent of the population, located primarily in rural areas, are without electricity. However, in some areas power cuts or discontinuous supply are not uncommon due to grid capacity issues and a lack of local generation facilities. In addition, in some regions the industrial base has expanded and investment in power infrastructure has failed to keep pace. Figure 4 shows the areas of greatest population density and domestic energy demand in Kazakhstan.
Figure 4 Population Map by Oblast
The electricity grid is separated into three regions west, north and south (Figure 5). It has a general north-south split in generation and demand with approximately 80 per cent of the electricity being produced in the north near coal reserves and 70 per cent being used in the same industrialised region (UNDP/GEF 2011). The transmission system operates at 500 kV and 220 kV
7 Black & Veatch 2011
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and consists of 24,101 km of 35 - 1150 kV overhead transmission lines and 74 power substations with an installed capacity of 34,408 MVA (see Figure 6). A 1,100 km 500 kV electricity transmission system has connected the north and south regions since 2009. Due to demand growth in the southern zone the transmission lines connecting north and south are fully loaded, and in the period of peak demand (winter) they are reported to be occasionally overloaded.
The northern electricity grid contains links to Russia and Central Asia and the southern network contains links to Kyrgyzstan and Uzbekistan. The west of the grid is isolated from the remainder of the national electricity system and has interconnections with Russia.
From 2011 to 2013 power consumption significantly exceeded energy production, which, taken into account transmission losses has highlighted a deficit of approximately 800 MW. This deficit is currently overcome by importing electricity from neighbouring countries. Demand is projected to reach 145 TWh by 2030 from the current level (CAGR of 2.6 per cent) (Åf- Mercados EMI 2013).
Figure 5 Transmission Regions in Kazakhstan
658 209 700 1173 1180 390 3195 480 850 1720 1609 700 160 95 337 1823
348
90 1862 160
160 320 1020 860 1620 1020
Source Åf-Mercados EMI (2013)
The proximity of existing transmission lines to areas of high wind power potential and the good correlation between seasonal wind levels and the peak
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in demand for electricity (the winter months) create conditions that favour the successful integration of wind power development in Kazakhstan.
In particular developing wind power projects in the south could help solve the problem of the overload of the north-south transmission lines. The northern zone has an excess of generation, but development would still be an advantage in order to reduce the power imports from neighbouring Russia. The western grid operates separately and currently has a load shortage of about 100 MW, which is also covered by power import from Russia. Again wind power development would reduce Kazakhstan’s reliance on imports from Russia.
Figure 6 Transmission System Map
Table 2 below gives an overview of the distribution of potential wind power in Kazakhstan, the proposed scale of development by 2030 according to the MEMR and UNDP wind farm development plan and the grid capacity by region.
Table 2 Wind Farm Potential and Grid Capacity in Kazakhstan
(MW) Wind Farm Grid capacity* Wind Farm Potential proposed in 2030 (UNDP)
West 2,200 601 250
North 11,878 2,705 800
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South 3,162 718 950
Total 17,240 4,024 2,000
* Based on expert judgement, taking 20 per cent of installed capacity as the guiding rule of thumb. Source: Åf-Mercados EMI (2013)
The table shows that approximately 20 per cent of potential installed capacity in the three regions could currently be connected to the grid. In order for Kazakhstan to achieve its potential of 17,240 MW generated by wind power the grid would require upgrading. The proposed target of generating 2,000 MW generated by 2030 are achievable with the existing transmission grid.
Based on power demand and transmission connectivity all three regions have wind farm development potential. However, there are some other considerations that need to be taken into account which may present barriers to wind development.
The west, due to its isolation may have stability problems if no grid development projects are implemented. For a power grid to remain stable, the frequency and phase of all power generation units must remain synchronous within narrow operational limits. Wind power generation is not constant and as the western grid has limited connections it may not be able to handle small frequency changes. The north, however, has a balancing advantage, due to sufficient transmission capacity to the Russian grid, which has a relatively stable power system. This region also has the highest potential capacity and strong connections to the southern region.
2.3.2 ANTICIPATED DEVELOPMENT
The suitability of the above regions for development of wind power assumes that there is no investment in the electricity grid of Kazakhstan. However it should be noted that considerable network development both on-going and planned is being undertaken by Government of the RoK and KEGOC.
Projects planned, or currently being implemented, include:
• Modernization of the national electrical network (NEN) to be completed by 2016. The project comprises reconstruction of the majority of substations and construction of some new transmission lines; • Construction of a 500 kV substation "Alma" ( located in the area of Almaty) with connection to the NEN This will eliminate the overloading of existing "Almaty" substation and ensure the reliability of power supply to the Almaty region; and
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• Reconstruction of a 220 kV overhead line central main substation in Astana.
There are also plans for connecting the western grid to the national grid by 2030.
2.4 EXISTING PROJECTS
At present there is only one wind farm in operation in Kazakhstan. The Kordai wind farm has a capacity of 1.5 MW (two turbines of 750 kW) and is located in the south of Kazakhstan in Zhambyl Oblast. This project is scheduled to be expanded to a capacity of 20 MW by the end of 2013.
2.5 KNOWN PROPOSED PROJECTS
In addition to small-scale local wind farms, larger scale installations are planned. The 2006 UNDP/GEF identifies 26 potential large wind farm locations which could be developed due to their optimal conditions in terms of grid connections and wind speeds. Not all of these sites however are likely to be developed due to other technical development constraints. At present there are 10 sites identified for development in 2014 by the Ministry of Industry and New Technologies (MINT) (see Table 3 and Figure 7). Half of these sites are located in the northern grid with only two located in the western region.
Each of these projects should be evaluated against the technical constraints outline in Section 3.3 and the environmental social constraints outlined in Section 4.0. These projects are scattered throughout Kazakhstan and therefore, do not appear to contribute to adverse cumulative impacts issues.
Table 3 MINT Wind Farm Sites to be Developed by 2014
Site Number Site Geographic Grid Installed Region capacity, MW (MBt)
1 Shelek corridor Southern South 51 Kazakhstan
2 Djungar gates Eastern North 50 Kazakhstan
3 Upper Tainti, Eastern North 24 East Kazakhstan Kazakhstan
4 2 km to the East Central North 10 of Kargalinsk
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Site Number Site Geographic Grid Installed Region capacity, MW (MBt)
city, Karagandy Kazakhstan
5 2 km to the Central North 35 South-West of Kazakhstan Yermentau, (Mount Yermentau)
6 5 km to the Central North 40 West of Arkalyk Kazakhstan city, Kostanay, (Mount Arkalyk)
7 40 km to the Western West 40 North-East of Kazakhstan. Atyrau city (near Karabatan)
8 10 km South- Western West 40 West of Fort- Kazakhstan Shevchenko city, Mangistau
9 Zhysymndik South South 40 Kazakhstan
10 30 km South- Southern South 20 West of Qorday Kazakhstan Zhambyl
Source: (Åf-Mercados EMI (2013)
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Figure 7 Location of Proposed MINT sites for 2014
Source: MINT (2010) www.kazembassy.org.uk
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3.0 AVAILABLE AND PRACTICAL TECHNOLOGIES
This section looks at the type of technology that would be employed for wind farm development in Kazakhstan. It details the key activities and environmental and physical constraints to be taken into consideration for the construction, operation and decommissioning of a potential site. It also discusses the current status of the wind power supply chain in Kazakhstan.
3.1 COMPONENTS
Three types of wind project are presently being considered for wind power generation in Kazakhstan. These projects are as follows:
• Small wind farms with less than 20 MW of capacity; • Medium size wind farms with capacities ranging from 20 MW to 100 MW; and • Large wind farms with greater than 100 MW of capacity (see Table 4).
In general, a turbine’s generating capacity typically extends to 2.5 to 3 MW with 5 MW models currently under development.
The following sections detail the typical wind farm components required for these projects, the layout of these components and the performance and operation of a typical wind farm. Project costs and component availability in Kazakhstan are also discussed.
Table 4 Typical Wind Farm Sizes
System Size Small Medium Large
Capacity <20 20-100 >100
No. of Turbines 7-20 7-50 50+
Source: Black and Veatch 2011
There are four main wind farm components described in the sections below:
• Meteorological (met) masts (and occasionally also met mast foundations); • Wind turbine foundations and wind turbines; • Buildings housing electrical switchgear, supervisory control and data acquisition equipment, and possibly spares and maintenance facilities; and • Access roads.
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3.1.1 MET MAST/TOWERS
Once a potential wind farm site is identified a met tower is usually installed to monitor the wind conditions of the site and confirm its suitability. These towers typically measure the wind speed, wind direction, temperature, pressure and humidity at the site. This data is important in developing a robust template for site design. The number of towers required is linked to the terrain of the proposed site. Wind farms located in complex terrain are more likely to require more than one mast to give an adequate picture of the wind resource across the site.
Typically there are three types of tower used in wind farm development. An initial small mast of approximately 40 m is installed first which requires no foundations and can be secured by guy ropes. These towers are usually installed 1 to 3 years before site construction. The data collected from these towers is extrapolated to reveal the predicted wind speeds at full wind turbine height (80-100m).
If after this data is analysed, the site is considered suitable for development, then met towers of wind turbine hub height are installed (usually approximately 80 m), as necessary, to confirm the monitoring results. These towers are usually in situ for 2 to 3 months before turbine construction.
Usually full turbine height permanent met towers are installed to monitor wind resources for operating wind farms. These towers typically require foundations and help ensure the efficient performance of installed turbines as shown in Figure 8.
Figure 8 Typical Permanent Met Mast
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3.1.2 WIND TURBINES AND FOUNDATIONS
There are commonly two types of wind turbine, vertical and horizontal axis machines. The most common design is the horizontal three bladed axis turbines. Two bladed axis turbines are generally cheaper however they have a higher operational noise than three bladed axis turbines and, depending on the location of a proposed development this may affect their use. The main components of a utility-scale wind turbine are presented below:
Turbine - A wind turbine comprises of a tower that supports a nacelle, the main shell containing an electric generator and the turbine blades attached via a hub. The nacelle has an anemometer attached so that the direction in which the blades face can be altered to maximise wind capture. It also houses the mechanical machinery and a device known as "the yaw mechanism", which allows the machine to turn itself towards the prevailing wind (Figure 9).
Figure 9 Schematic of Wind Turbine
Images courtesy of http://www.boem.gov/Renewable-Energy-Program/Renewable-Energy- Guide/Offshore-Wind-Energy.aspx and http://www.intechopen.com/books/advances-in- wind-power/wind-turbine-generator-technologies
Blades - The majority of rotor blades are made of glass reinforced plastic or wood epoxy but can be of aluminium or steel. A turbine works by the movement of wind through the rotor blades creating energy which spins a shaft leading from the hub of the rotor to a generator. This process results in electricity generation. A typical 80 m high tower contains a rotor diameter of approximately 90 m giving an overall operating height of 125 m.
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Tower - The tower of a turbine is installed using prefabricated tubes. Tubular towers are preferred due to aesthetic qualities and the ability to use the base of the tower for the switchgear and controls. Such a design also makes access to the nacelle safer, as a ladder can be placed inside the tower. Tower height varies depending on the manufacturer and amount of power generated. Rotor length also determines the minimum height of the tower as an appropriate clearance is required for the blades to turn safely. Typical turbine towers range from 80 to 100 m in height.
Base/Foundation – The detailed design of foundations depends on the type of foundation used and the ground conditions of the site. Turbine towers are generally fixed to a concrete foundation up to 18 m in diameter and 4 m deep, dependent on the size of the turbine. A turbine foundation must support the weight of all of the turbine equipment as well as the thrust load produced by the rotors. The surface of the foundation is normally flush with the surrounding ground (see Figure 10). If a site is located in land normally used for agricultural purposes, agricultural use can continue up to the edge of and over the foundations. Specially designed foundations such as piled foundations can also be used to minimise ground disturbance. For example wind erosion is widespread in Kazakhstan in arid and semi-arid areas, special mitigation measures such as piled foundations could be utilised to minimise construction impacts.
Figure 10 Wind Turbine Foundation Schematic and Photograph
Photo courtesy of http://dnrc.mt.gov/Trust/Wind/JudithGap.asp
3.1.3 SUPPORT BUILDINGS
Wind farms require a central computerised monitoring system, which controls the operation of the turbines. As mentioned above, switch gear, transformer and control equipment can occasionally be located in the turbine tower, however sometimes an additional building is required adjacent to the turbines. This on-site equipment is linked electronically to an operations headquarters off-site. Most wind farms do not contain permanent onsite staff however some larger sites may require staff during operation.
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The control unit is used to manage the turbines to avoid damage to equipment and enable a complete shut down when wind speeds are too high. Turbines can also be shut down when wind speeds are too low to be commercially viable.
The transformer is used to increase low voltages produced by the wind turbines to a higher voltage which can then be collected by a substation.
3.1.4 ACCESS ROADS
During the construction and operation phases wind turbines will normally require adequate means of vehicular access, capable of supporting heavy goods vehicles (HGV) carrying machinery. Stone and aggregate for access tracks and hard standing, concrete and steel for foundations, and cabling to transfer electricity, for example, will all need to be transported to site.
Extra-long vehicles carrying wind turbine rotors and towers (abnormal loads) will also be required to access the site. This will require the development of access roads to the site and connections to exiting road networks. In Kazakhstan, roads are the main infrastructure for haulage. In Kazakhstan many rural roads are in poor repair. A Strategy of Transport Sector Development for works up to 2015 has been developed, however the strategy is primarily focused on major transport corridors. In rural areas roads may not currently be accessible to HGVs or be suitable for abnormal loads. An abnormal loads and HGV assessment would be necessary for any potential wind farm site. Potential wind farm areas in more rural areas may therefore be inaccessible for development without substantial road infrastructure costs.
3.2 GRID CONNECTIVITY
Wind turbines are induction generators that require reactive power, depending on the output power and power factor correction, which can cause self-excitation, thus increasing harmonic content. Increasing harmonic content can create stability concerns for an interconnection, especially within weaker power systems (e.g. radial distribution lines). Different padmount transformer configurations can also increase or decrease the amount of fault current onto the system, so it is important to design the system to keep the zero sequence impedance to a minimum, but still have a ground reference (so no overvoltage scenarios occur). Series neutral reactors or resistors can be added to the neutral connections of the collection system to increase the zero sequence impedance, thus decreasing the fault current. The on-site collection system is typically operated at voltages of 25 to 35 kV. Wind projects of different sizes have different interconnection concerns as discussed below.
Smaller interconnections (< 20 MW) are typically more feasible to interconnect at lower voltages due to the equipment necessary to build out an interconnection substation for the wind farm. These interconnections would
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be best suited at the lower transmission voltage and distribution levels. The other reason for this is that smaller wind farms will typically serve local load instead of delivering power across long high-voltage transmission lines. The only caveat is that intermittent resources should not be interconnected to radial distribution systems due to stability concerns at the local distribution level. Smaller scale wind farms can typically deliver the power through one medium voltage underground feeder which may tap directly into the distribution system at an interconnection substation Each individual wind turbine will require a low voltage to medium voltage step-up transformer, although some newer models have built-in transformers inside the nacelle. A step-up transformer from the medium voltage side of the wind turbine pad mount transformers may not be necessary if the feeder voltage is the same as the distribution voltage. Distribution interconnection codes vary and should be used to determine requirements.
Medium scale interconnections (20-100 MW) are more feasible to interconnect at the medium transmission voltages, such as 220 kV and 330 kV. These project substations require larger equipment, but are acceptable for medium scale wind farms. These wind farms may serve local load, but can also be delivered into key transmission substations which step up to higher voltages. It is also optimal to locate these at substations with multiple outlets to avoid curtailment and ensure delivery of power. Medium scale interconnections typically require two to four medium-voltage feeders that collect into enclosed switchgear within a new collector substation at the project site which then is connected via overhead transmission to an interconnection substation. The switchgear may also be located within an existing substation and interconnected to a built out bus within the fence.
Large scale interconnections (>100 MW) are injected at higher voltage substations that have multiple outlets. The reason for this is to allow for delivery dispersed between multiple transmission lines and to avoid curtailment.
Figure 11 shows an example of a wind turbine with connecting cables and sub station.
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Figure 11 Typical Grid Connection for Wind Turbine
Source: Black & Veatch 2011
3.3 SITE DESIGN AND CONFIGURATION
As a rough guide, the installed capacity of the wind farm is likely to be 18 to 48 hectares per MW8. Lower capacities relate to areas of forest land while higher capacities relate to areas of farmland. As a general rule grouped turbines need to be positioned to allow a separation distance of around 3-4 rotor diameters between turbines. This limits energy loss through wind shadowing from upstream machines. Due to this spacing not all land within a proposed site is impacted by development; only two to eight per cent of a site is typically impacted by development 9 . This affected land can be separated into permanent structures of turbines and access roads and temporary impacts of laydown areas and access routes. Typically, the existing land use activities can continue during operation (e.g. farming and grazing).
Several factors should be considered when selecting a site and designing its configuration. The quality of the resource is an obvious primary consideration; however, there are some other significant issues in Kazakhstan, identified in the SER that should be considered when siting power facilities:
• Ground slope – In general ground slopes of less than 20 per cent are optimal for wind power plants. While plants can be designed to work
8 Denholm, P. et al, “Land-Use Requirements of Modern Wind Power Plants in the United States.” National Renewable Energy Lab NREL/TP-6A2-45834, August 2009.
9 Black & Veatch 2011
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on more steeply slopes lands, it is more economical to work of flatter lands. Access roads are also needed within the facility during construction and later for routine maintenance, so minimal slope is optimal.
• Extreme weather – Kazakhstan has cold winters which can reach as low as -58 °C and hot summers which can reach as high as 53 °C. Much of the north of the country is affected by snow in the winter. Such extreme temperatures could impact upon turbine functionality and may require extra servicing or advanced specification equipment. This is particularly relevant since the north of Kazakhstan has a high potential for wind development which is in highest demand in the winter months. Areas in the west of the country have an arid desert climate which could have implications on turbine foundation construction and turbine functionality. This may also impact project economics and should be considered for projects in the northern and eastern oblasts. In addition, areas with winds that are extremely strong may require design modifications to prevent damage to the turbines.
• Flood prone areas – Construction of wind power facilities in areas prone to flooding could result in the damage of turbine foundations and associated infrastructure. In general, construction in flood prone areas should be avoided.
• Seismicity, mudflows, and landslides - Construction of wind power facilities in areas of high seismicity or in areas prone to mudflows and landslides could result in the damage of turbines and associated infrastructure. In general, construction in high risk areas for these hazards should be avoided.
• Contaminated lands – Construction of solar facilities on contaminated lands may be a beneficial use of these degraded areas; however, special consideration must be made to ensure the health of workers that could be exposed to contaminants at the surface (e.g. nuclear testing areas) or below ground during construction.
• Land use - Wind power facilities would not be economically feasible on open water, especially given the abundance of available land in Kazakhstan; therefore, it is unlikely any facilities would be water- based.
• Proximity to transmission grid and loading – In general, facilities should be located proximate to existing substations with capacity on the transmission grid. Wind power facilities become to become less economical at increasing distances from substations due to the costs
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associated with extending distribution or transmission lines to the wind power plant.
3.3.1 WIND FARM LAYOUTS
The layout of a wind farm is site specific; it looks at the most efficient placement of turbines combined with the landforms/landscape the turbines are set within. The landscape of Kazakhstan is extremely diverse therefore no generic layout will suit all sites.
The most common layouts are a single line and grid (see Figures 12 and 13). These layouts are generally suited to the two types of terrain commonly used for wind farm siting, hill ridges and flat land. Hill ridges typically use a single line layout as it generates the best wind exposure. In the case of a site on flat land, a grid layout enables the wind resource to be captured in all areas of the site.
Figure 12 Photograph of a Ridge Line Wind Farm Installation
Source : http://www.ostenergy.com/en/Wind
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Figure 13 Photograph of a Grid Layout Wind Farm Installation
Source: http://www.snh.gov.uk/docs/A337202.pdf
3.3.2 CONSTRUCTION
Construction of a wind farm site is site specific as it relates to the type, size and location of the proposed wind farm. In general however the construction of a typical wind farm site will consist of the following phases:
• Mobilisation, including demarcation of the site boundary if practical, erection of temporary fencing or other suitable measures to protect adjacent sensitive habitats, and creation of a construction compound for off-loading materials and components and to accommodate temporary site offices and welfare facilities; • Creation of suitable access to site boundary; • Site clearance including any tree/shrub felling to allow construction of new tracks, stripping of vegetation, top and subsoil, and creation of soil storage areas; • Construction of internal tracks for access to turbines, mast and switch building locations; • Excavation of cable trenches and laying of electricity and communications cables; • Construction of turbine foundations including necessary excavations; • The delivery and erection of turbine towers and installation of nacelles and blades; • Construction of the grid connection and operations and control building including the switchgear and metering;
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• Erection of the permanent met mast; and • Progressive site reinstatement and restoration.
3.3.3 COMMISSIONING, OPERATION, AND MAINTENANCE
Once construction is complete, the wind farm is commissioned. Commissioning involves standard tests for electrical infrastructure and turbines. It usually takes a period of six months for the wind farm to reach full operation with operational levels increasing from 80 per cent–90 per cent after commissioning to a long-term operational level of 97 per cent or more10.
Once in operation, the turbines will normally be automated and visits to the site by operations staff will only be required approximately once a week for scheduled services and visual inspection of the turbines.
Longer visits for servicing, typically every six months, will be required to check and inspect blades, fastenings and oil quality. An oil change should only be necessary if there is an indication of degradation in the oil quality following the six monthly inspections. The blade and main brake activation systems usually under hydraulic control will require hydraulic oil replacement every five years. Unscheduled maintenance may also be required if there are equipment problems. If this is required for equipment within the nacelle then a crane will need to be brought to the site.
3.3.4 DECOMMISSIONING
The projected operational lifetime of a typical wind farm is 25 years. After this period there are two options, repowering the site and replacing existing wind turbines or decommissioning the site, removing the wind turbines and other major structures and reinstating the site.
Prior to decommissioning, a decommissioning method statement, detailing or how the site will be restored is usually prepared and approved by the relevant authorities.
At present wind turbines and met masts are removed by crane and reused elsewhere if possible. In the case of the foundation works, upper sections are removed and the voids backfilled with appropriate materials to support the land use at that time. Underground cables and deep concrete foundations are usually left in place as removal is likely to cause more disruption than leaving them in-situ. However, if techniques exist at that time to allow sensitive removal then these will be appraised and considered. Surface vegetation or soil make-up is also to be restored. As with the turbines the electrical control
10 http://www.renewableenergyworld.com/rea/news/article/2009/04/wind-farm-design-planning-research-and- commissioning
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building and internal equipment is removed and reused or recycled where possible.
3.4 DEVELOPMENT COSTS
Wind farm costs are largely determined by the complexity of the site and the turbine loads. The site may be considered complex if the ground conditions are difficult, for example hard rock or very wet ground or poor accessibility. A very windy site with high turbine loads will result in the need for more sophisticated civil infrastructure as well as turbines with site specific specifications. Table 5 shows the costs associated with a typical wind farm for each size of project. Extreme site examples are not included.
Table 5 Typical Wind Farm Costs
Small Medium Large
Installation Cost 2300-2700 2000-2500 1900-2300 (US$/kW)
Maintenance Cost 50-60 40-50 40-50 (US$/kW)
Source: Black and Veatch 2011
3.5 SUPPLY CHAIN IN KAZAKHSTAN
At present there is little wind farm development in Kazakhstan and therefore the wind turbine components industry and its associated supply chain of goods and services is poorly developed. As a result, it is reasonable to assume in the short- to medium-term, that components for wind power technology will need to be supplied from external sources. However, it was noted during meetings with local university meetings, that extreme climatic conditions in Kazakhstan may be unsuitable for imported technology and that these conditions may provide an impetus for local development of this technology. Skills and equipment from the extractives sector may have the potential to be adapted to aspects of wind farm development.
The world’s leading manufacturer of wind turbines is Denmark's Vestas with just under 15 per cent of the market share in 2011, other leading manufacturers are located in China, Germany and India( ). Kazakhstan is placed to take advantage of these manufacturers especially China through importing turbines using road and rail links. Successful wind farm development would require the expansion of the industry to provide locally sourced specialist equipment. For example the erection of wind turbines will require special cranes to assemble the towers of approximately 80 m. These cranes at present may not be readily available. Typical wind farm
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components of foundations and towers however use basic construction materials and labour and therefore may be able to be sourced locally.
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4.0 ENVIRONMENTAL AND SOCIAL CONSTRAINTS
A detailed assessment of environmental and social constraints related to wind (and the other three RES evaluated) is provided in the SER Report. Environmental and social factors that could significantly impact the effectiveness, economic feasibility, and therefore, the siting of these facilities are addressed in Section 3.3 of this RPER. In addition, there are areas of high environmental and/or social sensitivity the proximity of which should also be strongly considered. These environmental and/or social high sensitivity areas are discussed in detail in the SER and are summarized in this section.
• Important Bird Areas/Migratory Birds - There is a significant potential for birds and bat mortality resulting from wind strikes with turbines. Therefore, the siting of wind facilities in Important Bird Areas (IBAs), near known bird migratory routes, or bat roosting habitat should be avoided to the greatest extent possible. In addition, due to the height of wind turbines and the flight paths of migratory birds, an additional protective buffer of 5km should be placed around IBAs. Where siting facilities within an IBA or the buffer area is unavoidable, a more detailed assessment of environmental effects and additional impact mitigation measures will be required.
• Forested Areas - Potential wind sites in forested areas would be discouraged given the relative lack of this habitat and the abundance of un-forested areas throughout the country. When siting facilities within a forested area is unavoidable, a more detailed assessment of environmental effects and additional impact mitigation measures will be required.
• Protected/Designated Lands - Potential wind sites in or near other areas afforded legal protection, including National Parks, and preserved lands would be discouraged given the relative lack of this habitat and the abundance of un-forested areas throughout the country. When siting facilities within a protected/designated area is unavoidable, additional impact mitigation measures will be required.
• Surface Water Quality - Due to clearing, grading, trenching and foundation construction for the wind power plant components, there is a potential for soil erosion during construction. Due to this potential, if wind power facilities are located within 1km of a surface water feature (e.g., intermittent or perennial stream, lakes, or ponds), a more detailed assessment of environmental effects and additional impact mitigation measures will be required.
• Cultural heritage - Special care should be taken to avoid siting wind facilities at or within the viewshed of known or tentative UNESCO
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World Heritage sites due to the global uniqueness of these areas. Special care should also be taken to avoid placing wind facilities on or near locally-registered cultural heritage sites. Given the height of potential wind turbines, the lack of obstructive forest cover over most of Kazakhstan, and the generally flat terrain, a viewshed buffer of 20km should be placed around known or tentative UNESCO and national heritage features. When siting facilities within a viewshed buffer is unavoidable, a more detailed assessment of environmental effects and additional impact mitigation measures will be required. Cultural heritage features themselves would be considered exclusion zones.
• Material Assets/Social - Airplane or helicopter pilots can become disoriented by potential flicker and reflection of light off spinning wind turbine blades. In addition, the height of these wind turbines can create a higher potential for crashes in poor visibility conditions near airports. Therefore, special measures should be taken to avoid siting facilities near airports. Given the height of potential wind turbines, a buffer of 5km should be placed around airports. When siting facilities within a buffer is unavoidable, a more detailed assessment of environmental effects and additional impact mitigation measures will be required. Airports themselves would be considered exclusion zones.
• Settlements/Social – When considering potential wind farm sites, the impact on nearby residents and communities should be taken into account. Wind farms can impact upon residents through noise generation, vibration, and visual impacts (including shadow flicker) and construction/ operation traffic. Appropriate distances away from built up areas should be taken into account when analysing a potential site; therefore, a buffer of 1km should be placed around settlements (e.g., villages, towns, cities). When siting facilities within a buffer is unavoidable, a more detailed assessment of environmental effects and additional impact mitigation measures will be required. Settlements themselves would be considered exclusion zones.
• Cumulative effects – Special consideration should be given to the impact of concentrating multiple wind farms in a tightly constrained wind resource area that is also used as a major migratory bird flyway or near an IBA. Potentially significant cumulative effects associated with wind are presented in Table 6. Guidance for cumulative impact assessment at the development-specific level is available for RES from a number of different sources. These will be used as required by the Project Implementation Unit to establish the methodology for specific financed projects where there are potential cumulative impacts. A list of the most recent and relevant guidance and research is provided below:
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o Scottish Natural Heritage (SNH). “Assessing the Cumulative Impact of Onshore Wind Energy Developments”, March 2012. Available at: http://www.snh.gov.uk/docs/A675503.pdf.
o Band, W., Madders, M., Whitfield, D.P. (2007). Developing field and analytical methods to assess avian collision risk at wind farms. In “Birds and Wind farms: Risk Assessment and Mitigation” Eds. Manuela de Lucas, Guyonne F. E. Janss and Miguel Ferrer. Quercus Books.
o Masden, E.A., Haydon, D.T., Fox, A.D., Furness, R.W., Bullman, R & Desholm, M. (2009). Barriers to movement: impacts of wind farms on migrating birds ICES J. Mar. Science. 66: 746-753.
o Maclean, I. & Rehfisch, M. (2008). Developing techniques for ornithological cumulative impact assessment. BTO Report 513.
o Pearce-Higgins, J.W., Stephen, L., Langston, R.H.W., Bainbridge, I.P. & Bullman, R (2009). The distribution of breeding birds around upland wind farms. Journal of Applied Ecology 46: 1323–1331.
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Table 6 Cumulative effect issues associated with wind power generation and mitigation measures
Valued Geographic Temporal Issue Potential Mitigation Measures Resources Boundary Boundary WIND Cumulative effects on bird migration by wind development because of the potential for large wind farms to be Evaluate cumulative effects of Areas of high concentrated near important specific wind farms near migratory Biodiversity – wind speed Project migratory bird routes or near an IBA. pathways and IBAs and implement A tight concentration of wind farms birds near migratory operation until siting/spacing limitations. Also, in a tightly constrained flyway or routes and demobilisation implement technology mitigation near IBAs, could have a significant IBAs mortality effect on migrating birds. measures, outlined in Table 8-38. This may be compounded during poor weather with low visibility. Areas of high wind speed Visual screening, limits on the Project Cumulative effects to aesthetics near number of facilities in a defined area, associated with siting multiple wind Landscape operation until settlements or and siting/design modifications to facilities in a single viewshed demobilisation recreational decrease visual impact. areas Regional planning to limit the Cumulative impacts to roads and number of wind facilities in a related infrastructure from the Material Areas of high Project sensitive area or contributions to a development of multiple wind assets - roads wind speed construction fund used to pay for regional road facilities in a concentrated area and infrastructure improvements.
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5.0 KAZREFF PROJECT APPRAISAL - ENVIRONMENTAL AND SOCIAL PERFORMANCE REQUIREMENTS
Wind projects funded under KazREFF will be subject to the following environmental and social requirements, as stipulated by EBRD:
• The EBRD’s Environmental and Social Policy (2008) and its associated Performance Requirements. • Applicable requirements of Kazakhstan, including but not limited to those related with environmental impact assessments, environmental permitting, labour, public consultation, resettlement and compensation, occupational health and safety, community health and safety, and emergency response. • Relevant European Union Directives and requirements • International best practices, including those promulgated by other international financial institutions, the International Labour Organisation, and others.
5.1 EBRD REQUIREMENTS
Projects would need to adhere to the EBRD Environmental and Social Policy and its associated Performance Requirements (PR), which cover the following areas:
• PR 1: Environmental and Social Appraisal and Management • PR 2: Labour and Working Conditions • PR 3: Pollution Prevention and Abatement • PR 4: Community Health & Safety and Security • PR 5: Land Acquisition, Involuntary Resettlement and Economic Displacement • PR 6: Biodiversity Conservation and Sustainable Resource Management • PR 7: Indigenous Peoples • PR 8: Cultural Heritage • PR 9: Financial Intermediaries (FI) • PR 10: Information Disclosure and Stakeholder Engagement
Depending upon the scale of KazREFF project, EBRD would require a series of environmental documents to be produced in order to gain EBRD funding. Projects are screened at an early stage and placed into one of the four following categories, depending on the level and type of environmental and social due diligence that is required:
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• Category A projects are those with potentially significant and diverse environmental and social impacts, requiring detailed impact assessments • Category B projects are those with environmental and social impacts that are site-specific and can be addressed through readily available management and mitigation techniques • Category C projects have minimal environmental or social impacts • FI projects are where the EBRD is investing in a Financial Intermediary, such as a bank or equity fund.
This categorization reflects: (i) reflect the level of potential environmental and social effects and issues associated with the proposed project; and (ii) determine the nature and level of environmental and social investigations, information disclosure and stakeholder engagement required for each project, taking into account the nature, location, sensitivity and scale of the project, and the nature and magnitude of its possible environmental and social effect and issues.
Due to the relatively small scale of the potential KazREFF projects, most would likely fall under Category B, as the potential adverse environmental and/or social effects that they may give rise to are typically site-specific, and/or readily identified and addressed through mitigation measures. However, the siting of wind facilities within or near sensitive/protected areas or in situations where impacts could be more severe may result in these being classified as Category A projects. This determination is made by EBRD and KazREFF in the initial project phases.
5.1.1 CATEGORY A
If a project is considered to be a Category A project, it is usual to expect that it would require the development and disclosure of an Environmental and Social Impact Assessment Package including:
• An ESIA; • A Non-Technical Summary (NTS); • An Environmental and Social Action Plan (ESAP); • A Stakeholder Engagement Plan (SEP); • A Land Acquisition Plan (if land acquisition is required); • A Resettlement Action Plan (if population displacement is required).
Disclosure of these documents generally allows for a 120 day public consultation period, after which the documents are finalized, published, and financing may be secured. In general, the timeframe for completing the environmental and social review process for a Category A project typically takes 9 to 12 months to complete.
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5.1.2 CATEGORY B
If categorized as a Category B project, there are less detailed documentation requirements due to the lesser potential for significant environmental and social impact. EBRD typically requires the development and disclosure of:
• A Project Summary Document; • A Project Fact Sheet or Non-Technical Summary (NTS);
For Category B projects, EBRD also typically reviews, but does not require disclosure of:
• An Environmental and Social Action Plan (ESAP); • A Stakeholder Engagement Plan (SEP); • An Environmental and Social Due Diligence (ESDD) document that demonstrates compliance with PR1
Disclosure of these required documents generally allows for a 30 day public consultation period, after which the documents are finalized, published, and financing may be secured. In general, the timeframe for completing the environmental and social review process for a Category B project typically takes 3 to 6 months to complete.
5.2 KAZAKHSTAN REQUIREMENTS
Specific requirements for EIA procedures for all categories of economic activity are established by the document “Instruction on Environmental Impact Assessment at the Development of Prior Planned, Planned, Prior Project, and Project Documentation”. This guide contains:
• A list of activities which require implementation of the EIA procedure in full;
• A list of activities for which the full EIA procedure is proposed to the State Environmental Expertize (SEE) on the basis of preliminary expertise or by applying a set of criteria determined in normative documents; and
• A list of activities with insignificant environmental impact, for which only the preparation of an "Environmental impact statement" is sufficient for submission to the SEE.
Projects in Kazakhstan are classified by the Sanitary and Epidemiological Services (SES) of MOH according to five danger levels with one being the highest as defined by norms and standards in relation to human health and safety. The sensitivities of projects are measured by the SES Danger/Sanitary Categories. The categories are:
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• Danger/Sanitary Categories 1 & 2 projects have levels of severity/danger that trigger a full EIA. • Danger/Sanitary Category 3 projects are considered to have lower levels of severity/danger and as such a lesser assessment is undertaken, although still referred to as an Environmental Assessment. • Danger/Sanitary Category 4 & 5 projects are considered to present considerably lower risks of severity/danger and generally do not warrant an assessment beyond the initial screening.
The SES Danger/Sanitary Categories relate to four categories of RoK EIA (Оценка воздействия на окружающую среду - OVOS). The EIA/OVOS Categories are:
• Category I - Sanitary Class/Danger Categories 1 and 2 plus investigations and extractions of minerals, except for common minerals. Risks are high and approval by MOEP is required. A Category I EIA/OVOS is categorically required obligatory for large scale including road construction project with four lanes or more. • Category II - Sanitary Class/Danger Category 3 plus extractions of ubiquitous minerals, forestry activities and special uses of water. Risks are ranked as Medium High and approval is required from TEPO(s). • Category III - Sanitary Class/Danger Category 4 Risks are ranked as Low and approval is required from TEPO(s). • Category IV - Sanitary Class/Danger Category 5 plus projects involving animals, except recreational fishing and hunting. Risks are ranked as Low and approval is required from local administrations.
SEE reviews are conducted at end of each stage in the process and before proceeding to the next stage. Reviews are conducted first at the Oblast level and then by MEWR and other agencies as appropriate to the nature of the Project and the level of EIA Categorization. Under Kazakhstan regulations, the EIA process has three stages:
• Preliminary EIA (Environmental Impact Assessment - Pre-OVOS)
• Preparation of the EIA (OVOS). EIAs are obligatory for large scale projects.
• Preparation of an "Environmental Protection Section". The Environmental Protection Section is prepared in the detailed design stage in the event that mitigation measures defined in the EIA (OVOS) are required.
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At each stage of the EIA process, the developer is required to prepare an "Environmental Impact Statement", which is a compulsory annex to each EIA document. The "Environmental Impact Statement" must be presented in the package of documents for submission to the SEE for consideration. Reviews are conducted at the end of each stage, first at the Oblast level and the by MEWR and other agencies as appropriate for the project and EIA Category.
Public hearings or public consultations are required at all stages of EIA. The detailed requirements for public participation are reflected in the Environmental Code, Articles 57 and 60-67 and the “Rules of access to environmental information relate dot EIA procedure and decision-making process on intended economic and other activity”. Minutes from these hearings are filed as part of the EIA documentation.
The process provides for a preliminary review period of two weeks and a final review period of up to 90 days after which the EIA authors are required to defend the EIA at a consultation session with all stakeholders in attendance (usually not the general public). Once complete, the EIA is revised; a final document is prepared; and a formal OVOS certificate is issued to the Proponent, but usually only after another 30-day waiting period, allowing for any additional comments. This certificate allows the project to proceed with other approvals that may be required. Based on this information, it may take up to a year to complete the EIA process in Kazakhstan.
Based on additional guidance provided in the RoK EIA regulations, it is likely that wind projects (and in fact, all RES projects) would be considered Category II and would require Category II EIA/OVOS documentation. However, the siting of wind facilities within or near sensitive/protected areas may result in these being classified as Category I projects. This determination is made by MoE at the preliminary EIA stage.
The OVOS process was evaluated against the EBRD Environmental and Performance Standards to identify gaps areas that may be not be satisfied by the OVOS process. This gap analysis is provided in Appendix A.
5.3 KAZREFF APPRAISAL PROCESS
All projects considered for financing through KazREFF will under a detailed appraisal process in order to:
• Determine each project’s ability to meet EBRD environmental and social performance requirements; • Determine each project’s ability to meet EBRD RoK EIA regulations • Ensure that projects are technically feasible (part of the technical due diligence)
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• Identify significant issues and constraints that may negatively impact KazREFF’s ability to finance each project from an environmental and social perspective • Provide simplified guidance and resources to project proponents (and their environmental consultants) in order to more easily comply with EBRD and Kazakh requirements
The appraisal process will be developed and implemented by the Project Implementation Unit.
5.3.1 INITIAL SCREENING
The appraisal process includes an initial screening of the project proposal against the criteria presented in this RPER, the SER report, and consideration of key environmental and social issues. This initial screening is conducted after the project proponent completes the Environmental and Social Issues Checklist – Wind provided in Appendix B. This checklist includes identification of key environmental and social issues related to wind (and cumulative impacts) and is reviewed by KazREFF’s environmental and social review team. Based on the review of the checklist, the project’s EBRD category will be determined and specific documentation requirements will be communicated to the project proponent.
Once the EBRD requirements have been identified, KazREFF environmental and social review team will provide support to project proponents to comply with the Kazakh EIA regulations. In general, information gathered through the initial screening process can be useful in developing the preliminary EIS documentation required for the initial stage of the Kazakhstan EIA.
5.3.2 DOCUMENTATION REVIEW AND APPROVAL/FEEDBACK
Based on the initial screening and categorisation, the project proponent will then be expected to complete the preparation of required documentation.
Templates for the typical documents expected to support wind projects (under Category B) are provided in Appendix C and include templates for the NTS (Appendix C.1), the SEP (Appendix C.2), and the ESAP (Appendix C.3). If a project is determined to be a Category A project, an ESIA would be required. Due to the very specialized nature of an ESIA, an ESIA template has not been provided. However, information in the SER report will be extremely useful to identify information necessary for the preparation of these documents. The information in the SER identifying the environmental baseline, the anticipated effects, and mitigation strategies should also be very useful to inform the Kazakh EIA.
All projects will be expected to comply with EBRD PR1 through 10. Important information for assessing the significant environmental and social
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effects and avoidance, minimization, and/or mitigation of those effects is provided in the SER.
The required documents will be submitted to, and reviewed by, KazREFF environmental and social review team. The KazREFF environmental and social review team will work with the developer to ensure submitted information is sufficient to demonstrate compliance with EBRD’s PRs.
In addition, KazREFF environmental and social review team will review the progress of the Kazakh EIA and can, if requested, provide technical input and guidance on the process and content. KazREFF environmental and social review team will request updates from the project proponent on the progress of the project through the Kazakh EIA stages until final approval is received.
Once the required environmental and social documentation for KazREFF review has been found to be in compliance with the EBRD and the final Kazakh EIA is approved, KazREFF environmental and social review team will reflect that in the Project Screening Report.
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6.0 APPENDICES
A – Gaps between EBRD PR for ESIA and Kazakhstan EIA Requirements
B – Environmental and Social Issues Checklist - Wind
C – Environmental and Social Templates
C.1 – Non-Technical Summary (NTS)
C.2 – Stakeholder Engagement Plan (SEP)
C.3 – Environmental and Social Action Plan (ESAP) – Wind
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Kazakhstan Renewable Energy Financing Facility (KazREFF) - Strategic Environmental Review
Appendix A – Gaps between EBRD PR for ESIA and Kazakhstan EIA requirements
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Appendix A: Gaps between EBRD PR for ESIA and Kazakhstan EIA requirements
EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement PR 1: Environmental and All EBRD-financed projects undergo The EIA is obligatory for all sectors of None Social Appraisal and environmental and social appraisal economic and other activities that may Management directly or indirectly impact the environment and public health.
The EIA process is performed on the strength of commitment, integration (magnitude), alternative, adequacy, preservation, compatibility, flexibility, and public participation.
Categorization and EIA magnitude Economic activities subjected to the EIA None procedure are categorized as I, II, III, and IV, The EBRD categorizes proposed projects as “A”, of which categories I and II cause major “B”, and “C”. impacts on the environment. A project is classified as Category A when it could result in potentially significant and diverse According to the requirements, there is the adverse future environmental and/or social list of projects (economic activities) for impacts and issues which, at the time of which the EIA is recommended to be categorization, cannot readily be identified or performed in full (for example, oil industry assessed and which require a formalized and and crude oil refineries, thermal power participatory assessment process carried out by stations, chemical installations, pipelines independent third party specialists in accordance for transport of gas, oil or chemicals, etc.) with the PRs (Appendix 1 to the EBRD ESP). and the list of projects (economic activities) for which the requirements to carry out a A proposed project is classified as Category B comprehensive assessment are imposed by when the potential adverse environmental and / State review authorities on the basis of a or social impacts that it may give rise to are preliminary review or by applying
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement typically site-specific, and/or readily identified thresholds defined by regulations and addressed through mitigation measures. (agriculture, forestry, mining industry, These impacts could be from past, current or power industry, wind farms, etc.). future activities. Due diligence requirements may vary depending on the project and will be agreed with the EBRD on a case-by-case basis, in accordance with PR 1.
A proposed project is classified as Category C when it is likely to result in minimal or no adverse environmental or social impacts and therefore requires no further environmental and social appraisal beyond categorization.
Based on the KazREFF SER, it is anticipated that most funded projects will fall within Categories B or C. EIA stages The EIA process comprises the following None stages: 1) preliminary EIA (stage 1); 2) EIA that is performed for a complete and comprehensive analysis of potential effects of the project or further economic and other activities, substantiation of alternatives, and development of an environmental management plan (programme) (stage 2); 3) “Environmental Protection” section that constitutes part of the design documentation and contains engineering solutions aimed at prevention of adverse
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement impacts on the environment (stage 3).
The EIA format, completeness of studies, scope of used documents, levels and degree of detail of environmental scientific & design surveys depend on the design stage as well as on magnitude and intensity of impacts caused by projected economic and other activities on human health and environment.
EIA is an integral part of pre-design and design documents. Preliminary environmental and social assessment Through Pre-EIA activities, the potential None (Pre EIA) trends of changes in environmental and socioeconomic components as well as Through appraisal activities, the client will impacts on both the society and consider in an integrated manner the potential environment are identified. environmental and social issues and impacts associated with the proposed project. The No need in computations of the pollution appraisal process will be based on recent level for certain environmental information, including an accurate description components (air, soils, water, subsoil and delineation of the client’s business or the resources). project, and social and environmental baseline data at an appropriate level of detail. The Pre-EIA documents are disclosed for public appraisal should also identify applicable laws and by a project initiator. regulations of the jurisdictions in which the project operates that pertain to environmental Pre-design appraisal documents (business- and social matters, including those laws plans, feasibility studies) and main pre- implementing host country obligations under design documents such as “Investment international law (for example, commitments substantiation” and Pre-EIA documents are
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement related to land use planning and protected area submitted to the State Environmental management). Review (SER).
A positive Conclusion issued by the SER in favour of the project initiator, serves as a guide for making decisions to initiate designing of specific facilities and structures in accordance with the most rational option selected in the course of Pre-EIA development. Environmental and Environmental and social impacts and issues will The EIA process comprises an assessment None social appraisal (EIA) be appraised in the context of the project’s area of impacts on: mechanism of influence. Environmental and social issues and impacts will also be analysed for the relevant • atmospheric air stages of the project cycle. These may include • water resources; preconstruction, construction, operations, and • subsoil resources; decommissioning or closure and reinstatement. • industrial and domestic waste; Where relevant, the appraisal will also consider • physical impacts; the role and capacity of third parties, such as • lands and soils; local and national governments, contractors and • flora; suppliers, to the extent that they may influence • fauna; the project, recognizing that the client’s ability to • socioeconomic environment; address these risks and impacts will depend on its • environmental risks from planned control and influence over the third party actions. activities in the region The appraisal will also consider potential trans-
boundary and global issues, such as impacts from A project initiator discloses EIA documents effluents and emissions, increased use or for the public. contamination of international waterways, greenhouse gas emissions, climate change mitigation and adaptation issues, and impacts on endangered species and habitats.
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement
PR 2: Labour and At a minimum, the client’s human resources Labor relationship in the Republic of Labor relationship issues Working Conditions policies, procedures and standards shall be Kazakhstan is regulated by the Labor Code are not reflected in typical designed to: establish and maintain a sound and it does not constitute part of the EIA Kazakh EIA documents. This worker-management relationship; promote the process. would be a gap if not fair treatment, non-discrimination and equal addressed in a project- opportunity of workers; promote compliance Issues related to labor and working specific ESMP. with any collective agreements to which the conditions and safety are considered in the client is a party, national labour and employment “Environmental risk assessment in laws, and the fundamental principles and key connection with planned activities in the regulatory standards embodied in the ILO region” section. conventions that are central to this relationship; protect and promote the health of workers, especially by promoting safe and healthy working conditions.
PR 3: Pollution The client will avoid the release of pollutants or, Measures aimed at prevention and None Prevention and when avoidance is not feasible, minimize or abatement of environmental pollution are Abatement control their release. This applies to the release specified in EIA documents (“Atmospheric of pollutants due to routine, non-routine or Air”, “Water Resources”, and “Waste” accidental circumstances with the potential for sections). These measures provides for local, regional, or trans-boundary impacts. In introduction of low-waste and waste-free addition, the client should examine and technologies and special measures on i) incorporate in its operations energy efficiency prevention (abatement) of air emissions; ii) measures and measures to conserve water and adverse impact mitigation; iii) air quality other resources, consistent with the principles of monitoring; iv) amounts and chemical cleaner production. The client will avoid or composition of wastewater discharges; v) minimize the generation of hazardous and non- substantiation of the introduction of water hazardous waste materials and reduce its circulating systems and wastewater reuse harmfulness as far as practicable. systems, recycling of sludge from wastewater treatment facilities; vi)
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement groundwater protection against pollution and depletion; and vii) recommendations related to recycling, treatment and disposal of all types of waste and waste recycling/waste disposal technologies. PR 4: Community Health Requirements relating to: infrastructure and EIA documents comprise a section titled None & Safety and Security equipment safety; hazardous materials safety; “Assessment of environmental risks for the community exposure to disease; emergency environment and community health in preparedness and response; and security connection with planned economic personnel requirements. These requirements are activities”. This section contains i) focused on avoidance or prevention of risks and recommendations on prevention of and impacts rather than their minimization and response to emergencies; ii) consideration mitigation. of emergency probability; sources and kinds of emergencies and frequency of their occurrence as well as forecasts of their impacts on the environment and community. PR 5: Land Acquisition, The following requirements are considered in the Issues related to land acquisition and Kazakhstan EIA regulations Involuntary course of project design: carrying out of involuntary resettlement are regulated by do not contain Resettlement and consultations; grievance mechanism; the Land Code of the Republic of requirements related to Economic Displacement resettlement planning and implementation; Kazakhstan. But the Pre-EIA documents to land acquisition, Resettlement Action Plan; livelihood restoration be submitted to the SER for reviewing involuntary resettlement framework; compensation and benefits for should contain a copy of document for the and economic displaced persons; displacement; physical right of land use in the subject territory. displacement. displacement; economic displacement; and loss of public amenities. PR 6: Biodiversity Through the environmental and social appraisal The EIA process also includes an None Conservation and process, the client will identify and characterize assessment of impacts on vegetation in the Sustainable Resource the potential impacts on biodiversity likely to be project influence area (the presence of Management caused by the project. The extent of due diligence medicinal herbs; rare, endemic and Red should be sufficient to fully characterize the risks Data Book-listed plat species), green space
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement and impacts, consistent with a precautionary condition; forecasted changes of the approach and reflecting the concerns of relevant vegetation cover in the project stakeholders. The client will seek to avoid implementation area and impacts of these adverse impacts on biodiversity. changes on life and health of local communities; recommendations for conservation of vegetation communities, improvement of their condition, flora conservation and revegetation; recommendation for vegetation monitoring, etc.
Furthermore, the EIA documents contain a baseline assessment of aquatic and terrestrial fauna (the presence of rare, endangered and Red Data Book-listed fauna species); measure to conserve and reproduce the integrity of natural communities and species diversity of aquatic and terrestrial fauna; food potential improvement; a wildlife monitoring programme. In addition, the presence of natural territories and landmarks under special protection in the territory of potential construction operations is considered. PR 7: Indigenous In projects where Indigenous Peoples are likely to The Kazakhstan legislation does not specify The Kazakhstan EIA Peoples be affected, the client is required to carry out an requirements related to Indigenous procedure does not assessment of impacts on Indigenous Peoples. Peoples consider issues related to Depending upon the outcome of this, the client is Indigenous People. expected to first avoid adverse effects and where However, this is not this is not feasible, to prepare and Indigenous typically an issue in
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement Peoples’ Development Plan so as to minimize Kazakhstan, where there is and/or mitigate any potential adverse impacts. no indigenous population. The client is also expected to implement a specific grievance mechanism and determine appropriate modalities for compensation and benefit-sharing.
PR 8: Cultural Heritage At an early stage of the environmental and social EIA documents contain a section devoted None appraisal, the client should identify if any cultural to territories, landmarks and sites under heritage is likely to be adversely affected by the special protection. Cultural heritage is project, and assess the likelihood of any chance regulated by the RK Law “On Protection finds. The client will ensure that provisions for and Use of Historical and Cultural Heritage managing chance finds, defined as physical Sites and Objects” dated July 2, 1992. cultural heritage encountered unexpectedly Companies, institutions, organizations, during project implementation, are in place. Such educational institutions, public provisions shall include notification of relevant organizations and individuals will support competent bodies of found objects or sites; an authorized relevant body in alerting project personnel to the possibility of implementation of measures aimed at chance finds being discovered; and fencing-off protection, preservation and use of the area of finds to avoid any further disturbance historical and cultural heritage sites. or destruction.
PR 9: Financial Not applicable Not applicable Not applicable Intermediaries (FI)
PR 10: Information “Information Disclosure and Stakeholder Public opinion is given proper weight in the Kazakhstan requirements Disclosure and Engagement” specifies requirements relating to process of EIA development. Public opinion do not specify a detailed Stakeholder stakeholder identification, development of a consideration format depends on the procedure for stakeholders Engagement Stakeholder Engagement Plan, information significance of planned economic activities identification and disclosure, meaningful consultations, and and the extent of project influence on the engagement or the grievance mechanism. environment and community health; much grievance mechanism
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement depends on stakeholders. The procedure procedure. and dates of public consultations is regulated by environmental supervisory authorities.
Public opinion is mainly considered through public consultations. The results of public consultations are recorded in the form of a report where all key issues and disagreements between stakeholders and a client are recorded. Stakeholders’ comments and proposals are considered in design documents. Written proposals and comments from stakeholders (as an independent form of public opinion consideration) are collected for individual less significant projects of economic activities. At subsequent stages of project design, the procedure of public opinion consideration can be carried out through collection of written proposals and comments in respect of EIA findings for a certain industrial operation.
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Kazakhstan Renewable Energy Financing Facility (KazREFF) - Strategic Environmental Review
Appendix B – Environmental and Social Issues Checklist - Wind
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Please read this before completing the questionnaire: 1. This questionnaire is the first stage in the Bank’s environmental and social due diligence process. The more comprehensive the answers given, the less need will there be for the Bank to request further information. Please, therefore, try to answer the questions as fully and openly as possible. 2. The questionnaire makes reference to both “the Project”, the business activity for which EBRD funding is sought, and “the Company”, which is the corporate entity that is ultimately responsible for the Project. The Project may affect the whole Company or may only relate to one element within the Company. The Bank needs to understand both issues related to the Project being financed by the Bank and the impacts and issues associated with the Company as a whole. 3. There are a number of questions where further information is requested if a positive response is given. Additional information can be provided either in the questionnaire’s boxes or in separate documents.
PROJECT NAME: PROJECT LOCATION: Map Provided? Yes / No Company Name: Company Address: Country: Town/Location: Business Sector/Activities: Person completing questionnaire:
Name: Title: Date: Telephone: Mobile: E-mail:
Company authorised representative (e.g. Environmental Manager): I certify that, to the best of my knowledge and belief, the information contained in this questionnaire accurately represents current or future operations.
Signature:
Title: Date:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE COMPANY PROFILE
A) Ownership: • Private ownership %: ______• Public ownership %: ______B) Year of foundation: ______
C) Sector of operation and main products: ______D) Describe the main activities of the Company and its holdings including any on-shore wind or other renewable energy projects (include a description of the corporate structures and controls that are used to manage/oversee individual projects, including this one):
PROJECT DESCRIPTION
A) Technical information: Start of construction (planned date) Start of operation (planned date) Installed capacity (MW) Annual net generation (MWh) Type of turbines / towers (height, turbine diameter, maximum and minimum rotation speeds, etc) Are data on wind resource available (yes/no) Wind resource measuring period (start date / end date) Mean wind power density at 80 metres (W/m2) Distance to interconnection grid (km): Voltage level of interconnection grid (kV): Voltage level of overhead line to interconnection point (kV): Is operation constrained by seasonal migratory bird routes? (yes/no)
B) Status of project development: yes no
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE The project is still in its conceptual phase (we have only a project idea)? Technical design has started? Technical design is completed? Quotations / proposals from equipment suppliers have been received?
C) Summary of information on Environmental Impact Assessment: Is Environmental Impact Assessment (EIA) required? (yes/no) Has EIA been completed? (yes/no) If EIA is available, has it observed any adverse environmental impacts? If yes, describe them and any associated mitigation measures in Section 1b. If EIA is required but not available, when will it be completed?
D) Siting, design and key environmental and social considerations:
1. Describe the Project and provide a map showing its components, including the turbine infrastructure, generating units and control-centre (and approximate layout), roads, transmission lines, grid connections and other required facilities (such as sub-stations). 2. How were environmental and social issues incorporated into the siting and design optimisation process (see also questions under PR1 and PR6 below)? 2.1 What studies have been completed relating to potential impacts on avian populations and migratory passage? 2.2 What measures have been incorporated into the design and operation-plans to minimise risks to birds? 3. Wind resource issues – please describe: 3.1 Understanding of the operational regime for each facility and for operations in tandem; 3.2 Wind resource measurements and other meteorological data and monitoring information; 4. How have climate-change related variables been accommodated? PR1 - Environmental and Social Appraisal & Management Environmental and Social Appraisal 1.a Has the Company made an assessment of the Yes: No: environmental and social impacts of its operations? If yes, please provide a summary of that assessment:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE 1.b Has an Environmental and Social Impact Assessment Yes: No: (ESIA) been completed for this Project? If yes, please summarise the conclusions of the ESIA, including required/recommended mitigation, and send a copy/summary: 1.c Have relevant discussions been held with Yes: No: environmental regulators on the ESIA for the Project? If yes, please summarise: 1.d Is there an Environmental and Social Action Plan (ESAP) Yes: No: for the Project construction, operation and If yes, please summarise: decommissioning? 1.e Have any site investigations been performed to check Yes: No: the suitability of the site and characterise If yes, please provide a list of the studies: environmental and social baseline conditions, such as soil, water quality and groundwater testing, slope stability, survey for flora and fauna including bat, bird and water species, or the situation of nearby communities? 1.f What are the relevant Company’s Corporate Social Responsibility Standards? 1.g What processes are in place to manage environmental issues (such as the presence of sensitive species)? 1.h Will / does the Project involve significant excavations, Yes: No: demolitions, movement of earth, flooding or other If yes, please provide details: changes in the physical environment? 1.i What soil erosion/sedimentation mitigation/control procedures will be in place for the construction and operational phases of the Project? Environmental Management 1.j Who is responsible for environmental management at Name/title:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE the Company? Phone/mobile: Email: Who is responsible for social management / community Name/title: relations at the Company? Phone/mobile: Email: Who is, or will be, responsible for environmental Name/title: management for the Project? Will that person be on- Phone/mobile: site during construction and operation? Email: Who is, or will be, responsible for social management / Name/title: community relations for the Project? Will that person Phone/mobile: be on-site during construction and operation? Email: 1.k Does the Company have an Environmental and Social Yes: No: Management System (ESMS)? If yes, is the ESMS compliant with any internationally Yes: No: recognised systems such as ISO 14,001, OHSAS 18,001, SA 8000 or EMAS? 1.l Does the Company periodically prepare a summary Yes: No: report on environmental performance (or If yes, please provide a copy of the most recent report(s) sustainability) for shareholders, stakeholders, or others? How often? 1.m Does the Company routinely provide environmental Yes: No: training for Company personnel? If yes, please describe the training provided: Will the Company train workers for the Project? For Yes: No: construction and/or operation? If yes, which workers will be trained? What kind of training? Contractor management 1.n Will the Company use contractors during the Yes No
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE construction and/or operational phases of the Project? If yes, please provide details: 1.o Are prospective contractors required to submit Yes No environmental, health and safety, and/or labour information with bid documents (that is, do solicitations for proposals require such information)? 1.p Is a contractor’s past EHS performance considered Yes No during evaluation of bids? If yes, please describe how (including whether it is used as a pass/fail factor or as part of the overall score: 1.q Does the Company monitor performance of its Yes: No: contractors regarding environmental, health and safety, If yes, how often? How does the Company deal with poor and labour/human resources? performance? 1.r How will the contractors be managed to ensure they have processes in place to anticipate and respond to emerging risks and opportunities, associated with the Project? PR 2 – Labour and Working Conditions 2.a Who is responsible for Human Resources (HR) Name/title management at the Company? Phone/mobile: Email: 2.b Does the Company have written HR policies setting out Yes: No: its approach to managing its workforce? 2.c Are all workers provided with written information Yes: No: about their terms and conditions of employment? 2.d Has the Company ever been found in violation of any Yes: No: country’s labour and/or social security laws? If yes, please describe the circumstances Have these resulted in any penalties, fines, major Yes: No: recommendations or corrective action plans? If yes, please describe:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE 2.e Are employees free to form, or join, a workers’ Yes: No: organisation (e.g. a trade union) of their choosing? What percentage of the workforce belongs to such an organisation? 2.f Is the Company covered by a collective bargaining Yes: No: agreement? 2.g How does the Company interact with workers’ organisations and provide information to them? 2.h Does the Company have a grievance mechanism which Yes: No: allows employees to raise workplace concerns? If yes, please describe: How many grievances were received from employees Number: during the previous year? Please summarise the issues raised in grievances and how the company has addressed them: 2.i Have there been any strikes or other collective disputes Yes: No: related to labour and working conditions at the If yes, please describe the nature of the dispute and how it was Company in the past three years? resolved: Have there been any court cases related to labour Yes: No: issues? If yes, please summarise contested issues and outcome: Have there been any other significant labour issues Yes: No: raised by the media or by non-governmental organisations? If yes, please describe: 2.j Are there policies or terms and conditions covering Yes: No: employment of young persons under age 18? If yes, please describe What is the minimum legal working age? How does the Company verify the age of employees? Does the Company apply any restrictions to the tasks Yes: No:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE that can be done by younger workers? If yes, please describe: 2.k Are employees free to leave the premises when they Yes: No: are not required to work or with appropriate due cause? Does the Company retain any identity documentation Yes: No: from the employees? If yes, please explain which documents and why: Are employees free to resign from their jobs? Yes: No: If yes, please describe the notice and other procedural requirements? 2.l Does the Company have a policy for setting wages? Yes: No: How do the Company’s wage levels compare to comparable employers in your sector? 2.m Does the Company anticipate any redundancies or Yes: No: retrenchment in the next three years? If yes, please describe and explain the reason(s): 2.n Does the Company have policies or terms and Yes: No: conditions covering non-discrimination and equal If yes, please describe: opportunities in employment? 2.o Are any criteria other than compliance with job Yes: No: requirements (e.g., gender, ethnicity, nationality, If yes, please specify those criteria: religion, political or trade union affiliation) applied for recruitment / promotion / access to training / benefits? 2.p How many workers does the Company employ? Please provide numbers for men and women separately. How many are...: Direct: Seasonal: Full-time: Part-time: How many sub-contractors does the Company employ and what is the role of these sub-contractors? 2.q Will there be employment opportunities for local Yes: No:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE stakeholders? If yes, please describe these opportunities: How many non-skilled workers will be employed for the Construction: Operation: Project during construction and then operation? How many non-skilled workers are expected to be Near-by areas: Within the Country: recruited from nearby areas? From the country? What proportion of managers and skilled workers are Near-by areas: Within the Country: expected to be recruited from nearby areas? From the country? Occupational Health and Safety 2.r Who is responsible for health & safety management at Name/title: the Company and/or Project? Phone/mobile: Email: Is there an emergency response plan for dealing with Yes: No: natural disasters, such as earthquakes? (This is also relevant to PR-4 Community Health, Safety and If yes, please describe and provide a copy: Security) Is there sufficient information to confirm that Yes: No: construction will not result in land slips or other environmentally damaging incidents? (This is also If yes, please describe: relevant to PR-4 Community Health, Safety and Security) 2.s Does the Company have a Health & Safety Yes: No: Management System? Is the system compliant with an international health & Yes: No: safety standard such as OHSAS18001? 2.t Is the Company compliant with national requirements Yes: No: for health & safety? 2.u Is there a current Health & Safety Action Plan for the Yes: No:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE Company? If yes, please provide a copy of the latest update. Do project-specific health and safety plans (typically) go Yes: No: beyond the requirements of host countries? If yes, please summarise (typical) differences: 2.v Does the Company keep any statistics on Yes: No: • Fatalities; If yes, please provide health and safety statistics for the last three • Lost time accidents; years of operations. • Lost workdays resulting from incidents; and/or • Total staff hours worked? 2.w Have any Company operations been cited for violations Yes: No: of national or other health and safety standards and If yes, please summarise the circumstances and the outcome procedures in the last 3 years? 2.x Is there (or will there be) a Health and Safety Plan for Yes: No: this Project? If yes, please describe what it covers (or will cover)?
Will workers be required to undergo health and safety Yes: No: training? If yes, please indicate how often and what type(s) of training 2.y How does the Company ensure that workers employed by its contractors, sub-contractors or labour agents are protected by the same labour and health and safety standards as those that apply to the Company’s own employees? PR 3 – Pollution Prevention and Abatement Environmental Compliance 3.a In the last 3 years, has the Company been cited for any Yes: No: violations of environmental permits or regulations? If yes, please describe circumstances and outcomes: 3.b Has the Company applied for, and/or received, the Yes: No: required environmental permits and licences to Please list required permits and licenses, and their status (issued, construct the Project? To operate? applied for, etc.)
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE Construction: Operation: 3.c Which agencies and authorities will be primarily responsible for overseeing environmental performance of the Project? Air Emissions 3.d Does the Company produce air emissions? Yes: No: If yes, please describe the main sources, types and quantities of air emissions produced by the company: 3.e Please describe any measures taken to reduce emissions and prevent air pollution. 3.f Please provide monitoring data for total air emissions. Water Use 3.g What will be the main sources of water for the Project during construction and operation? How much water will the Company use at each phase of the Project? Have permits been issued? Yes: No: Will any water require treatment prior to use? Yes: No: If yes, please describe use, amount to be treated and treatment method: Wastewater Discharges 3.h What are the sources, types and quantities of effluent discharges that will produced by the Company during the Project? 3.i How much wastewater will be generated during Construction: Operation: construction and operation? How will wastewater be managed and discharged?
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE Is any wastewater treatment required prior to Yes: No: discharge? If yes, please describe: Solid Waste Management 3.j What are the types and quantities of solid wastes produced by the Company? How are these wastes disposed of? 3.k Are any hazardous wastes produced and how are these Yes: No: stored and disposed of? If yes, please describe: 3.l Does the Company implement any measures to reduce Yes: No: / reuse / recycle any solid wastes at its facilities? If yes, please summarise: Are contractors required to implement these Yes: No: measures? Hazardous Material Management 3.m What hazardous materials will used by the Company in the Project (such as flammable, explosive, reactive, radioactive and toxic substances) and in what quantities? What measures and procedures are in place for the handling and storage of such materials? 3.n Has the Company suffered any environmental incidents Yes: No: or accidents (such as spills, tank ruptures, explosions, If yes, please describe: etc.) during the previous three years at any of its facilities? 3.o Does the Company prepare Environmental Incident Yes: No: Reports, or similar, when an environmental accident or If yes, please describe the reporting system and indicate the relevant incident occurs? authorities you report to:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE 3.p Will fuel or other hazardous materials be stored and/or Yes No used for this Project? If yes, what materials will be used/stored? How much of each? How will they be used/stored? PR 4 - Community Health, Safety & Security 4.a How far are the nearest villages/towns/cities from the Please describe and include a map: Project site? How far from the Project site are the nearest occupied
houses and/or workplaces? 4.b Will the Company’s activities pose any material risks to, Yes: No: or have any significant impacts on, the health and If yes, please describe: safety of local communities or people? Yes: No: Has a public health assessment been undertaken? If yes, please describe:
4.c Has the Company developed measures to prevent Yes: No: and/or mitigate any such impacts? If yes, please describe:
4.d Has the Company consulted with locally affected Yes: No: community(ies) and stakeholders to discuss the Project If yes, please describe: and measures to be taken to reduce impacts, in order to understand any concerns and address issues associated with potential public health effects? How have impacts of the project on affected communities (if any) been identified and addressed? 4.e Will there be security guards to control entry to the Yes: No: Project site during construction and/or operation? If yes, will they be armed? How will they be trained?
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE Will security be outsourced to a separate company? Yes: No: If yes, what criteria did the Company use to select the security contractor? PR 5 - Land Acquisition, Involuntary Resettlement and Economic Displacement 5.a Does the Company have a person in charge of land Yes: No: acquisition and/or expropriation? Name: Title: Phone/mobile: Email: 5.b Have any structures or land already been acquired by Yes: No: the Company in connection to the Project? If yes, please provide details. 5.c How much land will need to be permanently acquired by the Company for the Project (including power- generating infrastructure, control centre, roads, transmission lines and other related facilities)? How much land will have to be temporarily occupied (e.g. for storage, access to construction sites, accommodation of workers)? 5.d Has the Company already identified owners and users Yes: No: of affected land and structures (for example, from Land If yes, please provide details: Books, Cadastre or through a field survey)? Have any negotiations with land/structure Yes: No: owners/users or any expropriation procedure been If yes, please provide details: initiated (including request for public interest)? What is the land currently being used for? Will land that is not needed by the Company continue Yes: No: to be used by others (such as land between buildings/generating infrastructure)?
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE 5.e Will any people need to be relocated to new houses, Yes: No: new farm land and/or lose access to other valuable If yes, please provide details. assets? 5.f Will the Company acquire land and/or pay for Yes: No: temporarily using it? If yes, how much land will be acquired and/or require payments for use? How will the amount to be paid for purchase or usage be determined? How will the Company proceed if agreement cannot be reached with owner(s)? Is there a written land acquisition plan for the Project? Yes: No: If yes, please provide details: 5.g Will any businesses / economic activities, both formal Yes: No: and informal, in the area be affected by construction If yes, please provide details: activities (e.g. tourism activities)? Does the Company have plans to compensate affected Yes: No: people for loss of business or economic activity? If yes, please provide details: 5.h Is there any resettlement required for this project? Yes No If yes, please provide details: If so, is there a Resettlement Action Plan? Yes No If yes, please provide details: PR 6 – Biodiversity Conservation & Sustainable Management of Living Resources 6.a How far is the Project from the nearest protected or Please provide a list with distances and provide a map showing the designated areas, or areas important for local Project and nearest protected/important areas. biodiversity, including Natura 2000 sites, national parks, Ramsar Sites (wetlands), etc.? 6.b Does the site provide habitat for any protected or Yes: No:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE sensitive species of plants or animals? If yes, please provide details: 6.c What habitat mapping or species surveys have been completed? 6.d Which habitat areas/species would be impacted by ancillary works, transmission lines, construction access roads, other construction activities etc? 6.e Is there any other baseline environmental data on Yes: No: wildlife of the area not already covered above or in the If yes, please provide further details: Project Description section? 6.f Is there any further information on potential impacts to Yes: No: species or habitats that have not been covered above If yes, please provide further details: or in the Project Description section? PR 7 – Indigenous Peoples Are there any indigenous peoples likely to be impacted by the project? Yes: No: If yes, please provide details: PR 8 – Cultural Heritage 8.a Is the Project located in or near a cultural heritage site Yes: No: recognised by the country in which the project is If yes, please provide details: located, or where artefacts have been found in the past (including UNESCO World Heritage Sites and those on the tentative list, Registered cultural heritage sites, zones and settlements)? 8.b Is the Project located on or near to a place of worship, Yes: No: cemetery or other place of importance and value to a If yes, please provide details: community? 8.c Has the Company consulted with the national, regional, Yes: No: and/or local agency(ies) responsible for protecting If yes, please provide details: cultural resources? ERM 65 KasREFF SER RPER WIND – June 2014
ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE 8.d Has the risk to cultural heritage sites and areas of Yes: No: archaeological interest been assessed and managed? If yes, please describe: PR 9 – Financial Intermediaries Not relevant for KazREFF PR 10 – Information Disclosure & Stakeholder Engagement 10.a Who will be affected by the Project, including the workforce and local communities? How and to what extent? 10.b Does the Company have a person in charge of Yes: No: communications with local communities? Name: Title: Phone/mobile: Email: 10.c Has the Company established a mechanism through Yes: No: which members of the public can raise concerns or If yes, please provide details: grievances concerning the Company’s environmental and social practices? 10.d Has the Company established a regular means for Yes: No: communicating with affected community(ies)/people If yes, please describe: (e.g. newsletter, email, helpline, open day)? 10.e Is the Company aware of any issues, concerns or Yes: No: positive feedback brought to the Company’s attention If yes, please describe: by members of the community, non-governmental organisations (NGOs), or the media? 10.f Has the company undertaken any consultations with Yes: No: stakeholders – including national, regional, and local If yes, please describe: authorities, NGOs, businesses, citizens? 10.g Does the Company have plans to implement Yes: No: ERM 66 KasREFF SER RPER WIND – June 2014
ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE community development activities (e.g. is there a If yes, please describe: corporate social responsibility plan)?
(end of questionnaire)
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Kazakhstan Renewable Energy Financing Facility (KazREFF) - Strategic Environmental Review
Appendix C – Environmental and Social Templates
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Kazakhstan Renewable Energy Financing Facility (KazREFF)
TEMPLATE - PROJECT NAME
DATE
Non Technical Summary of Environmental and Social Considerations
P
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CONTENTS
1 Introduction 71 2 Description of the Proposed Development 72 3 Environmental, Health, Safety and Social Review 72
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7.0 Introduction
Add summary of company proposing development – i.e private / public owned, company structure and operations Add summary of project proposals – i.e type of power plant, size and location Add summary of environmental studies undertaken to date – i.e an ESIA?, specialist surveys? (Company name XXX) has approached the European Bank for Reconstruction and Development (EBRD) for financing. The project is thus subject to EBRD’s 2008 Environmental and Social Policy and has been determined as a Category XXX project (add details of whether it is a category A or B project). EBRD has conducted an environmental and social due diligence assessment of the project and supported the development of applicable environmental and social documentation, namely a Stakeholder Engagement Plan, an Environmental and Social Action Plan, and this Non Technical Summary (also add reference to other relevant documents if appropriate eg an ESIA, specialist studies). This document provides in a non-technical manner an overview of the proposed development plans. The document also provides a summary of potential environmental and social impacts and other environmental and social issues relevant to the proposed activities. Appropriate measures to mitigate key adverse environmental and social effects that may arise during project construction and operation are also provided. This NTS document and other materials will be placed in the locations shown below on (add disclosure date XXX). During a 60 / 120 (delete as appropriate) -day period beginning on (add disclosure date XXX), anyone can provide comments and recommendations on the environmental, social and other aspects of the project. Comments can be made at public consultations to be held at the locations shown below, and may be submitted to the address below. Environmental and social documents will be available for review during normal business hours at the following location: XXXX (add details)
Meetings at which anyone can make comments will be held as follows: XXXX (add details) The dates and times of public meetings will be announced at least three weeks before the meeting(s), and advertised in local mass media. For further information on this project, or to provide comments on the project or the environmental and social documentation, please contact: Comments may be submitted to: Name Contact information Address: Complete all contact Phone: details Email:
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8.0 Description of the Proposed Development
Add project description – • prospective annual electricity generation, • equipment to be installed, • permitting requirements, • Location, size, (including location map(s)
9.0 Environmental, Health, Safety and Social Review
Key Environmental and Social Elements Several documents collectively make up the environmental and social documentation for the project. The Non Technical Summary is described above, while the other documents are described here. Environmental and Social Action Plan (ESAP) As part of the environmental and social due diligence evaluation, a wide review was conducted of corporate environmental, health, safety and social management arrangements. From the overall review, an Environmental and Social Action Plan (ESAP) has been developed which lists key actions to ensure areas for improvement can be implemented and include mitigation measures discussed above. This ESAP is being disclosed for public comment; key mitigation measures are described below. Stakeholder Engagement Plan (SEP) (Insert company name XXX) has prepared a Stakeholder Engagement Plan (SEP) for the Project. The SEP will guide (insert company name XXX) in communicating with people, institutions and any other stakeholders who may be affected by or interested in the implementation of Project. (Insert company name XXX) has assigned a social liaison officer, who will be responsible for keeping open dialogue with stakeholders groups and local public. This SEP is being disclosed for public comment. At any time before and during construction and operation, any stakeholder will have a chance to raise any concerns, provide comments and feedback about the Project. All such comments and grievances from people will be accepted, processed and answered by (insert company name XXX) in a timely manner.
Key Features Key environmental features and sensitive locations from a social perspective in relation to the site include:
XXX – add details
Potential Impacts and Mitigation Measures ERM 72 KasREFF SER RPER WIND – June 2014
The EBRD’s environmental and social diligence evaluation determined that the project could have negative impacts on environmental resources and on people if they are not controlled carefully. Therefore, the EBRD will require (insert company name XXX) to implement many actions (“mitigation measures”) to prevent, reduce, or mitigate impacts on people and the environment. A summary of key impacts and mitigation measures have been identified, and they are summarised in Appendix A.
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Overview of Potential Impacts and Mitigation
Resource Potential Impact / Issue of Concern Mitigation
For example … Climate and Air Quality
Geology, Geohazards and Soils
Surface Water & Groundwater
Water Supply
Ecosystems and Flora & Fauna Noise
Waste Management
Cultural Heritage Tourism
Visual Landscape
Socio-economics
Traffic Management
Occupational Health & Safety Public Health & Safety
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Others…
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Kazakhstan Renewable Energy Financing Facility (KazREFF)
TEMPLATE - PROJECT NAME
DATE
Stakeholder Engagement Plan
Prepared for:
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CONTENTS 1 Introduction 78 1.1 Background 78 1.2 Description of the Proposed Development 78 1.3 Overview of XXX (add company name) 78 1.4 Objectives of the Stakeholder Engagement Plan (SEP) 78 1.5 Structure of SEP 79 2 Regulatory Context 80 2.1 Kazakhstan requirements for stakeholder engagement/ public consultation 80 2.2 EBRD requirements for stakeholder engagement and public consultation 80 3 Summary of previous stakeholder engagement 82 3.1 EBRD previous stakeholder engagement and consultations in Kazakhstan 82 3.2 KazREFF SER Consultations 82 3.3 Public disclosure and consultations during project 83 3.4 Other consultations during the project 83 4 Stakeholder Identification and Communication Methods 84 5 Disclosure of Information and Stakeholder Engagement Programme 86 5.1 Disclosure of general information 86 5.2 Disclosure of information relevant to Project 86 5.3 Stakeholder engagement programme 86 6 Timetable 87 7 Public Grievance Mechanism 88 8 Roles and Responsibilities 89
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10.0 Introduction
10.1 BACKGROUND Add summary of company proposing development – i.e private / public owned, company structure and operations Add summary of project proposals – i.e type of power plant, size and location Add summary of environmental studies undertaken to date – i.e an ESIA?, specialist surveys? (Company name XXX) has approached the European Bank for Reconstruction and Development (EBRD) for financing. The project is thus subject to EBRD’s 2008 Environmental and Social Policy and has been determined as a Category XXX project (add details of whether it is a category A or B project). EBRD has conducted an environmental and social due diligence assessment of the project and supported the development of applicable environmental and social documentation, namely a Stakeholder Engagement Plan, an Environmental and Social Action Plan, and a Non Technical Summary of the environmental and social considerations (also add reference to other relevant documents if appropriate eg an ESIA, specialist studies). To meet EBRD requirements for stakeholder engagement and public consultation and disclosure (EBRD Performance Requirement PR10), a stakeholder and public engagement process with development of a Stakeholder Engagement Plan (SEP) will also be directly applied to this project. These details are laid out in this document, the SEP. EBRD considers stakeholder engagement as an essential part of good business practices and corporate citizenship, and a way of improving the quality of projects. In particular, effective community engagement is central to the successful management of risks and impacts on communities affected by projects, as well as to achieving enhanced community benefits.
10.2 DESCRIPTION OF THE PROPOSED DEVELOPMENT Add project description – • prospective annual electricity generation, • equipment to be installed, • permitting requirements, • Location, size, (including location map(s)
10.3 OVERVIEW OF XXX (ADD COMPANY NAME) Add summary of company proposing development – i.e private / public owned, company structure and operations
10.4 OBJECTIVES OF THE STAKEHOLDER ENGAGEMENT PLAN (SEP) This SEP has been developed with the aim of explaining how company name XXX will communicate with people and institutions who may be affected by or interested in the Project, at various stages of project preparation and implementation. The plan includes a
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grievance mechanism for stakeholders to raise any concerns related to the project for company name XXX attention. 10.5 STRUCTURE OF SEP The remainder of this SEP is organised as follows: • Chapter 2 briefly describes applicable regulations and requirements for stakeholder engagement and public consultations. • Chapter 3 summarises previous and on-going stakeholder engagement and public consultation activities. • Chapter 4 identifies stakeholders and describes communication methods with them. • Chapter 5 describes stakeholder engagement program and disclosure of information. • Chapter 6 describes roles and responsibilities for handling the consultation and information disclosure process. • Chapter 7 describes a grievance mechanism by which feedback, comments, concerns and complaints may be communicated to company name XXX and how these grievances and comments will be handled.
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11.0 Regulatory Context
11.1 KAZAKHSTAN REQUIREMENTS FOR STAKEHOLDER ENGAGEMENT/ PUBLIC CONSULTATION Kazakhstan is a signatory for Aarhus Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters (UNECE)11. The convention is designed to improve the way ordinary people engage with government and decision-makers on environmental matters. Consequently, citizens of Kazakhstan are entitled to be informed about all environment related issues pertaining to the project and it is the responsibility of public authorities, local authorities, or government departments to reveal such environmental information. National legislation also foresees broad public involvement in decision-making process. Further details to be added….
11.2 EBRD REQUIREMENTS FOR STAKEHOLDER ENGAGEMENT AND PUBLIC CONSULTATION Since EBRD may be involved in funding the Project, the Project must meet the best international practices and requirements for stakeholder engagement and public consultations as specified in the EBRD Environmental and Social Policy of 2008.
The principles, requirements, methodological and procedural aspects of stakeholder engagement for EBRD Category A and B projects are described in detail in PR10 “Information Disclosure and Stakeholder Engagement 12 . PR10 outlines a systematic approach to stakeholder engagement that will help clients build and maintain over time a constructive relationship with their stakeholders, including the locally affected communities.
As required, the following important stages shall be implemented for the Project engagement and consultation process: - Identification of project stakeholder groups. Identification of stakeholders, including members of the public who could be affected by the Project construction and operation. - Stakeholder engagement process and information disclosure. During this step, company name XXX is to ensure that identified stakeholders are appropriately engaged on environmental and social issues that could potentially affect them through a process of information disclosure and meaningful consultation. - Meaningful consultation. The consultation process will be based on the disclosure of information relevant to the Project activities and operations. The consultation process will be undertaken in a manner that is inclusive and culturally appropriate for all stakeholders, including effected communities and vulnerable groups.
11 UNECE Aarhus Convention on access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters
12 EBRD Environmental and Social Policy 2008 (http://www.ebrd.com/downloads/about/sustainability/2008policy.pdf)
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- Grievance mechanism. Maintaining a grievance process by which the general public and other stakeholders can raise concerns, and which will be handled in a prompt and consistent manner.
The stakeholder engagement process and SEP preparation was also guided by the IFC Good Practice Handbook13 that defines the best practice approach to stakeholder engagement.
13 http://www.ifc.org/ifcext/enviro.nsf/AttachmentsByTitle/p_StakeholderEngagement_Full/$FILE/IFC_StakeholderEngagement.pdf
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12.0 Summary of previous stakeholder engagement
12.1 EBRD PREVIOUS STAKEHOLDER ENGAGEMENT AND CONSULTATIONS IN KAZAKHSTAN The European Bank for Reconstruction and Development (”EBRD” or the “Bank”) has made RES a key priority for investment in its countries of operation and has reviewed a number of early stage RES projects in Kazakhstan. The Bank has gained initial approval from the Clean Technology Fund (CTF) for concessional finance of up to $110 million to help create markets for power from RES in Kazakhstan. The Bank is now in the process of establishing dedicated financing facilities to enable it to provide finance to both larger and smaller RES projects in Kazakhstan (up to €10 million per project). This will be supported by funds from the CTF. The Bank has been active since 2008 in assisting the Government of Kazakhstan (the “Government”) through a technical cooperation programme in supporting the preparation of legislation to support RES development which has involved extensive stakeholder dialogue with the Ministry of Industry and New Technologies (MINT). In 2012, during the early stages of renewable energy programme development for Kazakhstan, the EBRD launched the assignment Kazakhstan Renewable Energy Development Framework and Regulatory Support (TCS number 34068). This assignment was to provide technical assistance in renewable energy regulatory support and institution building to the Kazakhstan Ministry of Industry and New Technologies (MINT; subsequently renamed the Ministry of Environment and Water Resources, or MEWR). Included in that assignment was a Renewable Energy Market Study, which included extensive stakeholder dialogue to establish the appropriate structure for renewable energy regulation in Kazakhstan. A number of key stakeholders and interested parties were identified at that stage, including local authorities and regulators at different levels, potential donor agencies, scientific and research institutes, and private developers. All targeted groups were contacted, and a series of individual meetings and workshops were organized and undertaken.
12.2 KAZREFF SER CONSULTATIONS
The Kazakhstan Renewable Energy Financing (KazREFF) undertook a large stakeholder engagement exercise alongside the Strategic Environmental Review (SER) of the potential effects of implementing renewable energy projects funded under KazREFF. The SER consultations were undertaken in three stages:
• Stage 1 (between April and July 2013). In Stage 1, the information about the KazREFF SER and SER Scoping Report was disclosed to with 30 representatives of various stakeholder groups; 13 of whom were individually interviewed. Representative stakholders included representatives of local authorities, manufacturers, developers and consultants involved in the development and implementation of renewable energy projects in Kazakhstan. The initial list of stakeholders resulting from stakeholder identification and analysis was expanded and amended where necessary. • Stage 2 (between July 2013 and September 2013). In Stage 2, the SER Environmental Scoping Report was published on the KazREFF SER website at http://www.kazreff-
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ser.com. EBRD conducted half-day scoping meetings on 16 and 18 July 2013 in Astana and Almaty, respectively, to encourage broad stakeholder participation in the development of the SER. Outreach activities, including mailing, emailing and telephoning contacts, were undertaken with 86 organizations representing a variety of stakeholders in the Astana and Almaty areas including government, developers, non- governmental organizations (NGOs), consultants, and advisory bodies. Eighteen organizations representing a variety of stakeholders participated in the meetings. • Stage 3 (June 2014 through October 2014). In Stage 3, the Draft SER report was disclosed and initiated formal 120-day public consultation period, where all stakeholders had an opportunity to provide comment on the disclosed Draft SER report. During this timeframe, two workshops were held to both inform and educate stakeholders about the SER and the KazREFF.
12.3 PUBLIC DISCLOSURE AND CONSULTATIONS DURING PROJECT Add details of any public disclosure / consultation undertaken to date as part of this project.
12.4 OTHER CONSULTATIONS DURING THE PROJECT Add details of any other consultation that may have occurred as part of the project, for example with authorities to obtain necessary permits.
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13.0 Stakeholder Identification and Communication Methods
In order to define a communication process in line with EBRD PR10, company name XXX has identified several stakeholder groups that may be interested and/or affected by the Project development and implementation. The stakeholders identified include: • Internal stakeholders, such as company name XXX employees and construction contractors’ workers
• External stakeholders, such as o governmental authorities, o non-governmental organisations and o local residents.
Others who wish to be included in the list can contact company name XXX and be put on the mailing list for information on reporting, meetings, or other consultation opportunities.
Table 1 describes the stakeholder engagement programme and communication process by providing contact details of certain stakeholders, and identifying communication methods and specific media that will be used to notify stakeholders of information. Any suggestions for improvement of proposed communication methods or media are welcomed and can be submitted via the contact information at the end of this document.
Table 1. Stakeholder engagement programme for the Project Stakeholder group Description Communication method / Proposed Media channel and contact information (where applicable) Internal Stakeholders Employees XXX For example… Company website?? - Internal newsletters www.kazreff.com?? - Emails - Grievance procedure - Bulletin boards - Union meetings - Inserts with payslips Temporary Construction XXX For example… XXX Workers, subcontractors - Internal newsletters - Emails - Grievance procedure - Bulletin boards - Union meetings - Inserts with payslips Unions: XXX For example… XXX • XXX - Official correspondence.
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Table 1. Stakeholder engagement programme for the Project Stakeholder group Description Communication method / Proposed Media channel and contact information (where applicable) - Union newsletter. - Information on request to union representatives. External Stakeholders Population in XXX XXX XXX Newspapers: XXX Radio: XXX Company website?? www.kazreff.com?? Local authorities and public enterprises: For example… XXX For example… XXX Water Company - Communication via official letters and meetings Public Health Institute XXX For example… XXX - Ongoing working linkages with the Institute County / city XXX For example… XXX administration - Ongoing working linkages with the authorities - Official correspondence - Meetings State level authorities: - Ukrainian Water XXX For example… XXX Authority - Official correspondence - Ministries - Meetings • XXX
Other relevant external stakeholders For example… XXX - Meetings (invitation to public Company website?? Local Tourist Board consultation meetings) www.kazreff.com?? Others..
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14.0 Disclosure of Information and Stakeholder Engagement Programme
14.1 DISCLOSURE OF GENERAL INFORMATION Provide details of general information disclosure – website, company reports etc
14.2 DISCLOSURE OF INFORMATION RELEVANT TO PROJECT To meet the environmental and social requirements and performance standards of EBRD and EU, company name XXX will develop, disclose to the public and then implement an Environmental and Social Action Plan (ESAP), which will identify mitigation measures to minimise, reduce, eliminate or control potential adverse impacts on environment and people.
The final version of ESAP will be published on company name XXX official website (or KazREFF website?) and printed copies will be available on request from XXX (contact information available in the table above).
The local population will receive timely information (through the local media listed in the table above and announcements regarding grievance management in relation to construction activities, safety measures in the vicinity of the construction site, traffic management, employment opportunities and opportunities for service provision (catering, accommodation of workers, laundry services, etc.) and any other information identified through the development of the ESAP.
Annual project progress reports, including environmental and social impacts, health and safety performance and implementation of the external grievance mechanism will also be disclosed on company name XXX official website (or KazREFF website?) and will be available on request XXX (contact information available in the table above).
14.3 STAKEHOLDER ENGAGEMENT PROGRAMME Consultations and disclosure of information for local public
Public consultations will be held after a draft Environmental and Social Action Plan has been developed. Add details of proposed consultation. For example - who will manage it, when will it take place, and with whom?
Other stakeholder engagement activities Add details of proposed consultation. For example - who will manage it, when will it take place, and with whom?
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15.0 Timetable
Stakeholder(s) and engagement Issues / documents Possible dates activity(ies) During the development of ESAP and NTS XXX XXX XXX XXX XXX XXX When the ESAP/SEP/NTS are completed All stakeholders Publish ESAP, SEP and NTS (in XXX English and Ukrainian) and inform all stakeholders through local media. Include responses to comments, suggestions which were not incorporated in the documents. Before construction Contractors / temporary workers Agree construction related XXX grievance management, inform all stakeholders; Code of conduct for temporary workers, trainings Local population Information on safety measures XXX Traffic Management Plan Employment opportunities and opportunities for service provision During construction and operation Public consultation meetings if Implementation of the ESAP, new XXX necessary (determined in cooperation impacts, revision of documents, with EBRD) implementation of SEP, processing and responding to grievances
After construction
Ongoing meetings and cooperation, throughout the life of the project, with the following external stakeholders: • XXX
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16.0 Public Grievance Mechanism
The objective of a grievance procedure is to ensure that all comments and complaints from any project stakeholder, including local/regional authorities, residents of nearby residential areas, company name XXX employees, company name XXX contractors’ staff and other interested parties, are considered and addressed in an appropriate and timely manner. All grievances will be acknowledged and responded to within a reasonable timeframe. company name XXX will accept all comments and complaints associated with the project. A sample of a Comments and Complaints Form is shown in Appendix A. The comments and complaints will be summarised and listed in a Complaints/Comments Log Book, containing the name/group of commenter/complainant, date the comment was received, brief description of issues, information on proposed corrective actions to be implemented (if appropriate) and the date of response sent to the commenter/complainant. Any person or organisation may send comments and/or complaints in person or via post, email, or facsimile using the contact information specified in Section 8.0 below.
All comments and complaints will be responded to either verbally or in writing, in accordance with preferred method of communication specified by the complainant in the Comments and Complaints Form. Comments will be reviewed and taken into account in the project preparation; however they may not receive an individual response unless requested.
All grievances will be registered and acknowledged within 5 days and responded to within 20 working days. Company name XXX will keep a grievance log and report on grievance management, as part of annual project progress reports, available at the company name XXX website and on request at add contact details.
Comments and concerns regarding the project can be submitted in writing in the following ways: • electronic form on company name XXX website or KazREFF website?: add details • email: XXX • by post or hand delivered to (see example grievance form attached): – XXX • by phone: – XXX
Provide contact person and specify contact details Individuals who submit their comments or grievances have the right to request that their name be kept confidential.
During construction, grievances in relation to construction activities will be managed by company name XXX and construction contractor. Local residents will be informed about the contractors contact information before construction begins, through the local media (listed in the table above) and announcements in public places.
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A separate grievance mechanism is available for workers, both employees of company name XXX and the contractors. 17.0 Roles and Responsibilities
Provide contact person and specify contact details will have the overall responsibility for handling the consultation and information disclosure process, including organisation of consultation process, communication with identified stakeholder groups, collecting and processing comments/complaints, and responding to any such comments and complaints. Depending on the nature of a comment/complaint, some comments or complaints will be provided to the appropriate person in the company for a response.
Name of the person and title Affiliation XXX Company: XXX Postal Address: XXX Telephone: XXX E-mail address: XXX Hotline: XXX
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APPENDIX A Comments and Complaints Sample Form FORM FOR COMMENTS, COMPLAINTS AND REPORTS OF INDIVIDUALS Reference No: Full Name
Contact Information By Post: Please provide mailing address: and Preferred method ______of communication ______
Please mark how you wish to be contacted By Telephone: ______(mail, telephone, e-
mail). By E-mail ______
Description of Incident or Grievance: What happened? Where did it happen? Who did it happen to? What is the result of the problem? Source and duration of the problem?
Date of Incident/Grievance
One time incident/grievance (date ______) Happened more than once (how many times? _____) On-going (currently experiencing problem)
What would you like to see happen to resolve the problem?
Signature: ______Date: ______Please return this form to: XXXXXXXX Address ______: Tel.: ______or E-mail: ___
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CONTENTS
Kazakhstan Renewable Energy Financing Facility (KazREFF )
PROJECT NAME
Environmental and Social Action Plan - Wind
DATE
P
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CONTENTS
1 PROJECT OVERVIEW 93 1.1 Project approach 93 1.2 Scope of this ESAP 93 1.3 ESAP for on-shore wind projects 95
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1 PROJECT OVERVIEW
1.1 PROJECT APPROACH To encourage businesses to pursue sustainable energy projects, the European Bank for Reconstruction and Development (EBRD) has launched the Kazakhstan Renewable Energy Financing Facility (KazREFF). KazREFF aims to ‘provide development support and debt finance to renewable energy projects which meet required commercial, technical and environmental standards’. KazREFF not only provides tailor-made financing, but also provides technical assistance for businesses and local authorities based on information gathered and analysed by stakeholders to promote projects that are often challenging to finance and implement. KazREFF is part of the EBRD’s Sustainable Energy Initiative (SEI) which addresses the challenges of climate change and energy efficiency. Since the launch of the SEI in 2006, the EBRD has remained at the forefront in helping countries from Central Europe to Central Asia secure sustainable energy supplies and finance the efficient use of energy that will cut demand and imports, reduce pollution, and mitigate the effects of climate change. In co-operation with the national authorities in Kazakhstan, EBRD commissioned a Strategic Environmental Review (SER) for the KazREFF programme, focusing on renewable energy technologies in optimal areas of Kazakhstan. The renewable energy technologies specifically reviewed in the SER include small hydropower, on-shore wind, solar photovoltaic, and biogas technologies. Four Environmental and Social Action Plan (ESAP) templates have been produced – one for each of the renewable energy technologies – to provide a framework for further development at the inception of a given renewable energy project that is seeking funding from KazREFF. The SER and associated Environmental and Social Action Plans comply with the EBRD’s Environmental and Social Policy and its Public Information Policy.
1.2 SCOPE OF THIS ESAP This ESAP is for the on-shore wind renewable energy scenario; It includes a series of actions to be undertaken in order to manage – that is, to plan and implement specific measures to avoid, reduce, control, or otherwise mitigate – potential environmental, occupational health and safety, and social impacts during construction and operation14. This ESAP should be considered as a template which will be reviewed and amended by project proponents who wish to develop specific on-shore wind projects funded by KazREFF in the future; and will be part of the contract between the project developer and EBRD. It is envisaged that EBRD will require performance of the required actions to be regularly reported and that it will periodically monitor implementation of the ESAP. The table below presents the actions required by this ESAP, organised by the EBRD’s Performance Requirements. These actions should be added to as befits the individual project situation; If there is a good reason to remove an action from the table this can be agreed with the EBRD during the development of the project. The table shows the source and timing of
14 For purposes of this ESAP, “construction” includes all actions in the field to construct the project, including support and ancillary facilities such as construction camps, roads, temporary or permanent buildings, staging areas, etc. “Operation” means routine and non-routine operation and maintenance of the hydropower plant and support facilities, and “project performance” includes the entire period of construction and operation.
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the requirement and the criteria by which performance of the action will be evaluated. Implementation of all the actions will be the responsibility of project developer. When other companies perform work under contract, the developer will be responsible for those contractors’ compliance with the requirements of the ESAP. This is expected to be accomplished by inclusion of appropriate requirements in contracts and subcontracts, and by direct oversight and supervision by the developer as needed. As specified in various required actions, or as otherwise agreed by the parties, once produced, a project-level ESAP may be further revised from time to time during project performance. No changes to the project-level ESAP will allow violations of Kazakhstan law or of EBRD requirements for environmental and social performance. Additionally, it should be fully understood by all parties that this ESAP does not supersede any local or national laws; the developer must comply with all applicable laws and regulations governing the development of the proposed facilities.
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KAZAKHSTAN RENEWABLE ENERGY FINANCING FACILITY (KAZREFF) 1.3 ESAP FOR ON-SHORE WIND PROJECTS Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility 0 Prepare and submit reports on status of ESAP EBRD PR1 Each six months Submission reports on environmental, implementation and environmental and social during construction, occupational health and safety, and performance, including resolution of grievances. annually thereafter social (ESHS) performance 1. Environmental and social planning and management 1.1 Achieve and maintain environmental and social Best international Ongoing Include in ESHS report the status of management systems equivalent to ISO 14001. management practices. environmental and social management systems PR1 1.2 Achieve and maintain an occupational health Best international Ongoing Include in ESHS report the status of OHS and safety (OHS) management system to OHSAS management practices. management systems 18001 or equivalent for all companies associated PR1 with energy generation, transmission and distribution. 1.3 Appoint responsible manager(s) for Best international Throughout - Appointment of corporate ESHS environmental and occupational health and management practices. construction and manager safety issues. Train foremen and appropriate operation PR1 - Training of foremen and other staff staff on each construction team and ensure operations meet the relevant requirements of this - Ultimate goal: full compliance with ESAP and, as needed, the requirements of ESAP EBRD’s Performance Requirements. - Include in ESHS report updates on appointment(s) and training 1.4 Develop comprehensive waste management Best international Prior to and during - Preparation and implementation of plans for the project. Plans should include (at a management practices. construction waste management plans minimum): PR1 - Include in ESHS report information - Procedures for proper handling of all waste on plan preparation and waste
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility generated at the construction or operational management compliance status site (including hazardous and non-hazardous waste); - Methods to verify proper off-site management of related wastes by contract waste managers; and, - Measures to minimise waste generation and maximise reuse and recycling. Note that wastes include paper, printer cartridges, lights, and office waste as well as construction and industrial waste 1.5 Establish corporate policy and procedures for Best international Prior to and during ESHS reports to EBRD on: oversight of contractor (if project proponent is management practices. construction - Programme description not also contractor) ESHS performance during PR1 construction, to include (at a minimum): - Highlights of performance (appointments, inspections, etc.) - Inclusion of appropriate ESAP and other legal requirements in contracts, including - Training requirement for staff/management training; - Contractor summaries (both at - Assignment of clear responsibilities within contractor level and compiled project developer for contractor oversight of the level) in terms of environmental and projects; OHS performance summaries - Regular inspections of sites and contractors’ construction camps; - Contractor reports on performance sufficient to allow inclusion of data in ESHS reports to the Bank, and to allow developer to determine if corrective actions are needed; and,
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility - Verification of training and professional credentials for contractor environmental and OHS managers and staff. 1.6 Obtain all required permits for the projects and Local regulatory Prior to construction - Identify permits required and comply with permit requirements. requirements and during received in ESHS reports; and, operation, as PR1 - Report on compliance in ESHS applicable reports 1.7 Monitor performance of project during operation PR1 During operation Submission of monitoring reports against the environmental and social standards demonstrating that predicted and objectives set and submit regular reports to environmental and social effects are being satisfactory mitigated for. EBRD at agreed timescales and for an agreed period (likely to be a number of years). 2. Performance Requirement 2: Labour and Working Conditions 2.1 Evaluate HR management system and PR2 Prior to construction - Until complete, include in ESHS procedures against EBRD requirements and report status of required and Kazakhstan law, including specifically completed updates to HR systems; provisions covering: - Report annually on key worker data, - terms of employment and dismissal; including dismissals and new hires, status of medical checks, etc.; and, - grievance mechanism; - Include in ESHS report data on - discrimination, harassment, violations and numbers of workers in various human rights; categories (management, skilled, - proscription of forced and child labour; unskilled, etc.), and breakdown by gender. - mandatory medical checks for new hires; and, - social leave/benefits. Update system/policies as necessary to ensure ERM 97 KasREFF SER RPER WIND – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility compliance. 2.2 As part of policy development under item 1.5 PR2 Prior to contracting - Preparation and implementation of above, develop and implement a contractor plan; and, management plan for the project, and procedures - Report on contractors’ compliance ensuring contractor’s compliance with EBRD PR and oversight results. 2 and Kazakhstan labour law. 2.3 Support local labour force by: Best international Throughout - No complaints from labour force; practices. construction and, - Providing realistic information on employment opportunities, with transparent PR2 - Include data on use of local labour in hiring practices; ESHS reports. - Advertise for all positions; - Employing local labour where possible; - Pay wages at least average for the area for comparable positions; and, - Construction camps must comply with Kazakhstan law and provide adequate heating, showering and cooking facilities. 2.4 Develop and implement an OHS plan to guide Best international Plan in place prior - Preparation and implementation of all project-related activities on the project sites practices. to construction (for OHS plans for projects; during construction and then throughout contractors, prior to PR2 - Review and approval of contractor operation. Also require contractor site operations). OHS plans; and, plan/compliance. Requirements to include (but Throughout not be limited to): - Include in ESHS reports to Bank data construction and on performance by developer and - Job- and task-specific hazard analysis and operation. contractors (hours worked, accidents, controls for developer and contractor’s lost time, etc.). activities (given the nature of wind turbine construction, this should include specific
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility measures for working at heights); - Provision of PPE, requirements for use of PPE, and enforcement of PPE use; - Safety training for all personnel, covering hazards for their jobs; - Review and approval of contractors OHS plans, to meet same standards as developer’s plan; - Oversight of contractor OHS implementation, including mandatory reporting; and, - Recording incident statistics, including total work hours.
2.5 Location and life activities of construction camps Best international At all times Compliance shall meet the requirements of Kazakhstan law practices. construction camps Include data on incidents in ESHS and EBRD PR2. PR2 are occupied reports 3. Performance Requirement 3: Pollution Prevention and Abatement 3.1 Implement mitigation measures and best Best international Throughout Minimal dust generation management practices to prevent / reduce / practices. construction control air pollution from fugitive dust and PR3 vehicle / equipment emissions. - Control dust emissions in dry periods by using water or other dust suppression methods on roads and other areas that may generate dust; - Ensure efficient usage of delivery vehicles; including use of alternative and/or more
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility efficient delivery methods (including for example rail, boat) during construction to optimise the emissions to atmosphere per payload; - Ensure all vehicles carrying spoil and all stockpiles are covered; - Switch vehicles and equipment off when not in use; and, - Keep all motorised equipment and vehicles well-maintained to reduce emissions. 3.2 Develop erosion, sediment and water quality Best international Throughout Mitigated adverse impacts on water control plan for all areas where the ground will practices. construction quality be disturbed during construction. Plan should (at PR3 Report on impacts in ESHS reports. a minimum): - Specify use of good housekeeping practices and best management practices to minimise surface water and stormwater runoff to watercourses and aquatic habitat (especially in critical areas or time periods for aquatic life). For example, siltation dispersal, such as settling ponds, using silt curtains along any nearby waterways, straw bales, check-dams, and seeding; - Keep hard-standing areas and road surfaces clean from mud and oil build up; - Keep stockpiles covered, minimise bare ground near rivers; - Store hazardous and potentially polluting
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility materials in bunded, secure, areas away from watercourse and pathways to watercourses (e.g. drains, ditches); - Use kerbed/ bunded areas to prevent run off to river; - Silt collected in any device or structure should be cleaned away regularly; - Inspections of vehicles and equipment for leaks before use near or in water; and, - Particular attention should be given to avoiding steep slopes and implementing erosion control measures, and promptly re- vegetating cleared land with native species only. 3.3 Implement measures to prevent / reduce / Best international Throughout Mitigation in place for potential adverse control ground contamination as a result of spills practices. construction and impacts of ground contamination. of fuel, lubricants and other chemicals. operation PR3 - Store fuels and oils in bunded containers with 110% capacity; - Ensure drip-trays are in place where fuels or oils are stored or used; - Identify a designated bunded refuelling location; - Educate drivers and equipment operators in proper fuel management, including clean-up of spills; and, - Make spill kits available, and use if necessary
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility to clean up oil spills etc before contaminants can enter the ground or watercourses. 3.4 Ensure appropriate containment and disposal of Best international Throughout Reduction in the risk of water / land construction wastewater, including sanitary practices. construction and pollution and impacts on ecology water and storm water. All sanitary and storm operation PR3 water to be collected and delivered to a nearby waste water treatment works. 3.5 Developer to ensure that the project team has a Best international Throughout Potential major incidents identified and high level of preparedness for emergencies (such practices. construction and avoided through emergency planning; if as earthquakes and major dam failures) and that operation major incidents occur, these are handled PR3 PR4 an appropriate emergency plans is in place and according to the planned procedures. understood by developer and contractor staff. Include the local community in the emergency plan. 3.6 Develop plans to reduce project-related Best international Planning prior to GHG emissions minimised greenhouse gas (GHG) emissions practices. construction and GHG emissions reported to EBRD in implementation - Establish baseline GHG emissions; PR3 ESHA report. throughout - Estimate construction and operation GHG construction and emissions and take steps to reduce these operation during project design; and, - Record actual GHG emissions during construction and operation. 3.7 Develop reinstatement plans for working areas Best international Planning prior to Working areas reinstated with including for the re-vegetation of areas cleared practices. construction and appropriate vegetation as soon as prior to, or during, construction. implementation practicable following construction (it is PR3 following recognised that could take a number of construction. months or in some cases years).
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility 3.8 Develop soil protection plan to include: Best international Prior to construction Mitigated for potential adverse impacts practices. upon soils. - Site selection and facilities arrangement (including transmission lines, access roads, PR3 PR4 etc) to avoid or minimise displacement of productive agricultural lands; - Measures to minimise compaction and other alteration of soil composition across working area; and, - Soil erosion across the working area (as separate to erosion of banks and river bed within the watercourse). 4. Performance Requirement 4: Community Health & Safety and Security 4.1 Develop and implement – and require PR4 Throughout - Public notices contractors to implement – procedures to protect construction and - Security training public health and safety, to include (but not be operation limited to): - Include in ESHA report to Bank data on notices, training, etc. - Traffic management plan for all drivers and equipment operators (see 4.2 below); - Public notice of construction operations near areas open to the public; - Methods to identify and prevent spread of those communicable diseases that can be transmitted by the project components or its workforce (including contractors); - Methods to prevent and minimise exacerbating impacts caused by natural hazards (such as landslides or floods);
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility - Security as needed to prevent unauthorised access to project locations, with appropriate training for guards to be guided by the principles of proportionality, good international practice and Kazakhstan law; and, - Hazard notices/signs/barriers to discourage/prevent access to energised components or other dangerous areas. 4.2 Develop and implement a Traffic Management - Best international Throughout Traffic management plan Plan. practices construction and Include in ESHS reports data on all operation - Design routes so as to avoid schools, - PR4 accidents hospitals, and other areas where there may be heavy pedestrian or child use; - Notify communities and place signs on public roads prior to periods of heavy use; - Place warning signs along the perimeter of construction areas; - Confine construction activities to daylight hours; - Establish and enforce strict speed limits on- and off-site; - Provide training to all drivers, enforce compliance with traffic plan; and, - Identify and implement measures to reduce construction traffic where possible, for example through car sharing and use of
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility bicycles etc. 4.3 Develop a noise monitoring and mitigation PR2, PR4 Establish baseline Robust baseline programme that will establish a pre-construction prior to construction Minimal off-site disturbance baseline and ensure construction and operational Monitor noise noise is within Kazakhstan law and to minimise Early awareness of potential noise periodically off-site disturbance to local population. impacts, allowing mitigation to be put in throughout place as required Avoidance and mitigation measures for noise, construction should include consideration of: - Proper siting of wind farms to avoid locations in close proximity to sensitive noise receptors (e.g. residences, hospitals and schools); - Turbine designs which adhere to relevant national and international acoustic design standards for wind turbines (such as those provide by the International Energy Agency, the International Electrotechnical Commissions and the American National Standards Institute); - Consideration of using turbine designs that allow lower rotational speeds in high winds, such as variable speed turbines or pitched blades; - Controls on construction and operation hours; - Controls on type of construction and maintenance plant/vehicles; - Controls on type of delivery vehicles used, routes used for deliveries and timing of
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility deliveries; and, - Noise screening of works / operational areas. 4.4 Establish and enforce clear rules for workers Best international At all times when Include in ESHS report information on (including contractor employees) in construction practices construction camps complaints and incidents involving camps to prevent off-site disturbance incidents are occupied workers, and contractor/developer involving local residents. responses 4.5 Avoid or mitigate for the risk of ‘shadow flicker’ Best international Prior to construction Minimal off-site disturbance (which occurs when the sun passes behind the practices
wind turbine and casts a shadow) through appropriate siting to avoid sensitive receptors (such as residential areas) or through using modelling software to identify zones of flicker in order to inform proper siting of the turbines. 4.6 Avoid or mitigate for the risk of ‘blade or tower Best international Prior to construction Minimal off-site disturbance glint’ (which occurs when the sunlight strikes a practices
rotor blade or the tower at a particular angle) through careful siting to avoid sensitive receptors or through painting the wind turbines and tower with non-reflective coating to avoid reflections. 4.7 Avoid or mitigate for potential impacts upon Legal obligation and best Prior to construction No risk to aviation aircraft navigation safety, through: international practices
- Consultation with air traffic authorities and adherence to all required national and international air safety measures; - Where feasible, avoiding siting wind farms close to airports and or known flight paths; and,
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility - Inclusion of anti-collision lighting and marking systems on towers and blades. 5. Performance Requirement 5: Land Acquisition, Involuntary Resettlement and Economic Displacement 5.1 Avoid siting projects where they will cause PR5 PR4 Prior to construction Project siting in area of least disturbance disruption or displacement to established to communities Best international communities, farms and homes, or users of practices grazing land where possible through thorough consideration of alternatives. 5.2 If displacement is unavoidable, plan to improve PR5 PR4 Prior to construction Sustainable improvements to socio- or, at a minimum, restore the livelihoods and economic status of any displaced persons Best international standards of living of any displaced persons to practices pre-project levels. Displaced persons could include those who have legally recognisable rights or claims to the land, those with customary clams to the land, those with no legally recognisable rights or clams to the land, seasonal resource users such as herders/fishing families, hunter and gathers who may have interdependent economic relations with communities located within the project area. 5.3 Attempt to reach negotiated settlements with all PR5 Prior to construction Amicable agreements avoiding the need affected individuals / households for involuntary resettlement 5.4 If required, compensation to be provided at just PR5 Prior to construction Amicable agreements. replacement value, as determined by court Include information on certified valuators. This will take the form of acquisition/resettlement/ compensation replacement by a similar property or cash actions in ESHS report to Bank. compensation. 6. Performance Requirement 6: Biodiversity, Conservation and Sustainable Resource Management
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility 6.1 Undertake pre-construction ecological surveys Best international Prior to construction Survey reports, focussed on area of and associated assessments of the project practices. proposed construction footprints (including ancillary works such as PR6 improvements to transmission lines and access roads) and surrounding areas to establish a robust baseline. Surveys and assessments should be included for terrestrial ecosystems and aquatic ecosystems as befits the specific project and situation. However, it is envisaged that for on-shore wind, surveys will particularly be needed for the following: - Birds (including migratory species and to take into account key migration routes); - Bats; and, - Other wide-ranging mammals (including, otter, brown bear, bison, lynx and wildcat). 6.2 Develop an Ecosystem Protection Plan following Best international Develop plan prior Production of an Ecosystem Protection the ecological surveys. practices. to construction and Plan follow plan during Follow the Biodiversity Mitigation Hierarchy: to PR6 construction. Avoid, Minimise, Mitigate and Offset likely adverse effects. This plan to cover the construction and operational phases and to include consideration of all species and habitats applicable to the project, including provisions to: - Avoid, or mitigate for, siting of wind turbines
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility or associated transmission lines in areas recognised as important for bird migration paths (where avoidance is not possible, an example of mitigation would be to group turbines rather than spread them widely, or to orient rows of turbines parallel to known bird movements); - Avoid, or mitigate for, siting of wind turbines or associated structures in areas recognised as important for bat roosting and foraging; - Mitigation for potential light disturbance to bats and other nocturnal species; - Identify and avoid or mitigate for project impacts upon species utilising key crossing points (crossing roads, transmission lines, etc). Mitigation may include, for example, such inclusions as aerial bat crossings, mammal underpasses, speed restricted crossing points and fencing, and / or restrictions upon vehicle movements during key migratory periods or times of day. 6.3 Following construction, re-grade and re-vegetate Best international End of construction Reduced adverse effects on flora and disturbed areas with native grass and shrub practices. fauna species. PR6 6.4 Avoid development within sites protected for Best international Prior to construction Reduced adverse effects on flora and their biodiversity under international or practices. fauna Kazakhstan law (habitats and/or species PR6
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility 6.5 Avoid, or mitigate for, siting of development in Best international Prior to construction Reduced adverse effects on nature areas important for nature tourism practices. tourism PR6 8. Performance Requirement 8: Cultural Heritage 8.1 Undertake archaeological desk study and site PR8 Prior to construction Survey report, focussed on area of investigations where necessary to identify the proposed construction. likelihood of presence of artefacts or other items of cultural significance.
8.2 Develop measures to avoid direct impacts on PR8 Prior to construction Protection of cultural heritage protected cultural heritage sites and their Include information on finds in ESHS settings (including UNESCO sites and those on report to Bank. the tentative list); and avoid, or where necessary mitigate for, impacts upon Registered Cultural Heritage Sites, Zones and Settlements, and unregistered or previously undiscovered sites by following a staged approach to cultural heritage studies involving qualified expertise and in consultation with the EBRD. 8.3 Before (and if needed, during) major earthworks, PR8 Throughout Protection of cultural heritage ensure the supervision of an archaeologist from a construction Include information on finds in ESHS competent conservatory institution to prevent report to Bank. destruction or theft of found objects and building remains with scientific or material value. 8.4 Develop a chance find procedure PR8 Prior to construction Protection of cultural heritage 8.5 Develop measures to avoid, or where not PR8 Prior to construction Protection of cultural practices and possible to avoid, mitigate for potential loss or resources disruption to cultural practices or resources. Include information on finds in ESHS
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility report to Bank. 8.6 Undertake a Landscape and Visual Impact Best international Prior to construction Protection of landscapes Assessment (LVIA) of the project, including practices. consideration of the potential visual impacts of PR8 the turbines and associated infrastructure from all relevant viewing angles when considering locations. 8.7 Develop a Landscape Protection Plan following Best international Prior to construction Protection of landscapes the LVIA. Follow the Mitigation Hierarchy: to practices. Avoid, Minimise, Mitigate and Offset likely PR8 adverse effects upon the natural features and landscapes that have archaeological, paleontological, historical, architectural, religious, aesthetic or other cultural significance. This plan to cover the construction and operational phases and to consider the inclusion of the following aspects where applicable: - Screening of works and operations (for example by using natural features such as tree lines, or by careful placement of earthworks); - Sensitive turbine placement and route placement of power transmission lines, access roads and other associated work; - Burial of intra-project transmission lines in sensitive areas; - Removal of inoperative turbines; - Routing of roads and transmission lines
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility along existing cuttings or linear features to reduce on setting; - Selection of construction materials and colours to integrate the development into the surrounding landscape (including painting all turbines a uniform colour, typically matching the sky, whilst observing air navigation marking rules); and, - Avoid including lettering, company insignia, advertising, or graphics on turbines. 10. Performance Requirement 10: Information Disclosure and Stakeholder Engagement 10.1 Develop a Stakeholder Engagement Plan, PR10 Prior to construction Review and approval by EBRD including a Grievance Mechanism (SEP) 10.2 Complete EBRD ESIA requirements for Category PR10 Prior to construction Disclosure through suitable means, to be B projects with a disclosure package, to be agreed with EBRD, which could include: agreed with EBRD, comprising of at least the - Flyers to local residents; SEP, this Environmental and Social Action Plan and a Non-technical summary of the - Posters in local venues/ public halls; environmental and social assessment - Information on KazREFF and/or undertaken. developer’s websites; - Public meetings; and/or, - Other, as specified in SEP. 10.3 Implement the agreed SEP, inform stakeholders PR10 Throughout project Include in ESHS report: of activities and progress, and receive and - details on grievances and resolution; respond to grievances. and, - consultations and other outreach to
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility the community, including authorities
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Prepared For: Consultancy Contract C26157REV/JPNS- 2013-02-01 Kazakhstan Renewable Energy Financing Facility (KazREFF) - Strategic Environmental Review
Renewable Project Environmental Review Report - Solar
June 2014 ERM Japan Ltd. The Landmark Tower Yokohama 19th Floor, 2-2-1 Minatomirai, Nishi-ku YOKOHAMA 220-8119 Japan www.erm.com
The world's leading sustainability consultancy
Contents
1.0 INTRODUCTION 1
2.0 RESOURCE AVAILABILITY AND POTENTIAL 2
2.1 RESOURCE AVAILABILITY 2
2.2 RESOURCE POTENTIAL 5
2.3 TRANSMISSION CAPACITY AND CONSTRAINTS 6
2.3.1 Existing Conditions 6
2.3.2 Anticipated Development 10
2.4 EXISTING PROJECTS 10
2.5 KNOWN PROPOSED PROJECTS 10
3.0 AVAILABLE AND PRACTICAL TECHNOLOGIES 12
3.1 COMPONENTS 12
3.1.1 PV Modules 13
3.1.2 Inverters and Transformers 13
3.1.3 Racking 14
3.2 GRID CONNECTIVITY 15
3.3 SITE DESIGN AND CONFIGURATION 17
3.3.1 Solar Farm Land Usage 18
3.3.2 Construction 19
3.3.3 Commissioning, Operation, and Maintenance 20
3.3.4 Decommissioning 20
3.4 DEVELOPMENT COSTS 20
3.5 SUPPLY CHAIN IN KAZAKHSTAN 21
4.0 ENVIRONMENTAL AND SOCIAL CONSTRAINTS 23
5.0 KAZREFF PROJECT APPRAISAL - ENVIRONMENTAL AND SOCIAL PERFORMANCE REQUIREMENTS 27
5.1 EBRD REQUIREMENTS 27
5.1.1 Category A 28
5.1.2 Category B 29
5.2 KAZAKHSTAN REQUIREMENTS 29
5.3 KAZREFF APPRAISAL PROCESS 31
5.3.1 Initial Screening 32
5.3.2 Documentation Review and Approval/Feedback 32
6.0 APPENDICES 34
1.0 INTRODUCTION
This Renewable Project Environmental Review (RPER) Report for Solar in Kazakhstan is one of four separate reports (other RPER reports were prepared for wind, small hydropower, and biogas) that have been prepared by Environmental Recourses Management (ERM) for the European Bank for Reconstruction and Development (EBRD). These RPER reports are prepared to support the Kazakhstan Renewable Energy Financing Facility (KazREFF) Strategic Environmental Review (SER) and provide a resource to provide guidance to developers and their consultants, as well as technical evaluators of proposed renewable projects, by identifying areas of good potential and the nature and scale of technologies that can be applied in different parts of Kazakhstan.
The source documents which have informed this RPER report are as follows:
• ERM KazREFF Strategic Environmental Review, Final Inception Report, 29 May 2013; • ERM KazREFF Strategic Environmental Review, Draft Scoping Report, 21 May 2013; • Mercados Energy Markets International, Kazakhstan Renewable Energy Market Study (KREMS), Draft Final Report, July 2013 (ÅF-Mercados EMI (2013)); • Black and Veatch, Renewable Energy in Ukraine Technical Report: Solar, 1 September 2011 (Black and Veatch 2011).
These sources have been supplemented by additional research carried out by ERM and additional sources of data identified in the text.
ERM 1 KazREFF RPER Report SOLAR – June 2014
2.0 RESOURCE AVAILABILITY AND POTENTIAL
This section of the report identifies the characteristics of the solar rich resource areas of the country and the regions of Kazakhstan where solar farm development is technically feasible. It also assesses the nature and extent of constraints to solar farm development.
2.1 RESOURCE AVAILABILITY
Kazakhstan is the world’s ninth largest country being some 2.7 million km2 in extent. Figure 1 shows the different oblasts of Kazakhstan. The western regions are dominated by extensive lowlands that include Aral and Caspian Seas, while the centre of the country is characterised by rolling hills with peaks up to 1,565 m. The south eastern and south western parts of the country are bordered by mountain ranges. Approximately 10 per cent of the country is occupied by mountains (Figure 2) and the majority of the country is un-forested. The expanse of land and terrain within Kazakhstan indicates the potential solar resource that could be available for exploitation.
Figure 1 Location Map
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Figure 2 Topography Map
Because utility scale solar depends upon large tracts of flat, un-forested land, the development of large scale solar generating stations in many locations around the world is in competition with land use for agriculture. However, in Kazakhstan, the main agricultural land is concentrated in the northern part of the country, which is less desirable for solar facilities because of its lower solar insolation. Thus, the potential for such competition with agricultural lands is limited. In general, the ground conditions in Kazakhstan are highly favourable for the development of solar facilities.
Kazakhstan has an abundance of solar radiation due to its geography and its relative elevation above sea level. It receives on average of 6.5 to 6.8 hours of sunlight per day. Annual total daily irradiation varies between 3.5 and 4.6 kilowatt hours per square meter, which is among the best potential in the world (Figure 3). The southern areas of the country, especially the Aral Sea region and Qyzylorda oblast, are most favourable for the use of solar energy. The solar energy potential in these regions reaches to 2500- 3000 solar hours in a year.
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Figure 3 Solar Resource Map
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Table 1 below highlights the solar power generating capacity of each of Kazakhstan’s oblasts. This potential in relation to transmission capacity and constraints is discussed in Section 2.3.
Table 1 Regional Solar Potential by Oblast
Region E, kW-h/m2 Region E, kW-h/m2
Astana 1,302 Almaty 1,411
Kostanai 1,224 Aktau 1,427
Petropavlovsk 1,227 Aqtobe 1,352
Qaragandy 1,335 Shymkent 1,477
Ust-Kamenogorsk 1,285 Uralsk 1,251
Ekibastuz 1,284 Turkestan 1,476
Semei 1,373 Taraz 1,373
Pavlodar 1,307 Qyzylorda 1,620
Kokshetau 1,227 Taldykorgan 1,420
Source: Reference guide to SNiP 2.01.01-82 Building Climatology.
2.2 RESOURCE POTENTIAL
The Action Plan for Development of Alternative and Renewable Energy in Kazakhstan for 2013-2020 has a short-term goal for the development of four solar plants totalling 77 MW in electricity generating capability. This programme as well as other initiatives, was used by the RoK government as a basis for a series of actions and targets for solar development from 2015 to 2030 which encourages the construction of solar facilities generating a capacity of up to 0.5 GW by 20301.
Kazakhstan has very large coal, oil, gas and uranium resources that are all being actively exploited. The country is the third largest producer of crude oil in Central Asia, behind Russia and China and has the third largest reserves outside of the OPEC member countries. One result of the abundance of energy resources has been the lack of a driver for developing solar energy on the basis of a scarcity of indigenous energy resources. Nevertheless, other drivers needed to be (and were) identified such as the need to reduce
1 CONCEPT for transition of the Republic of Kazakhstan to Green Economy, 2013
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greenhouse gas emissions, to strengthen local power supply and to act as an economic stimulus2.
2.3 TRANSMISSION CAPACITY AND CONSTRAINTS
To realise the solar energy potential of Kazakhstan solar electricity generating facilities will need to be in general proximity to existing transmission lines and the existing electricity grid will need to have adequate capacity to receive the power generated. Sites that are situated a great distance from load centres or major transmission lines face greater development costs and are generally less favourable than sites with better access to these facilities. Larger projects are able to locate farther away from transmission while smaller projects are located closer to transmission, due to economies of scale of larger projects to absorb higher transmission costs3.
2.3.1 EXISTING CONDITIONS
The grid in Kazakhstan is state-owned and operated by the Kazakhstan Electricity Grid Operating Company (KEGOC). There are also 21 regional energy companies (RECs) that distribute electricity on a regional monopoly basis. Due to the size of Kazakhstan the network is characterised by long distance transmission. The Kazakhstan transmission network dates back to the Soviet era and has a history of underinvestment. However at present it has sufficient capacity and no voltage problems. The majority of the population is connected to the grid, less than 5 per cent of the population, located primarily in rural areas, are without electricity. However, in some areas power cuts or discontinuous supply are not uncommon due to grid capacity issues and a lack of local generation facilities. In addition, in some regions the industrial base has expanded and investment in power infrastructure has failed to keep pace. Figure 4 shows the areas of greatest population density and domestic energy demand in Kazakhstan.
2 Lessons learnt from the UNDP-GEF project “Kazakhstan — Wind Power Market Development Initiative, UNDP Kazakhstan, 2011. 3 Black & Veatch 2011
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Figure 4 Population Map by Oblast
The electricity grid is separated into three regions west, north and south (Figure 5). It has a general north-south split in generation and demand with approximately 80 per cent of the electricity being produced in the north near coal reserves and 70 per cent being used in the same industrialised region (UNDP/GEF 2011). The transmission system operates at 500 kV and 220 kV and consists of 24,101 km of 35 - 1150 kV overhead transmission lines and 74 power substations with an installed capacity of 34,408 MVA (see Figure 6). A 1,100 km 500 kV electricity transmission system has connected the north and south regions since 2009. Due to demand growth in the southern zone the transmission lines connecting north and south are fully loaded, and in the period of peak demand (winter) they are reported to be occasionally overloaded.
The northern electricity grid contains links to Russia and Central Asia and the southern network contains links to Kyrgyzstan and Uzbekistan. The west of the grid is isolated from the remainder of the national electricity system and has interconnections with Russia.
From 2011 to 2013 power consumption significantly exceeded energy production, which, taken into account transmission losses has highlighted a deficit of approximately 800 MW. This deficit is currently overcome by importing electricity from neighbouring countries. Demand is projected to reach 145 TWh by 2030 from the current level (CAGR of 2.6 per cent) (Åf- Mercados EMI 2013).
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Figure 5 Transmission Regions in Kazakhstan
658 209 700 1173 1180 390 3195 480 850 1720 1609 700 160 95 337 1823
348
90 1862 160
160 320 1020 860 1620 1020
Source: Åf-Mercados EMI (2013)
Developing solar power projects in the south could help solve the problem of the overload of the north-south transmission lines. The northern zone has an excess of generation, but development would still be an advantage in order to reduce the power imports from neighbouring Russia. The western grid operates separately and currently has a load shortage of about 100 MW, which is also covered by power import from Russia. Solar power development in the western zone, especially in Manggystau, would reduce Kazakhstan’s reliance on imports from Russia.
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Figure 6 Transmission System Map
In general, the existing transmission system should not be an impediment to solar development, although there are areas where accessing transmission would be prohibitively costly. Most of the solar projects under consideration are small to moderate in size (2 MW to 20 MW) and while such projects do impact transmission flows, they are dwarfed by the existing hydro and coal plants, which are mostly greater than 400 MW. The existing transmission lines have been planned for these larger projects, so where lines exist, the addition of one or two small projects is not likely to upset the dynamics of the system unless the system is already at its capacity limit. The limits of the system could only be determined by a full system flow analysis for individual projects, but, in general, capacity availability should not be a problem. Solar development is likely to be in the southern areas of the country. In the southern oblasts of Qyzylorda, Southern Kazakhstan, and Zhambyl, there is a major (500 kV) transmission line and a number of smaller (230 kV) lines. The southern region often imports power and, to the degree that a new solar facility would displace this imported power, the loads would effectively net out.
There are large areas of the country (Aqtobe and Qyzylorda) that have excellent potential, available land, but no transmission infrastructure. In these areas without access to major transmission lines, it would be problematic to connect solar systems of 50 MW or more, and on some small radial lines, even 20 MW facilities could require system reinforcements. Extending the lines here would reinforce the entire Kazakhstan transmission system, but it would be a major undertaking and if the only resources added were solar, the intermittency on the system could create stability problems.
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2.3.2 ANTICIPATED DEVELOPMENT
The suitability assessment of the transmission grid for development of solar power assumes that there is no investment in the electricity grid of Kazakhstan. However it should be noted that considerable network development both on-going and planned is being undertaken by Government of the RoK and KEGOC.
Projects planned, or currently being implemented, include:
• Modernization of the national electrical network (NEN) to be completed by 2016. The project comprises reconstruction of the majority of substations and construction of some new transmission lines; • Construction of a 500 kV substation "Alma" ( located in the area of Almaty) with connection to the NEN This will eliminate the overloading of existing "Almaty" substation and ensure the reliability of power supply to the Almaty region; and • Reconstruction of a 220 kV overhead line central main substation in Astana.
There are also plans for connecting the western grid to the national grid by 2030.
2.4 EXISTING PROJECTS
At this time, a very limited number of solar facilities have been built. The existing installed capacity of solar photovoltaics (PV) in Kazakhstan is only 0.5 MW, all coming from the Otar Solar Power Plant in Zhambyl oblast. There are plans to extend this facility to 7 MW, and then to 24 MW by 2014.
2.5 KNOWN PROPOSED PROJECTS
In addition to small-scale local solar facilities, larger scale installations are planned and include:
• Samruk-Energy (an agency of the Kazakhstan government) has proposed a 70 MW solar facility near Astana to be on-line in time for EXPO 2017. • Kazakatomprom has a PV cell manufacturing facility and has proposed a solar project, but no details are available at this time. • Chevron and Astana Solar have been identified as important stakeholders for solar, but there are no details on specific projects they may be considering.
In stakeholder meetings conducted during the SER scoping process, representatives from the Republic of Kazakhstan Institute noted that they
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understand there exists, or is planned, a 2 MW solar facility in Capchup, but details of this project are not available. These are summarised in Table 2.
Table 2 Operating/Announced Solar PV Projects
Name/Owner Location Operating Proposed MW MW
Otar Solar Zhambyl 0.5 7 (2013) 24 (2014)
Samruk Energy Astana 0 70
Kazakatomprom Unknown Unknown Unknown
Chevron Unknown Unknown Unknown
Astana Solar Unknown Unknown Unknown
Unknown Capchup Unknown 2
Source Åf-Mercados EMI (2013)
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3.0 AVAILABLE AND PRACTICAL TECHNOLOGIES
This section looks at the type of technology that would be employed for solar power generation in Kazakhstan. It details the key activities and environmental and physical constraints to be taken into consideration for the construction, operation and decommissioning of a potential site. It also discusses the current status of the solar facility power supply chain in Kazakhstan.
3.1 COMPONENTS
Only utility scale, ground mounted solar PV projects sized at 0.5 MW or greater are presently being considered for solar power generation in Kazakhstan. The following sections detail typical solar farm components and the performance and operation of a typical solar farm. Project costs and component availability are also discussed.
A PV system has three critical components: PV modules, inverters, and racking. In addition, the interconnection infrastructure at a medium or high voltage is especially important for medium and large PV projects. Other components include wiring, combiner boxes, disconnection switches, meters, and monitoring equipment. Figure 7 presents a general conceptual overview of a Solar PV system.
Figure 7 Conceptual Overview of a Solar PV System
Source: Black & Veatch (2011)
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3.1.1 PV MODULES
There are many variations of solar PV technologies based on different types of solar cells (monocrystalline, polycrystalline, amorphous, thin film, etc.) and mounting structures (fixed tilt, single-axis tracking, dual-axis tracking, etc.).
Initially, solar cells were either monocrystalline or polycrystalline silicon. As recently as 2008, there were a limited number of factories producing the high- quality silicon wafers needed for solar PV, resulting in shortages and high prices. The construction of hundreds of additional factories to produce these wafers, and the development of alternative technologies, has drastically changed this situation. Today, in addition to monocrystalline and polycrystalline solar cells, there are amorphous and thin film cells. Amorphous cells are produced by a deposition technology and have sometimes been promoted as a manufacturing-in-a-box technology that could be easily set up and used to promote local manufacturing. Thin film technology is manufactured through a sputtering-type application system. Thin film technology was initially developed commercially by First Solar and the technology represented a major breakthrough in cost. Today, polycrystalline and thin-film are the two dominant types of solar cells. Thin film is generally cheaper and lighter but less efficient, thus requiring more surface area for the same output. However, these two technologies have become highly competitive in recently years, so that at any time one might be less costly overall than the other. In general, since the shortages of the 2008 time period, solar cells have fallen in cost by close to 80 per cent.
In addition to crystalline, amorphous, and thin film solar PV cells, concentrating solar PV cells have come into the marketplace within the last two years. Concentrating PV cells are not the same as concentrated thermal solar. In solar thermal technology, the solar energy is transferred to a power tower or to fluids in a tube. In either of those cases, the liquid is heated and then power is generated through a traditional steam system. In concentrating PV cells, the cell itself is concentrating the energy and producing a larger output of electricity. There is no thermal component, nor standard steam generation system. The concentrating PV cells are more expensive to produce, somewhat off-setting the higher output. Today there are a limited number of factories producing the concentrating PV cells, but they are planned for, or being used in, a number of large-scale solar facilities in South Africa and the United States.
3.1.2 INVERTERS AND TRANSFORMERS
The inverter converts DC current generated by the PV modules into grid- quality AC current. For the types of projects being considered in this REPR, two large capacity inverters are used to integrate a single power conversion unit with a typical capacity between 1 and 2 MW. This type of PV design is
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known as a central inverter configuration and has typical conversion efficiencies between 97 and 98 per cent.
For utility-scale projects, the inverter output is connected to a transformer that elevates the voltage to a distribution level. The collection of all the transformers output occurs at a switchyard, which can also be the point of interconnection to the grid via a substation. The switchyard output is elevated to the distribution or the transmission voltage before interconnection with the grid.
3.1.3 RACKING
A simple utility scale solar facility consists of a large number of solar panels individually mounted on supporting structures; usually metal grids raised approximately one meter off the ground, which, in turn, are supported by vertical posts driven into the ground. In some cases, where the soil is not sufficiently stable, holes are bored and the posts are put into these holes and concrete foundations are poured to stabilize and support the posts. The electric leads from each PV panel are then connected to the panels on each side, with between 12 and 36 panels connected in series into a string. The strings are wired together in parallel into an array. An array can contain as few as 10 or as many as 100 strings, depending on the decision of the designer. The arrays are generally configured to face south (in the northern hemisphere), and are tilted at an angle calculated to create the maximum electricity during the year.
Most systems have the panels and supporting structures fixed in place as described above, and are called “fixed tilt” systems. The installation does not move once in place. However, the units can be configured to have single- or dual-axis tracking to allow the arrays to track the sun, daily and seasonally, and optimize the amount of solar radiation received as shown in Figure 8. Tracking systems add to the cost of a solar facility but increase the overall output. Whether the additional cost of tracking is worth the additional output depends upon the particular system, insolation conditions and configuration.
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Figure 8 Typical Solar PV Racking Systems
Source: Black & Veatch (2011)
In all cases, the mounting systems must be designed to withstand any expected earthquake forces or wind loads. To date, anecdotal evidence suggests that most utility scale solar facilities have not experienced damage even from major wind storms (such as Hurricane Sandy on Long Island, New York, U.S., in 2012). However, longer term data is not available.
3.2 GRID CONNECTIVITY
From an electrical interconnection perspective, modules are connected in series to form strings or arrays. Arrays typically connected to inverters, which transform the direct current generated by the panels into alternating current appropriate for the electric grid. Panel-to-panel connections are generally run along the structures, but array to inverter to transformer cabling is usually buried in shallow covered trenches. The final step connects all the inverters to a transformer, where the plant voltage, usually 600 to 1000 volts, is significantly increased to the appropriate voltage for interconnection to the grid.
Solar PV plants consist of DC solar panels tied together as a grid into a DC-to- AC inverter. Inverters provide negligible single line to ground fault current to the system. Inverters do increase harmonic content to a system due to the
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power electronics required to convert the power to AC. Increasing harmonic content can create stability concerns for an interconnection, especially within weaker power systems (e.g. radial distribution lines). Although there is a small amount of fault current contributed by the inverters, the padmount transformers and cable can still provide a source of fault current, albeit low in contrast to other technologies. Different padmount transformer configurations can also increase or decrease the amount of fault current onto the system, so it is important to design the system to keep the zero sequence impedance to a minimum, but still have a ground reference (so no overvoltage scenarios occur). Series neutral reactors or resistors can be added to the neutral connections of the collection system to increase the zero sequence impedance, thus decreasing the fault current. Solar PV projects of different sizes have different interconnection concerns as discussed below.
Smaller interconnections (1 to 5 MW) are typically more feasible to interconnect at lower voltages due to the equipment necessary to build out an interconnection substation for the solar plant. These interconnections would be best suited at the lower transmission voltage and distribution levels. Solar facilities of this size typically serve local load instead of delivering power across long high-voltage transmission lines. The only caveat is that intermittent resources should not be interconnected to radial distribution systems due to stability concerns. Smaller scale solar plants can typically deliver the power through one medium voltage underground feeder which may tap directly into the distribution system at an interconnection substation. Distribution interconnection codes vary and should be used to determine requirements.
Medium scale interconnections (5 to 20 MW) are more feasible to interconnect at medium transmission voltages, such as 220 kV. These project substations require more inverters and more feeders, and larger equipment. These solar plants may serve local load, but can also be delivered into key transmission substations which step up to higher voltages. It is also optimal to locate these at substations with multiple outlets to avoid curtailment and ensure delivery of power.
Medium scale solar installations typically require more feeders from the inverters, but once collected together can be combined to step up the voltage through a step up transformer. Some inverters have transformers built in, and in this case, would just need to be connected into enclosed switchgear within a new collector substation which then is connected via overhead transmission to an interconnection substation. The switchgear may also be located within an existing substation and interconnected to a built-out bus within the fence.
Large scale interconnections (>20 MW) are injected at higher voltage substations that have multiple outlets. The reason for this is to allow for delivery dispersed between multiple transmission lines and to avoid
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curtailment. Large scale solar plants collect into a large collector substation with switchgear after the inverter. Newer inverters with transformers built in can deliver the power at distribution voltages, but this would still need to be stepped up again to get to the transmission voltage. These built-in transformers may not benefit the overall installation of the solar plant due to the large quantity of feeders necessary. The switchgear delivers the medium voltage feeders (approximately 25 MW per feeder, up to eight feeders per enclosed switchgear) to one or more step up transformers. This power is then delivered to the interconnection substation or an existing substation.
3.3 SITE DESIGN AND CONFIGURATION
Several factors should be considered when selecting a site and designing its configuration. The quality of the resource is an obvious primary consideration; however, there are some other significant issues in Kazakhstan, identified in the SER that should be considered when siting power facilities:
• Flood prone areas – Construction of solar plants in areas prone to flooding could result in the damage of PVs and associated infrastructure. In general, construction in flood prone areas should be avoided.
• Extreme weather – Snow has a potential negative impact on the ability to harvest solar energy. In most locations where solar has been installed around the world, the tilt of the solar panels has been adequate to cause normal snowfall to slide off and not accumulate. However, the potential in some of Kazakhstan’s oblasts for snow to accumulate to a depth of 2 meters or more means that, at some locations, panels might need to be placed on an elevated rack in order to function during typical snow seasons4. There is little comparable data to make recommendations in this regard, but it is a consideration.
On the positive side, research suggests that PV solar panels are more efficient in cold weather and, therefore, it is possible that solar systems installed in the generally cold regions of Kazakhstan may actually produce more electricity per unit than similar projects in more temperate zones.
• Air pollution - Air pollution is a common issue in the major cities and industrial areas of Kazakhstan. Kazakhstan has set the Maximum Permissible Concentration for suspended dust at 0.5 milligrams per cubic meter on hourly average. A heavy concentration of suspended dust has the potential both to decrease the net solar insolation and to accumulate dust on panels, requiring more frequent cleaning to avoid
4 Snow information: Kazakh Research Institute of Power Engineering
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a loss of efficiency. This may be an important consideration, especially in the Qaraghandy and Pavlodor regions, which have been shown to have had the country’s highest emission levels.
• Seismicity, mudflows, and landslides - Construction of solar plants in areas of high seismicity or in areas prone to mudflows and landslides could result in the damage of PVs and associated infrastructure. In general, construction in high risk areas for these hazards should be avoided.
• Contaminated lands – Construction of solar facilities on contaminated lands may be a beneficial use of these degraded areas; however, special consideration must be made to ensure the health of workers that could be exposed to contaminants at the surface (e.g. nuclear testing areas) or below ground during construction.
• Land use - In general, due to the relatively tight spacing of PV panels and the arrays, the existing land use activities such as agricultural cannot continue during operation. Also, solar facilities would not be economically feasible on open water, especially given the abundance of available land in Kazakhstan; therefore, it is unlikely any facilities would be water-based.
• Proximity to transmission grid and loading – In general, facilities should be located proximate to existing substations with capacity on the transmission grid. Solar facilities become to become less economical at increasing distances from substations due to the costs associated with extending distribution or transmission lines to the solar plant.
3.3.1 SOLAR FARM LAND USAGE
Utility scale solar can be sited in 0.5 MW to 2 MW blocks, which are often available relatively near to cities and load centres. Larger blocks of land are needed for the 50 MW to 200 MW-sized projects that are more cost-efficient. The U.S Department of Energy’s National Renewable Energy Laboratory (NREL) estimates that at least 2 contiguous hectares are needed per MW for such solar projects. However, discussions with developers suggest that the NREL land estimates are slightly low and that, in practice, projects usually require as much as 10 per cent additional land to accommodate actual conditions.
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Table 3 Solar Project Land Usage
PV TYPE Hectares/MW
Fixed polycrystalline 2.02
Fixed thin film 2.83
Single-axis polycrystalline 3.23
Source: NREL’s 2012 study, p. 13. Note: As the efficiencies of thin film have improved, the difference between the amount of land needed for a fixed polycrystalline solar facility and for a fixed thin film solar facility is narrowing.
In areas that have physical characteristics that make them advantageous for both wind and solar, it is theoretically possible to site these resources side by side and limit the land use but take maximum advantage of both resources. This has been proposed primarily for areas that are transmission constrained but where the two resources’ generating profiles would not generally overlap—that is, the wind blows primarily at night and solar, of course, generates exclusively during the day. The actual mechanics of controlling both resources to avoid generation overlap and line overload has so far outweighed the potential for combining their use in most situations.
3.3.2 CONSTRUCTION
Construction of a solar power site is site specific as it relates to the type, size and location of the proposed facility. In general however the construction of a typical solar power site will consist of the following phases:
• Mobilisation, including demarcation of the site boundary if practical, erection of temporary fencing or other suitable measures to protect adjacent sensitive habitats, and creation of a construction compound for off-loading materials and components and to accommodate temporary site offices and welfare facilities; • Creation of suitable access to site boundary; • Site clearance including any tree/shrub felling to allow construction of new tracks, stripping of vegetation, top and subsoil, and creation of soil storage areas; • Site grading. • Excavation of cable trenches and laying of electricity and communications cables; • Construction of array foundations, central control building, storage buildings, switchgear and metering; • Securing the PV panels onto the arrays;
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• Construction of substation/grid interconnection; • Installation of monitoring equipment/meteorological station; and • Site restoration.
3.3.3 COMMISSIONING, OPERATION, AND MAINTENANCE
Once construction is complete, the solar plant is commissioned. Commissioning involves standard tests for electrical infrastructure and the solar PV panels.
Once established, the operation and maintenance at a utility-scale PV facility is minimal. Routine maintenance includes washing the arrays to remove dust and inspecting the connections between arrays. If ground cover has been added to avoid erosion, there may be a need to monitor and cut the vegetation to avoid overgrowth and shading of the cells. Generally, facilities are fenced to limit the ability of thieves to access the facilities and steal the cabling. This is especially a consideration if copper cable is used and if that commodity is highly marketable.
More sophisticated facilities monitor the output of individual arrays to spot cell failures. Typically, facilities function with no or minimal staff on site.
3.3.4 DECOMMISSIONING
The projected operational lifetime of a typical solar plant is 25 to 30 years. After this period there are two options, repowering the site and replacing the solar PV panels or decommissioning the site, removing the arrays and other major structures and reinstating the site.
Prior to decommissioning, a decommissioning method statement, detailing or how the site will be restored is usually prepared and approved by the relevant authorities.
The above ground structures would be removed manually. Footers for the arrays would be removed and the voids backfilled with appropriate materials to support the land use at that time. Underground cables and deep concrete foundations are usually left in place as removal is likely to cause more disruption than leaving them in-situ. However, if techniques exist at that time to allow sensitive removal then these will be appraised and considered. Surface vegetation or soil make-up is also to be restored. As with the turbines the electrical control building and internal equipment is removed and reused or recycled where possible.
3.4 DEVELOPMENT COSTS
As noted previously, the cost for solar cells has dropped dramatically over the last several years, driven primarily by reduced costs of solar cells and
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resulting modules. NREL cites a Paula Mints study from 2010 showing global PV modules had decreased in price by $1.36 per watt from 2008 to 2010, but this data, showing a 1/3 cost decrease, is already dated. Table 4 shows the recent pricing trends for installed costs for each type of project. Extreme site examples are not includes.
Table 4 Estimated Installed Solar Project Costs
PV TYPE Installed Cost Installed Cost US $/kW US $/kW (2010) (2011)
Fixed axis 3,800 2,790
Single axis 4,400 3,370
Source: NREL’s 2012 study, ppg. 25, 33.
In a 2012 study, NREL forecasted a decreased cost to $1.01 per watt by 2020 based on incremental improvements in efficiencies. However, developers suggest that, in some cases, module costs are close to this goal already and that solar cell costs have declined by 80 per cent. Cost of the balance-of-the system has been declining, also, but not as rapidly.
3.5 SUPPLY CHAIN IN KAZAKHSTAN
At present there is little utility-scale solar development in Kazakhstan and therefore the PV and support components industry and its associated supply chain of goods and services is poorly developed.
Silicon is the major component of PV cells and it is plentiful in Kazakhstan, as it is in many places worldwide. In January 2013, it was announced that Astana Solar had opened a PV module production plan in Astana with the ability to create PC up to 60 MW annually, with a planned expansion to 100 MW5. All of the silicon used in this plant is sourced from Kazakhstan. No other facilities are known to exist within Kazakhstan. Worldwide, there is a glut of PV cells and panels, so it is expected that importing them would not be a problem. PV cells are manufactured in neighbouring China and could be imported over land.
The other components for utility scale PV construction are aluminium and steel for racking, electronics equipment including inverters and transformers, and cabling. These are all readily available within Kazakhstan. The
5 http://www.pv-magazine.com/news/details/beitrag/kazakhstan--new-plant-opened-in-astana-as-part-of-larger-pv- project_100009718/#axzz2eVfL6fMI
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technology and ability of the workforce to construct is readily available in Kazakhstan.
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4.0 ENVIRONMENTAL AND SOCIAL CONSTRAINTS
A detailed assessment of environmental and social constraints related to solar (and the other three RES evaluated) is provided in the SER Report. Environmental and social factors that could significantly impact the effectiveness, economic feasibility, and therefore, the siting of these facilities are addressed in Section 3.3 of this RPER. In addition, there are areas of high environmental and/or social sensitivity the proximity of which should also be strongly considered. These environmental and/or social high sensitivity areas are discussed in detail in the SER and are summarized in this section.
• Important Bird Areas/Migratory Birds - There is a potential for birds to become disoriented by reflections from solar PVs, resulting in collisions with ground-based obstacles. Therefore, the siting of solar facilities in Important Bird Areas (IBAs) or near known bird migratory routes should be avoided to the greatest extent possible. Therefore, an additional protective buffer of 5 km should be placed around IBAs. Where siting facilities within an IBA or the buffer area is unavoidable, a more detailed assessment of environmental effects and additional impact mitigation measures will be required.
• Forested Areas - Potential solar sites in forested areas would be discouraged given the relative lack of this habitat and the abundance of un-forested areas throughout the country. When siting facilities within a forested area is unavoidable, a more detailed assessment of environmental effects and additional impact mitigation measures will be required.
• Protected/Designated Lands - Potential solar sites in or near other areas afforded legal protection, including National Parks, and preserved lands would be discouraged given the relative lack of this habitat and the abundance of un-forested areas throughout the country. When siting facilities within a protected/designated area is unavoidable, additional impact mitigation measures will be required.
• Surface Water Quality - Due to clearing, grading, trenching and foundation construction for the solar power plant components, there is a potential for soil erosion during construction. Due to this potential, if solar power facilities are located within 1 km of a surface water feature (e.g., intermittent or perennial stream, lakes, or ponds), a more detailed assessment of environmental effects and additional impact mitigation measures will be required.
• Cultural heritage - Special care should be taken to avoid siting solar facilities at or within the viewshed of known or tentative UNESCO World Heritage sites due to the global uniqueness of these areas.
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Special care should also be taken to avoid placing solar facilities on or near locally-registered cultural heritage sites. Given the low actual elevation of potential solar arrays and the need for generally flat terrain, the viewshed for solar arrays is somewhat limited. Therefore, a viewshed buffer of 5 km should be placed around known or tentative UNESCO and national heritage features for solar facility development. When siting facilities within a viewshed buffer is unavoidable, a more detailed assessment of environmental effects and additional impact mitigation measures will be required. Cultural heritage features themselves would be considered exclusion zones.
• Material Assets/Social - Airplane or helicopter pilots can become disoriented by potential reflection of light off solar PVs near airports. Therefore, special measures should be taken to avoid siting facilities near airports and a buffer of 5 km should be placed around airports. When siting facilities within a buffer is unavoidable, a more detailed assessment of environmental effects and additional impact mitigation measures will be required. Airports themselves would be considered exclusion zones.
• Cumulative effects – Special consideration should be given to the impact of concentrating multiple solar farms in an area with high resource soils. Potentially significant cumulative effects associated with solar are presented in Table 5. Guidance for cumulative impact assessment at the development-specific level is available for RES from a number of different sources. These will be used as required by the Project Implementation Unit to establish the methodology for specific financed projects where there are potential cumulative impacts. A list of the most recent and relevant guidance and research is provided below:
o There was no CIA guidance specific to solar facilities found. UK planning documents available at: http://planningguidance.planningportal.gov.uk/blog/guidan ce/renewable-and-low-carbon-energy/particular-planning- considerations-for-hydropower-active-solar-technology-solar- farms-and-wind-turbines/ indicate that the methodology would be the same as that applied to wind farms.
o Some limited guidance on cumulative impacts associated with visual and landscape effects is provided in: Land Use Consultants, “ An Assessment of the Landscape Sensitivity to On-shore Wind Energy and Photovoltaic Development in Cornwall, Annex 4: Guidance on the Cumulative Landscape and Visual Impact Assessment of Multiple On-shore Wind Energy Developments and Solar PV Developments, prepared for Cornwall Council, April 2011. Available at:
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http://www.cornwall.gov.uk/idoc.ashx?docid=c993ec47- 8c8b-4545-9fba-cd719c7b078d&version=-1
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Table 5 Cumulative effect issues associated with solar power generation and mitigation measures
Valued Geographic Temporal Issue Potential Mitigation Measures Resources Boundary Boundary SOLAR Project Extent of Regional land planning measures to Cumulative loss of agricultural High value construction mapped high limit the siting of locations in high output from facility development soils until value soils value soil areas. demobilisation
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5.0 KAZREFF PROJECT APPRAISAL - ENVIRONMENTAL AND SOCIAL PERFORMANCE REQUIREMENTS
Solar projects funded under KazREFF will be subject to the following environmental and social requirements, as stipulated by EBRD:
• The EBRD’s Environmental and Social Policy (2008) and its associated Performance Requirements. • Applicable requirements of Kazakhstan, including but not limited to those related with environmental impact assessments, environmental permitting, labour, public consultation, resettlement and compensation, occupational health and safety, community health and safety, and emergency response. • Relevant European Union Directives and requirements • International best practices, including those promulgated by other international financial institutions, the International Labour Organisation, and others.
5.1 EBRD REQUIREMENTS
Projects would need to adhere to the EBRD Environmental and Social Policy and its associated Performance Requirements (PR), which cover the following areas:
• PR 1: Environmental and Social Appraisal and Management • PR 2: Labour and Working Conditions • PR 3: Pollution Prevention and Abatement • PR 4: Community Health & Safety and Security • PR 5: Land Acquisition, Involuntary Resettlement and Economic Displacement • PR 6: Biodiversity Conservation and Sustainable Resource Management • PR 7: Indigenous Peoples • PR 8: Cultural Heritage • PR 9: Financial Intermediaries (FI) • PR 10: Information Disclosure and Stakeholder Engagement
Depending upon the scale of KazREFF project, EBRD would require a series of environmental documents to be produced in order to gain EBRD funding. Projects are screened at an early stage and placed into one of the four following categories, depending on the level and type of environmental and social due diligence that is required:
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• Category A projects are those with potentially significant and diverse environmental and social impacts, requiring detailed impact assessments • Category B projects are those with environmental and social impacts that are site-specific and can be addressed through readily available management and mitigation techniques • Category C projects have minimal environmental or social impacts • FI projects are where the EBRD is investing in a Financial Intermediary, such as a bank or equity fund.
This categorization reflects: (i) reflect the level of potential environmental and social effects and issues associated with the proposed project; and (ii) determine the nature and level of environmental and social investigations, information disclosure and stakeholder engagement required for each project, taking into account the nature, location, sensitivity and scale of the project, and the nature and magnitude of its possible environmental and social effect and issues.
Due to the relatively small scale of the potential KazREFF projects, most would likely fall under Category B, as the potential adverse environmental and/or social effects that they may give rise to are typically site-specific, and/or readily identified and addressed through mitigation measures. However, the siting of solar power facilities within or near sensitive/protected areas or in situations where impacts could be more severe may result in these being classified as Category A projects. This determination is made by EBRD and KazREFF in the initial project phases.
5.1.1 CATEGORY A
If a project is considered to be a Category A project, it is usual to expect that it would require the development and disclosure of an Environmental and Social Impact Assessment Package including:
• An ESIA; • A Non-Technical Summary (NTS); • An Environmental and Social Action Plan (ESAP); • A Stakeholder Engagement Plan (SEP); • A Land Acquisition Plan (if land acquisition is required); • A Resettlement Action Plan (if population displacement is required).
Disclosure of these documents generally allows for a 120 day public consultation period, after which the documents are finalized, published, and financing may be secured. In general, the timeframe for completing the environmental and social review process for a Category A project typically takes 9 to 12 months to complete.
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5.1.2 CATEGORY B
If categorized as a Category B project, there are less detailed documentation requirements due to the lesser potential for significant environmental and social impact. EBRD typically requires the development and disclosure of:
• A Project Summary Document; • A Project Fact Sheet or Non-Technical Summary (NTS);
For Category B projects, EBRD also typically reviews, but does not require disclosure of:
• An Environmental and Social Action Plan (ESAP); • A Stakeholder Engagement Plan (SEP); • An Environmental and Social Due Diligence (ESDD) document that demonstrates compliance with PR1
Disclosure of these required documents generally allows for a 30 day public consultation period, after which the documents are finalized, published, and financing may be secured. In general, the timeframe for completing the environmental and social review process for a Category B project typically takes 3 to 6 months to complete.
5.2 KAZAKHSTAN REQUIREMENTS
Specific requirements for EIA procedures for all categories of economic activity are established by the document “Instruction on Environmental Impact Assessment at the Development of Prior Planned, Planned, Prior Project, and Project Documentation”. This guide contains:
• A list of activities which require implementation of the EIA procedure in full;
• A list of activities for which the full EIA procedure is proposed to the State Environmental Expertize (SEE) on the basis of preliminary expertise or by applying a set of criteria determined in normative documents; and
• A list of activities with insignificant environmental impact, for which only the preparation of an "Environmental impact statement" is sufficient for submission to the SEE.
Projects in Kazakhstan are classified by the Sanitary and Epidemiological Services (SES) of MOH according to five danger levels with one being the highest as defined by norms and standards in relation to human health and safety. The sensitivities of projects are measured by the SES Danger/Sanitary Categories. The categories are:
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• Danger/Sanitary Categories 1 & 2 projects have levels of severity/danger that trigger a full EIA. • Danger/Sanitary Category 3 projects are considered to have lower levels of severity/danger and as such a lesser assessment is undertaken, although still referred to as an Environmental Assessment. • Danger/Sanitary Category 4 & 5 projects are considered to present considerably lower risks of severity/danger and generally do not warrant an assessment beyond the initial screening.
The SES Danger/Sanitary Categories relate to four categories of RoK EIA (Оценка воздействия на окружающую среду - OVOS). The EIA/OVOS Categories are:
• Category I - Sanitary Class/Danger Categories 1 and 2 plus investigations and extractions of minerals, except for common minerals. Risks are high and approval by MOEP is required. A Category I EIA/OVOS is categorically required obligatory for large scale including road construction project with four lanes or more. • Category II - Sanitary Class/Danger Category 3 plus extractions of ubiquitous minerals, forestry activities and special uses of water. Risks are ranked as Medium High and approval is required from TEPO(s). • Category III - Sanitary Class/Danger Category 4 Risks are ranked as Low and approval is required from TEPO(s). • Category IV - Sanitary Class/Danger Category 5 plus projects involving animals, except recreational fishing and hunting. Risks are ranked as Low and approval is required from local administrations.
SEE reviews are conducted at end of each stage in the process and before proceeding to the next stage. Reviews are conducted first at the Oblast level and then by MEWR and other agencies as appropriate to the nature of the Project and the level of EIA Categorization. Under Kazakhstan regulations, the EIA process has three stages:
• Preliminary EIA (Environmental Impact Assessment - Pre-OVOS)
• Preparation of the EIA (OVOS). EIAs are obligatory for large scale projects.
• Preparation of an "Environmental Protection Section". The Environmental Protection Section is prepared in the detailed design stage in the event that mitigation measures defined in the EIA (OVOS) are required.
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At each stage of the EIA process, the developer is required to prepare an "Environmental Impact Statement", which is a compulsory annex to each EIA document. The "Environmental Impact Statement" must be presented in the package of documents for submission to the SEE for consideration. Reviews are conducted at the end of each stage, first at the Oblast level and the by MEWR and other agencies as appropriate for the project and EIA Category.
Public hearings or public consultations are required at all stages of EIA. The detailed requirements for public participation are reflected in the Environmental Code, Articles 57 and 60-67 and the “Rules of access to environmental information relate dot EIA procedure and decision-making process on intended economic and other activity”. Minutes from these hearings are filed as part of the EIA documentation.
The process provides for a preliminary review period of two weeks and a final review period of up to 90 days after which the EIA authors are required to defend the EIA at a consultation session with all stakeholders in attendance (usually not the general public). Once complete, the EIA is revised; a final document is prepared; and a formal OVOS certificate is issued to the Proponent, but usually only after another 30-day waiting period, allowing for any additional comments. This certificate allows the project to proceed with other approvals that may be required. Based on this information, it may take up to a year to complete the EIA process in Kazakhstan.
Based on additional guidance provided in the RoK EIA regulations, it is likely that solar power projects (and in fact, all RES projects) would be considered Category II and would require Category II EIA/OVOS documentation. However, the siting of solar power facilities within or near sensitive/protected areas may result in these being classified as Category I projects. This determination is made by MoE at the preliminary EIA stage.
The OVOS process was evaluated against EBRD Environmental and Performance Standards to identify gaps areas that may not be satisfied by the OVOS process. This gap analysis is provided in Appendix A.
5.3 KAZREFF APPRAISAL PROCESS
All projects considered for financing through KazREFF will under a detailed appraisal process in order to:
• Determine each project’s ability to meet EBRD environmental and social performance requirements; • Determine each project’s ability to meet EBRD RoK EIA regulations • Ensure that projects are technically feasible (part of technical due diligence)
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• Identify significant issues and constraints that may negatively impact KazREFF’s ability to finance each project from an environmental and social perspective • Provide simplified guidance and resources to project proponents (and their environmental consultants) in order to more easily comply with EBRD and Kazakh requirements
The appraisal process will be developed and implemented by the Project Implementation Unit.
5.3.1 INITIAL SCREENING
The appraisal process includes an initial screening of the project proposal against the criteria presented in this RPER, the SER report, and consideration of key environmental and social issues. This initial screening is conducted after the project proponent completes the Environmental and Social Issues Checklist – Solar provided in Appendix B. This checklist includes identification of key environmental and social issues related to solar (and cumulative impacts) and is reviewed by KazREFF’s environmental and social review team. Based on the review of the checklist, the project’s EBRD category will be determined and specific documentation requirements will be communicated to the project proponent.
Once the EBRD requirements have been identified, KazREFF environmental and social review team will provide support to project proponents to comply with the Kazakh EIA regulations. In general, information gathered through the initial screening process can be useful in developing the preliminary EIS documentation required for the initial stage of the Kazakhstan EIA.
5.3.2 DOCUMENTATION REVIEW AND APPROVAL/FEEDBACK
Based on the initial screening and categorisation, the project proponent will then be expected to complete the preparation of required documentation.
Templates for the typical documents expected to support solar projects (under Category B) are provided in Appendix C and include templates for the NTS (Appendix C.1), the SEP (Appendix C.2), and the ESAP (Appendix C.3). If a project is determined to be a Category A project, an ESIA would be required. Due to the very specialized nature of an ESIA, an ESIA template has not been provided. However, information in the SER report will be extremely useful to identify information necessary for the preparation of these documents. The information in the SER identifying the environmental baseline, the anticipated effects, and mitigation strategies should also be very useful to inform the Kazakh EIA.
All projects will be expected to comply with EBRD PR1 through 10. Important information for assessing the significant environmental and social
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effects and avoidance, minimization, and/or mitigation of those effects is provided in the SER.
The required documents will be submitted to, and reviewed by, KazREFF environmental and social review team. The KazREFF environmental and social review team will work with the developer to ensure submitted information is sufficient to demonstrate compliance with EBRD’s PRs.
In addition, KazREFF environmental and social review team will review the progress of the Kazakh EIA and can, if requested, provide technical input and guidance on the process and content. KazREFF environmental and social review team will request updates from the project proponent on the progress of the project through the Kazakh EIA stages until final approval is received.
Once the required environmental and social documentation for KazREFF review has been found to be in compliance with the EBRD and the final Kazakh EIA is approved, KazREFF environmental and social review team will reflect that in the Project Screening Report.
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6.0 APPENDICES
A – Gaps between EBRD PR for ESIA and Kazakhstan EIA Requirements
B – Environmental and Social Issues Checklist - Solar
C – Environmental and Social Templates
C.1 – Non-Technical Summary (NTS)
C.2 – Stakeholder Engagement Plan (SEP)
C.3 – Environmental and Social Action Plan (ESAP) – Solar
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Kazakhstan Renewable Energy Financing Facility (KazREFF) - Strategic Environmental Review
Appendix A – Gaps between EBRD PR for ESIA and Kazakhstan EIA requirements
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Appendix A: Gaps between EBRD PR for ESIA and Kazakhstan EIA requirements
EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement PR 1: Environmental and All EBRD-financed projects undergo The EIA is obligatory for all sectors of None Social Appraisal and environmental and social appraisal economic and other activities that may Management directly or indirectly impact the environment and public health.
The EIA process is performed on the strength of commitment, integration (magnitude), alternative, adequacy, preservation, compatibility, flexibility, and public participation.
Categorization and EIA magnitude Economic activities subjected to the EIA None procedure are categorized as I, II, III, and IV, The EBRD categorizes proposed projects as “A”, of which categories I and II cause major “B”, and “C”. impacts on the environment. A project is classified as Category A when it could result in potentially significant and diverse According to the requirements, there is the adverse future environmental and/or social list of projects (economic activities) for impacts and issues which, at the time of which the EIA is recommended to be categorization, cannot readily be identified or performed in full (for example, oil industry assessed and which require a formalized and and crude oil refineries, thermal power participatory assessment process carried out by stations, chemical installations, pipelines independent third party specialists in accordance for transport of gas, oil or chemicals, etc.) with the PRs (Appendix 1 to the EBRD ESP). and the list of projects (economic activities) for which the requirements to carry out a A proposed project is classified as Category B comprehensive assessment are imposed by when the potential adverse environmental and / State review authorities on the basis of a or social impacts that it may give rise to are preliminary review or by applying
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement typically site-specific, and/or readily identified thresholds defined by regulations and addressed through mitigation measures. (agriculture, forestry, mining industry, These impacts could be from past, current or power industry, wind farms, etc.). future activities. Due diligence requirements may vary depending on the project and will be agreed with the EBRD on a case-by-case basis, in accordance with PR 1.
A proposed project is classified as Category C when it is likely to result in minimal or no adverse environmental or social impacts and therefore requires no further environmental and social appraisal beyond categorization.
Based on the KazREFF SER, it is anticipated that most funded projects will fall within Categories B or C. EIA stages The EIA process comprises the following None stages: 1) preliminary EIA (stage 1); 2) EIA that is performed for a complete and comprehensive analysis of potential effects of the project or further economic and other activities, substantiation of alternatives, and development of an environmental management plan (programme) (stage 2); 3) “Environmental Protection” section that constitutes part of the design documentation and contains engineering solutions aimed at prevention of adverse
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement impacts on the environment (stage 3).
The EIA format, completeness of studies, scope of used documents, levels and degree of detail of environmental scientific & design surveys depend on the design stage as well as on magnitude and intensity of impacts caused by projected economic and other activities on human health and environment.
EIA is an integral part of pre-design and design documents. Preliminary environmental and social assessment Through Pre-EIA activities, the potential None (Pre EIA) trends of changes in environmental and socioeconomic components as well as Through appraisal activities, the client will impacts on both the society and consider in an integrated manner the potential environment are identified. environmental and social issues and impacts associated with the proposed project. The No need in computations of the pollution appraisal process will be based on recent level for certain environmental information, including an accurate description components (air, soils, water, subsoil and delineation of the client’s business or the resources). project, and social and environmental baseline data at an appropriate level of detail. The Pre-EIA documents are disclosed for public appraisal should also identify applicable laws and by a project initiator. regulations of the jurisdictions in which the project operates that pertain to environmental Pre-design appraisal documents (business- and social matters, including those laws plans, feasibility studies) and main pre- implementing host country obligations under design documents such as “Investment international law (for example, commitments substantiation” and Pre-EIA documents are
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement related to land use planning and protected area submitted to the State Environmental management). Review (SER).
A positive Conclusion issued by the SER in favour of the project initiator, serves as a guide for making decisions to initiate designing of specific facilities and structures in accordance with the most rational option selected in the course of Pre-EIA development. Environmental and Environmental and social impacts and issues will The EIA process comprises an assessment None social appraisal (EIA) be appraised in the context of the project’s area of impacts on: mechanism of influence. Environmental and social issues and impacts will also be analysed for the relevant • atmospheric air stages of the project cycle. These may include • water resources; preconstruction, construction, operations, and • subsoil resources; decommissioning or closure and reinstatement. • industrial and domestic waste; Where relevant, the appraisal will also consider • physical impacts; the role and capacity of third parties, such as • lands and soils; local and national governments, contractors and • flora; suppliers, to the extent that they may influence • fauna; the project, recognizing that the client’s ability to • socioeconomic environment; address these risks and impacts will depend on its • environmental risks from planned control and influence over the third party actions. activities in the region The appraisal will also consider potential trans-
boundary and global issues, such as impacts from A project initiator discloses EIA documents effluents and emissions, increased use or for the public. contamination of international waterways, greenhouse gas emissions, climate change mitigation and adaptation issues, and impacts on endangered species and habitats.
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement
PR 2: Labour and At a minimum, the client’s human resources Labor relationship in the Republic of Labor relationship issues Working Conditions policies, procedures and standards shall be Kazakhstan is regulated by the Labor Code are not reflected in typical designed to: establish and maintain a sound and it does not constitute part of the EIA Kazakh EIA documents. This worker-management relationship; promote the process. would be a gap if not fair treatment, non-discrimination and equal addressed in a project- opportunity of workers; promote compliance Issues related to labor and working specific ESMP. with any collective agreements to which the conditions and safety are considered in the client is a party, national labour and employment “Environmental risk assessment in laws, and the fundamental principles and key connection with planned activities in the regulatory standards embodied in the ILO region” section. conventions that are central to this relationship; protect and promote the health of workers, especially by promoting safe and healthy working conditions.
PR 3: Pollution The client will avoid the release of pollutants or, Measures aimed at prevention and None Prevention and when avoidance is not feasible, minimize or abatement of environmental pollution are Abatement control their release. This applies to the release specified in EIA documents (“Atmospheric of pollutants due to routine, non-routine or Air”, “Water Resources”, and “Waste” accidental circumstances with the potential for sections). These measures provides for local, regional, or trans-boundary impacts. In introduction of low-waste and waste-free addition, the client should examine and technologies and special measures on i) incorporate in its operations energy efficiency prevention (abatement) of air emissions; ii) measures and measures to conserve water and adverse impact mitigation; iii) air quality other resources, consistent with the principles of monitoring; iv) amounts and chemical cleaner production. The client will avoid or composition of wastewater discharges; v) minimize the generation of hazardous and non- substantiation of the introduction of water hazardous waste materials and reduce its circulating systems and wastewater reuse harmfulness as far as practicable. systems, recycling of sludge from wastewater treatment facilities; vi)
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement groundwater protection against pollution and depletion; and vii) recommendations related to recycling, treatment and disposal of all types of waste and waste recycling/waste disposal technologies. PR 4: Community Health Requirements relating to: infrastructure and EIA documents comprise a section titled None & Safety and Security equipment safety; hazardous materials safety; “Assessment of environmental risks for the community exposure to disease; emergency environment and community health in preparedness and response; and security connection with planned economic personnel requirements. These requirements are activities”. This section contains i) focused on avoidance or prevention of risks and recommendations on prevention of and impacts rather than their minimization and response to emergencies; ii) consideration mitigation. of emergency probability; sources and kinds of emergencies and frequency of their occurrence as well as forecasts of their impacts on the environment and community. PR 5: Land Acquisition, The following requirements are considered in the Issues related to land acquisition and Kazakhstan EIA regulations Involuntary course of project design: carrying out of involuntary resettlement are regulated by do not contain Resettlement and consultations; grievance mechanism; the Land Code of the Republic of requirements related to Economic Displacement resettlement planning and implementation; Kazakhstan. But the Pre-EIA documents to land acquisition, Resettlement Action Plan; livelihood restoration be submitted to the SER for reviewing involuntary resettlement framework; compensation and benefits for should contain a copy of document for the and economic displaced persons; displacement; physical right of land use in the subject territory. displacement. displacement; economic displacement; and loss of public amenities. PR 6: Biodiversity Through the environmental and social appraisal The EIA process also includes an None Conservation and process, the client will identify and characterize assessment of impacts on vegetation in the Sustainable Resource the potential impacts on biodiversity likely to be project influence area (the presence of Management caused by the project. The extent of due diligence medicinal herbs; rare, endemic and Red should be sufficient to fully characterize the risks Data Book-listed plat species), green space
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement and impacts, consistent with a precautionary condition; forecasted changes of the approach and reflecting the concerns of relevant vegetation cover in the project stakeholders. The client will seek to avoid implementation area and impacts of these adverse impacts on biodiversity. changes on life and health of local communities; recommendations for conservation of vegetation communities, improvement of their condition, flora conservation and revegetation; recommendation for vegetation monitoring, etc.
Furthermore, the EIA documents contain a baseline assessment of aquatic and terrestrial fauna (the presence of rare, endangered and Red Data Book-listed fauna species); measure to conserve and reproduce the integrity of natural communities and species diversity of aquatic and terrestrial fauna; food potential improvement; a wildlife monitoring programme. In addition, the presence of natural territories and landmarks under special protection in the territory of potential construction operations is considered. PR 7: Indigenous In projects where Indigenous Peoples are likely to The Kazakhstan legislation does not specify The Kazakhstan EIA Peoples be affected, the client is required to carry out an requirements related to Indigenous procedure does not assessment of impacts on Indigenous Peoples. Peoples consider issues related to Depending upon the outcome of this, the client is Indigenous People. expected to first avoid adverse effects and where However, this is not this is not feasible, to prepare and Indigenous typically an issue in
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement Peoples’ Development Plan so as to minimize Kazakhstan, where there is and/or mitigate any potential adverse impacts. no indigenous population. The client is also expected to implement a specific grievance mechanism and determine appropriate modalities for compensation and benefit-sharing.
PR 8: Cultural Heritage At an early stage of the environmental and social EIA documents contain a section devoted None appraisal, the client should identify if any cultural to territories, landmarks and sites under heritage is likely to be adversely affected by the special protection. Cultural heritage is project, and assess the likelihood of any chance regulated by the RK Law “On Protection finds. The client will ensure that provisions for and Use of Historical and Cultural Heritage managing chance finds, defined as physical Sites and Objects” dated July 2, 1992. cultural heritage encountered unexpectedly Companies, institutions, organizations, during project implementation, are in place. Such educational institutions, public provisions shall include notification of relevant organizations and individuals will support competent bodies of found objects or sites; an authorized relevant body in alerting project personnel to the possibility of implementation of measures aimed at chance finds being discovered; and fencing-off protection, preservation and use of the area of finds to avoid any further disturbance historical and cultural heritage sites. or destruction.
PR 9: Financial Not applicable Not applicable Not applicable Intermediaries (FI)
PR 10: Information “Information Disclosure and Stakeholder Public opinion is given proper weight in the Kazakhstan requirements Disclosure and Engagement” specifies requirements relating to process of EIA development. Public opinion do not specify a detailed Stakeholder stakeholder identification, development of a consideration format depends on the procedure for stakeholders Engagement Stakeholder Engagement Plan, information significance of planned economic activities identification and disclosure, meaningful consultations, and and the extent of project influence on the engagement or the grievance mechanism. environment and community health; much grievance mechanism
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement depends on stakeholders. The procedure procedure. and dates of public consultations is regulated by environmental supervisory authorities.
Public opinion is mainly considered through public consultations. The results of public consultations are recorded in the form of a report where all key issues and disagreements between stakeholders and a client are recorded. Stakeholders’ comments and proposals are considered in design documents. Written proposals and comments from stakeholders (as an independent form of public opinion consideration) are collected for individual less significant projects of economic activities. At subsequent stages of project design, the procedure of public opinion consideration can be carried out through collection of written proposals and comments in respect of EIA findings for a certain industrial operation.
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Kazakhstan Renewable Energy Financing Facility (KazREFF) - Strategic Environmental Review
Appendix B – Environmental and Social Issues Checklist - Solar
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Please read this before completing the questionnaire: 1. This questionnaire is the first stage in the Bank’s environmental and social due diligence process. The more comprehensive the answers given, the less need will there be for the Bank to request further information. Please, therefore, try to answer the questions as fully and openly as possible. 2. The questionnaire makes reference to both “the Project”, the business activity for which EBRD funding is sought, and “the Company”, which is the corporate entity that is ultimately responsible for the Project. The Project may affect the whole Company or may only relate to one element within the Company. The Bank needs to understand both issues related to the Project being financed by the Bank and the impacts and issues associated with the Company as a whole. 3. There are a number of questions where further information is requested if a positive response is given. Additional information can be provided either in the questionnaire’s boxes or in separate documents.
PROJECT NAME: PROJECT LOCATION: Map Provided? Yes / No Company Name: Company Address: Country: Town/Location: Business Sector/Activities: Person completing questionnaire:
Name: Title: Date: Telephone: Mobile: E-mail:
Company authorised representative (e.g. Environmental Manager): I certify that, to the best of my knowledge and belief, the information contained in this questionnaire accurately represents current or future operations.
Signature:
Title: Date:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE COMPANY PROFILE
A) Ownership: • Private ownership %: ______• Public ownership %: ______B) Year of foundation: ______
C) Sector of operation and main products: ______
D) Describe the main activities of the Company and its holdings including any solar photovoltaic or other renewable energy projects (include a description of the corporate structures and controls that are used to manage/oversee individual projects, including this one):
PROJECT DESCRIPTION
A) Technical information: Start of construction (planned date) Start of operation (planned date) Installed capacity (MW) Annual net generation (MWh) Type of solar photovoltaic panels (eg fixed tilt or axis-tracking; crystalline or thin-film?) Are data on solar irradiation available (yes/no) Solar irradiation measuring period (start date / end date) Daily average of solar irradiation at Project site (kWh/m2) Distance to interconnection grid (km): Voltage level of interconnection grid (kV): Voltage level of overhead line to interconnection point (kV): Land area required (m2)
B) Status of project development: yes no
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE The project is still in its conceptual phase (we have only a project idea)? Technical design has started? Technical design is completed? Quotations / proposals from equipment suppliers have been received?
C) Summary of information on Environmental Impact Assessment: Is Environmental Impact Assessment (EIA) required? (yes/no) Has EIA been completed? (yes/no) If EIA is available, has it observed any adverse environmental impacts? If yes, describe them and any associated mitigation measures in Section 1b. If EIA is required but not available, when will it be completed?
D) Siting, design and key environmental and social considerations:
1. Describe the Project and provide a map showing its components, including the solar panel infrastructure (photovoltaic modules, inverters, racking transformer and sub-station (and approximate layout)), roads, transmission lines, grid connections and other required facilities. 2. How were environmental and social issues incorporated into the siting and design optimisation process (see also questions under PR1 and PR6 below)? 2.1 What studies have been completed relating to potential impacts on local communities and other land-users? 3. Solar resource issues – please describe: 3.1 Understanding of the operational regime for each facility and for operations in tandem; 3.2 Solar resource measurements and other meteorological data and monitoring information; 4. How have climate-change related variables been accommodated? PR1 - Environmental and Social Appraisal & Management Environmental and Social Appraisal 1.a Has the Company made an assessment of the Yes: No: environmental and social impacts of its operations? If yes, please provide a summary of that assessment: 1.b Has an Environmental and Social Impact Assessment Yes: No:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE (ESIA) been completed for this Project? If yes, please summarise the conclusions of the ESIA, including required/recommended mitigation, and send a copy/summary: 1.c Have relevant discussions been held with Yes: No: environmental regulators on the ESIA for the Project? If yes, please summarise: 1.d Is there an Environmental and Social Action Plan (ESAP) Yes: No: for the Project construction, operation and If yes, please summarise: decommissioning? 1.e Have any site investigations been performed to check Yes: No: the suitability of the site and characterise If yes, please provide a list of the studies: environmental and social baseline conditions, such as soil, water quality and groundwater testing, slope stability, survey for flora and fauna including bat, bird and water species, or the situation of nearby communities? 1.f What are the relevant Company’s Corporate Social Responsibility Standards? 1.g What processes are in place to manage environmental issues (such as the presence of sensitive species)? 1.h Will / does the Project involve significant excavations, Yes: No: demolitions, movement of earth, flooding or other If yes, please provide details: changes in the physical environment? 1.i What soil erosion/sedimentation mitigation/control procedures will be in place for the construction and operational phases of the Project? Environmental Management 1.j Who is responsible for environmental management at Name/title: the Company? Phone/mobile: Email:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE Who is responsible for social management / community Name/title: relations at the Company? Phone/mobile: Email: Who is, or will be, responsible for environmental Name/title: management for the Project? Will that person be on- Phone/mobile: site during construction and operation? Email: Who is, or will be, responsible for social management / Name/title: community relations for the Project? Will that person Phone/mobile: be on-site during construction and operation? Email: 1.k Does the Company have an Environmental and Social Yes: No: Management System (ESMS)? If yes, is the ESMS compliant with any internationally Yes: No: recognised systems such as ISO 14,001, OHSAS 18,001, SA 8000 or EMAS? 1.l Does the Company periodically prepare a summary Yes: No: report on environmental performance (or If yes, please provide a copy of the most recent report(s) sustainability) for shareholders, stakeholders, or others? How often? 1.m Does the Company routinely provide environmental Yes: No: training for Company personnel? If yes, please describe the training provided: Will the Company train workers for the Project? For Yes: No: construction and/or operation? If yes, which workers will be trained? What kind of training? Contractor management 1.n Will the Company use contractors during the Yes No construction and/or operational phases of the Project? If yes, please provide details: 1.o Are prospective contractors required to submit Yes No environmental, health and safety, and/or labour
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE information with bid documents (that is, do solicitations for proposals require such information)? 1.p Is a contractor’s past EHS performance considered Yes No during evaluation of bids? If yes, please describe how (including whether it is used as a pass/fail factor or as part of the overall score: 1.q Does the Company monitor performance of its Yes: No: contractors regarding environmental, health and safety, If yes, how often? How does the Company deal with poor and labour/human resources? performance? 1.r How will the contractors be managed to ensure they have processes in place to anticipate and respond to emerging risks and opportunities, associated with the Project? PR 2 – Labour and Working Conditions 2.a Who is responsible for Human Resources (HR) Name/title management at the Company? Phone/mobile: Email: 2.b Does the Company have written HR policies setting out Yes: No: its approach to managing its workforce? 2.c Are all workers provided with written information Yes: No: about their terms and conditions of employment? 2.d Has the Company ever been found in violation of any Yes: No: country’s labour and/or social security laws? If yes, please describe the circumstances Have these resulted in any penalties, fines, major Yes: No: recommendations or corrective action plans? If yes, please describe: 2.e Are employees free to form, or join, a workers’ Yes: No: organisation (e.g. a trade union) of their choosing? What percentage of the workforce belongs to such an organisation?
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE 2.f Is the Company covered by a collective bargaining Yes: No: agreement? 2.g How does the Company interact with workers’ organisations and provide information to them? 2.h Does the Company have a grievance mechanism which Yes: No: allows employees to raise workplace concerns? If yes, please describe: How many grievances were received from employees Number: during the previous year? Please summarise the issues raised in grievances and how the company has addressed them: 2.i Have there been any strikes or other collective disputes Yes: No: related to labour and working conditions at the If yes, please describe the nature of the dispute and how it was Company in the past three years? resolved: Have there been any court cases related to labour Yes: No: issues? If yes, please summarise contested issues and outcome: Have there been any other significant labour issues Yes: No: raised by the media or by non-governmental organisations? If yes, please describe: 2.j Are there policies or terms and conditions covering Yes: No: employment of young persons under age 18? If yes, please describe What is the minimum legal working age? How does the Company verify the age of employees? Does the Company apply any restrictions to the tasks Yes: No: that can be done by younger workers? If yes, please describe: 2.k Are employees free to leave the premises when they Yes: No: are not required to work or with appropriate due cause? Does the Company retain any identity documentation Yes: No:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE from the employees? If yes, please explain which documents and why: Are employees free to resign from their jobs? Yes: No: If yes, please describe the notice and other procedural requirements? 2.l Does the Company have a policy for setting wages? Yes: No: How do the Company’s wage levels compare to comparable employers in your sector? 2.m Does the Company anticipate any redundancies or Yes: No: retrenchment in the next three years? If yes, please describe and explain the reason(s): 2.n Does the Company have policies or terms and Yes: No: conditions covering non-discrimination and equal If yes, please describe: opportunities in employment? 2.o Are any criteria other than compliance with job Yes: No: requirements (e.g., gender, ethnicity, nationality, If yes, please specify those criteria: religion, political or trade union affiliation) applied for recruitment / promotion / access to training / benefits? 2.p How many workers does the Company employ? Please provide numbers for men and women separately. How many are...: Direct: Seasonal: Full-time: Part-time: How many sub-contractors does the Company employ and what is the role of these sub-contractors? 2.q Will there be employment opportunities for local Yes: No: stakeholders? If yes, please describe these opportunities: How many non-skilled workers will be employed for the Construction: Operation: Project during construction and then operation? How many non-skilled workers are expected to be Near-by areas: Within the Country: recruited from nearby areas? From the country? What proportion of managers and skilled workers are Near-by areas: Within the Country:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE expected to be recruited from nearby areas? From the country? Occupational Health and Safety 2.r Who is responsible for health & safety management at Name/title: the Company and/or Project? Phone/mobile: Email: Is there an emergency response plan for dealing with Yes: No: natural disasters, such as earthquakes? (This is also relevant to PR-4 Community Health, Safety and If yes, please describe and provide a copy: Security) Is there sufficient information to confirm that Yes: No: construction will not result in land slips or other environmentally damaging incidents? (This is also If yes, please describe: relevant to PR-4 Community Health, Safety and Security) 2.s Does the Company have a Health & Safety Yes: No: Management System? Is the system compliant with an international health & Yes: No: safety standard such as OHSAS18001? 2.t Is the Company compliant with national requirements Yes: No: for health & safety? 2.u Is there a current Health & Safety Action Plan for the Yes: No: Company? If yes, please provide a copy of the latest update. Do project-specific health and safety plans (typically) go Yes: No:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE If yes, please summarise (typical) differences: 2.v Does the Company keep any statistics on Yes: No: • Fatalities; If yes, please provide health and safety statistics for the last three • Lost time accidents; years of operations. • Lost workdays resulting from incidents; and/or • Total staff hours worked? 2.w Have any Company operations been cited for violations Yes: No: of national or other health and safety standards and If yes, please summarise the circumstances and the outcome procedures in the last 3 years? 2.x Is there (or will there be) a Health and Safety Plan for Yes: No: this Project? If yes, please describe what it covers (or will cover)?
Will workers be required to undergo health and safety Yes: No: training? If yes, please indicate how often and what type(s) of training 2.y How does the Company ensure that workers employed by its contractors, sub-contractors or labour agents are protected by the same labour and health and safety standards as those that apply to the Company’s own employees? PR 3 – Pollution Prevention and Abatement Environmental Compliance 3.a In the last 3 years, has the Company been cited for any Yes: No: violations of environmental permits or regulations? If yes, please describe circumstances and outcomes: 3.b Has the Company applied for, and/or received, the Yes: No: required environmental permits and licences to Please list required permits and licenses, and their status (issued, construct the Project? To operate? applied for, etc.) Construction: Operation: 3.c Which agencies and authorities will be primarily responsible for overseeing environmental performance
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE of the Project? Air Emissions 3.d Does the Company produce air emissions? Yes: No: If yes, please describe the main sources, types and quantities of air emissions produced by the company: 3.e Please describe any measures taken to reduce emissions and prevent air pollution. 3.f Please provide monitoring data for total air emissions. Water Use 3.g What will be the main sources of water for the Project during construction and operation? How much water will the Company use at each phase of the Project? Have permits been issued? Yes: No: Will any water require treatment prior to use? Yes: No: If yes, please describe use, amount to be treated and treatment method: Wastewater Discharges 3.h What are the sources, types and quantities of effluent discharges that will produced by the Company during the Project? 3.i How much wastewater will be generated during Construction: Operation: construction and operation? How will wastewater be managed and discharged? Is any wastewater treatment required prior to Yes: No: discharge? If yes, please describe: Solid Waste Management 3.j What are the types and quantities of solid wastes ERM 56 KasREFF SER RPER SOLAR – June 2014
ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE produced by the Company? How are these wastes disposed of? 3.k Are any hazardous wastes produced and how are these Yes: No: stored and disposed of? If yes, please describe: 3.l Does the Company implement any measures to reduce Yes: No: / reuse / recycle any solid wastes at its facilities? If yes, please summarise: Are contractors required to implement these Yes: No: measures? Hazardous Material Management 3.m What hazardous materials will used by the Company in the Project (such as flammable, explosive, reactive, radioactive and toxic substances) and in what quantities? What measures and procedures are in place for the handling and storage of such materials? 3.n Has the Company suffered any environmental incidents Yes: No: or accidents (such as spills, tank ruptures, explosions, If yes, please describe: etc.) during the previous three years at any of its facilities? 3.o Does the Company prepare Environmental Incident Yes: No: Reports, or similar, when an environmental accident or If yes, please describe the reporting system and indicate the relevant incident occurs? authorities you report to: 3.p Will fuel or other hazardous materials be stored and/or Yes No used for this Project? If yes, what materials will be used/stored? How much of each? How will they be used/stored? PR 4 - Community Health, Safety & Security 4.a How far are the nearest villages/towns/cities from the Please describe and include a map:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE Project site? How far from the Project site are the nearest occupied
houses and/or workplaces? 4.b Will the Company’s activities pose any material risks to, Yes: No: or have any significant impacts on, the health and If yes, please describe: safety of local communities or people? Yes: No: Has a public health assessment been undertaken? If yes, please describe:
4.c Has the Company developed measures to prevent Yes: No: and/or mitigate any such impacts? If yes, please describe:
4.d Has the Company consulted with locally affected Yes: No: community(ies) and stakeholders to discuss the Project If yes, please describe: and measures to be taken to reduce impacts, in order to understand any concerns and address issues associated with potential public health effects? How have impacts of the project on affected communities (if any) been identified and addressed? 4.e Will there be security guards to control entry to the Yes: No: Project site during construction and/or operation? If yes, will they be armed? How will they be trained? Will security be outsourced to a separate company? Yes: No: If yes, what criteria did the Company use to select the security contractor?
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE PR 5 - Land Acquisition, Involuntary Resettlement and Economic Displacement 5.a Does the Company have a person in charge of land Yes: No: acquisition and/or expropriation? Name: Title: Phone/mobile: Email: 5.b Have any structures or land already been acquired by Yes: No: the Company in connection to the Project? If yes, please provide details. 5.c How much land will need to be permanently acquired by the Company for the Project (including power- generating infrastructure, control centre, roads, transmission lines and other related facilities)? How much land will have to be temporarily occupied (e.g. for storage, access to construction sites, accommodation of workers)? 5.d Has the Company already identified owners and users Yes: No: of affected land and structures (for example, from Land If yes, please provide details: Books, Cadastre or through a field survey)? Have any negotiations with land/structure Yes: No: owners/users or any expropriation procedure been If yes, please provide details: initiated (including request for public interest)? What is the land currently being used for? Will land that is not needed by the Company continue Yes: No: to be used by others (such as land between buildings/generating infrastructure)? 5.e Will any people need to be relocated to new houses, Yes: No: new farm land and/or lose access to other valuable If yes, please provide details. assets? 5.f Will the Company acquire land and/or pay for Yes: No:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE temporarily using it? If yes, how much land will be acquired and/or require payments for use? How will the amount to be paid for purchase or usage be determined? How will the Company proceed if agreement cannot be reached with owner(s)? Is there a written land acquisition plan for the Project? Yes: No: If yes, please provide details: 5.g Will any businesses / economic activities, both formal Yes: No: and informal, in the area be affected by construction If yes, please provide details: activities (e.g. tourism activities)? Does the Company have plans to compensate affected Yes: No: people for loss of business or economic activity? If yes, please provide details: 5.h Is there any resettlement required for this project? Yes No If yes, please provide details: If so, is there a Resettlement Action Plan? Yes No If yes, please provide details: PR 6 – Biodiversity Conservation & Sustainable Management of Living Resources 6.a How far is the Project from the nearest protected or Please provide a list with distances and provide a map showing the designated areas, or areas important for local Project and nearest protected/important areas. biodiversity, including Natura 2000 sites, national parks, Ramsar Sites (wetlands), etc.? 6.b Does the site provide habitat for any protected or Yes: No: sensitive species of plants or animals? If yes, please provide details: 6.c What habitat mapping or species surveys have been completed? 6.d Which habitat areas/species would be impacted by ancillary works, transmission lines, construction access
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE roads, other construction activities etc? 6.e Is there any other baseline environmental data on Yes: No: wildlife of the area not already covered above or in the If yes, please provide further details: Project Description section? 6.f Is there any further information on potential impacts to Yes: No: species or habitats that have not been covered above If yes, please provide further details: or in the Project Description section? PR 7 – Indigenous Peoples Are there any indigenous peoples likely to be impacted by the project? Yes: No: If yes, please provide details: PR 8 – Cultural Heritage 8.a Is the Project located in or near a cultural heritage site Yes: No: recognised by the country in which the project is If yes, please provide details: located, or where artefacts have been found in the past (including UNESCO World Heritage Sites and those on the tentative list, Registered cultural heritage sites, zones and settlements)? 8.b Is the Project located on or near to a place of worship, Yes: No: cemetery or other place of importance and value to a If yes, please provide details: community? 8.c Has the Company consulted with the national, regional, Yes: No: and/or local agency(ies) responsible for protecting If yes, please provide details: cultural resources? 8.d Has the risk to cultural heritage sites and areas of Yes: No: archaeological interest been assessed and managed? If yes, please describe: PR 9 – Financial Intermediaries Not relevant for KazREFF
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE PR 10 – Information Disclosure & Stakeholder Engagement 10.a Who will be affected by the Project, including the workforce and local communities? How and to what extent? 10.b Does the Company have a person in charge of Yes: No: communications with local communities? Name: Title: Phone/mobile: Email: 10.c Has the Company established a mechanism through Yes: No: which members of the public can raise concerns or If yes, please provide details: grievances concerning the Company’s environmental and social practices? 10.d Has the Company established a regular means for Yes: No: communicating with affected community(ies)/people If yes, please describe: (e.g. newsletter, email, helpline, open day)? 10.e Is the Company aware of any issues, concerns or Yes: No: positive feedback brought to the Company’s attention If yes, please describe: by members of the community, non-governmental organisations (NGOs), or the media? 10.f Has the company undertaken any consultations with Yes: No: stakeholders – including national, regional, and local If yes, please describe: authorities, NGOs, businesses, citizens? 10.g Does the Company have plans to implement Yes: No: community development activities (e.g. is there a If yes, please describe: corporate social responsibility plan)?
(end of questionnaire)
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Kazakhstan Renewable Energy Financing Facility (KazREFF) - Strategic Environmental Review
Appendix C – Environmental and Social Templates
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Kazakhstan Renewable Energy Financing Facility (KazREFF)
TEMPLATE - PROJECT NAME
DATE
Non Technical Summary of Environmental and Social Considerations
P
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CONTENTS
1 Introduction 66 2 Description of the Proposed Development 67 3 Environmental, Health, Safety and Social Review 67
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7.0 Introduction
Add summary of company proposing development – i.e private / public owned, company structure and operations Add summary of project proposals – i.e type of power plant, size and location Add summary of environmental studies undertaken to date – i.e an ESIA?, specialist surveys? (Company name XXX) has approached the European Bank for Reconstruction and Development (EBRD) for financing. The project is thus subject to EBRD’s 2008 Environmental and Social Policy and has been determined as a Category XXX project (add details of whether it is a category A or B project). EBRD has conducted an environmental and social due diligence assessment of the project and supported the development of applicable environmental and social documentation, namely a Stakeholder Engagement Plan, an Environmental and Social Action Plan, and this Non Technical Summary (also add reference to other relevant documents if appropriate eg an ESIA, specialist studies). This document provides in a non-technical manner an overview of the proposed development plans. The document also provides a summary of potential environmental and social impacts and other environmental and social issues relevant to the proposed activities. Appropriate measures to mitigate key adverse environmental and social effects that may arise during project construction and operation are also provided. This NTS document and other materials will be placed in the locations shown below on (add disclosure date XXX). During a 60 / 120 (delete as appropriate) -day period beginning on (add disclosure date XXX), anyone can provide comments and recommendations on the environmental, social and other aspects of the project. Comments can be made at public consultations to be held at the locations shown below, and may be submitted to the address below. Environmental and social documents will be available for review during normal business hours at the following location: XXXX (add details)
Meetings at which anyone can make comments will be held as follows: XXXX (add details) The dates and times of public meetings will be announced at least three weeks before the meeting(s), and advertised in local mass media. For further information on this project, or to provide comments on the project or the environmental and social documentation, please contact: Comments may be submitted to: Name Contact information Address: Complete all contact Phone: details Email:
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8.0 Description of the Proposed Development
Add project description – • prospective annual electricity generation, • equipment to be installed, • permitting requirements, • Location, size, (including location map(s)
9.0 Environmental, Health, Safety and Social Review
Key Environmental and Social Elements Several documents collectively make up the environmental and social documentation for the project. The Non Technical Summary is described above, while the other documents are described here. Environmental and Social Action Plan (ESAP) As part of the environmental and social due diligence evaluation, a wide review was conducted of corporate environmental, health, safety and social management arrangements. From the overall review, an Environmental and Social Action Plan (ESAP) has been developed which lists key actions to ensure areas for improvement can be implemented and include mitigation measures discussed above. This ESAP is being disclosed for public comment; key mitigation measures are described below. Stakeholder Engagement Plan (SEP) (Insert company name XXX) has prepared a Stakeholder Engagement Plan (SEP) for the Project. The SEP will guide (insert company name XXX) in communicating with people, institutions and any other stakeholders who may be affected by or interested in the implementation of Project. (Insert company name XXX) has assigned a social liaison officer, who will be responsible for keeping open dialogue with stakeholders groups and local public. This SEP is being disclosed for public comment. At any time before and during construction and operation, any stakeholder will have a chance to raise any concerns, provide comments and feedback about the Project. All such comments and grievances from people will be accepted, processed and answered by (insert company name XXX) in a timely manner.
Key Features Key environmental features and sensitive locations from a social perspective in relation to the site include:
XXX – add details
Potential Impacts and Mitigation Measures ERM 67 KasREFF SER RPER SOLAR – June 2014
The EBRD’s environmental and social diligence evaluation determined that the project could have negative impacts on environmental resources and on people if they are not controlled carefully. Therefore, the EBRD will require (insert company name XXX) to implement many actions (“mitigation measures”) to prevent, reduce, or mitigate impacts on people and the environment. A summary of key impacts and mitigation measures have been identified, and they are summarised in Appendix A.
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Overview of Potential Impacts and Mitigation
Resource Potential Impact / Issue of Concern Mitigation
For example … Climate and Air Quality
Geology, Geohazards and Soils
Surface Water & Groundwater
Water Supply
Ecosystems and Flora & Fauna Noise
Waste Management
Cultural Heritage Tourism
Visual Landscape
Socio-economics
Traffic Management
Occupational Health & Safety Public Health & Safety
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Others…
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Kazakhstan Renewable Energy Financing Facility (KazREFF)
TEMPLATE - PROJECT NAME
DATE
Stakeholder Engagement Plan
Prepared for:
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CONTENTS 1 Introduction 73 1.1 Background 73 1.2 Description of the Proposed Development 73 1.3 Overview of XXX (add company name) 73 1.4 Objectives of the Stakeholder Engagement Plan (SEP) 73 1.5 Structure of SEP 74 2 Regulatory Context 75 2.1 Kazakhstan requirements for stakeholder engagement/ public consultation 75 2.2 EBRD requirements for stakeholder engagement and public consultation 75 3 Summary of previous stakeholder engagement 77 3.1 EBRD previous stakeholder engagement and consultations in Kazakhstan 77 3.2 KazREFF SER Consultations 77 3.3 Public disclosure and consultations during project 78 3.4 Other consultations during the project 78 4 Stakeholder Identification and Communication Methods 79 5 Disclosure of Information and Stakeholder Engagement Programme 81 5.1 Disclosure of general information 81 5.2 Disclosure of information relevant to Project 81 5.3 Stakeholder engagement programme 81 6 Timetable 82 7 Public Grievance Mechanism 83 8 Roles and Responsibilities 84
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10.0 Introduction
10.1 BACKGROUND Add summary of company proposing development – i.e private / public owned, company structure and operations Add summary of project proposals – i.e type of power plant, size and location Add summary of environmental studies undertaken to date – i.e an ESIA?, specialist surveys? (Company name XXX) has approached the European Bank for Reconstruction and Development (EBRD) for financing. The project is thus subject to EBRD’s 2008 Environmental and Social Policy and has been determined as a Category XXX project (add details of whether it is a category A or B project). EBRD has conducted an environmental and social due diligence assessment of the project and supported the development of applicable environmental and social documentation, namely a Stakeholder Engagement Plan, an Environmental and Social Action Plan, and a Non Technical Summary of the environmental and social considerations (also add reference to other relevant documents if appropriate eg an ESIA, specialist studies). To meet EBRD requirements for stakeholder engagement and public consultation and disclosure (EBRD Performance Requirement PR10), a stakeholder and public engagement process with development of a Stakeholder Engagement Plan (SEP) will also be directly applied to this project. These details are laid out in this document, the SEP. EBRD considers stakeholder engagement as an essential part of good business practices and corporate citizenship, and a way of improving the quality of projects. In particular, effective community engagement is central to the successful management of risks and impacts on communities affected by projects, as well as to achieving enhanced community benefits.
10.2 DESCRIPTION OF THE PROPOSED DEVELOPMENT Add project description – • prospective annual electricity generation, • equipment to be installed, • permitting requirements, • Location, size, (including location map(s)
10.3 OVERVIEW OF XXX (ADD COMPANY NAME) Add summary of company proposing development – i.e private / public owned, company structure and operations
10.4 OBJECTIVES OF THE STAKEHOLDER ENGAGEMENT PLAN (SEP) This SEP has been developed with the aim of explaining how company name XXX will communicate with people and institutions who may be affected by or interested in the Project, at various stages of project preparation and implementation. The plan includes a
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grievance mechanism for stakeholders to raise any concerns related to the project for company name XXX attention. 10.5 STRUCTURE OF SEP The remainder of this SEP is organised as follows: • Chapter 2 briefly describes applicable regulations and requirements for stakeholder engagement and public consultations. • Chapter 3 summarises previous and on-going stakeholder engagement and public consultation activities. • Chapter 4 identifies stakeholders and describes communication methods with them. • Chapter 5 describes stakeholder engagement program and disclosure of information. • Chapter 6 describes roles and responsibilities for handling the consultation and information disclosure process. • Chapter 7 describes a grievance mechanism by which feedback, comments, concerns and complaints may be communicated to company name XXX and how these grievances and comments will be handled.
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11.0 Regulatory Context
11.1 KAZAKHSTAN REQUIREMENTS FOR STAKEHOLDER ENGAGEMENT/ PUBLIC CONSULTATION Kazakhstan is a signatory for Aarhus Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters (UNECE)6. The convention is designed to improve the way ordinary people engage with government and decision-makers on environmental matters. Consequently, citizens of Kazakhstan are entitled to be informed about all environment related issues pertaining to the project and it is the responsibility of public authorities, local authorities, or government departments to reveal such environmental information. National legislation also foresees broad public involvement in decision-making process. Further details to be added….
11.2 EBRD REQUIREMENTS FOR STAKEHOLDER ENGAGEMENT AND PUBLIC CONSULTATION Since EBRD may be involved in funding the Project, the Project must meet the best international practices and requirements for stakeholder engagement and public consultations as specified in the EBRD Environmental and Social Policy of 2008.
The principles, requirements, methodological and procedural aspects of stakeholder engagement for EBRD Category A and B projects are described in detail in PR10 “Information Disclosure and Stakeholder Engagement 7 . PR10 outlines a systematic approach to stakeholder engagement that will help clients build and maintain over time a constructive relationship with their stakeholders, including the locally affected communities.
As required, the following important stages shall be implemented for the Project engagement and consultation process: - Identification of project stakeholder groups. Identification of stakeholders, including members of the public who could be affected by the Project construction and operation. - Stakeholder engagement process and information disclosure. During this step, company name XXX is to ensure that identified stakeholders are appropriately engaged on environmental and social issues that could potentially affect them through a process of information disclosure and meaningful consultation. - Meaningful consultation. The consultation process will be based on the disclosure of information relevant to the Project activities and operations. The consultation process will be undertaken in a manner that is inclusive and culturally appropriate for all stakeholders, including effected communities and vulnerable groups.
6 UNECE Aarhus Convention on access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters
7 EBRD Environmental and Social Policy 2008 (http://www.ebrd.com/downloads/about/sustainability/2008policy.pdf)
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- Grievance mechanism. Maintaining a grievance process by which the general public and other stakeholders can raise concerns, and which will be handled in a prompt and consistent manner.
The stakeholder engagement process and SEP preparation was also guided by the IFC Good Practice Handbook8 that defines the best practice approach to stakeholder engagement.
8 http://www.ifc.org/ifcext/enviro.nsf/AttachmentsByTitle/p_StakeholderEngagement_Full/$FILE/IFC_StakeholderEngagement.pdf
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12.0 Summary of previous stakeholder engagement
12.1 EBRD PREVIOUS STAKEHOLDER ENGAGEMENT AND CONSULTATIONS IN KAZAKHSTAN The European Bank for Reconstruction and Development (”EBRD” or the “Bank”) has made RES a key priority for investment in its countries of operation and has reviewed a number of early stage RES projects in Kazakhstan. The Bank has gained initial approval from the Clean Technology Fund (CTF) for concessional finance of up to $110 million to help create markets for power from RES in Kazakhstan. The Bank is now in the process of establishing dedicated financing facilities to enable it to provide finance to both larger and smaller RES projects in Kazakhstan (up to €10 million per project). This will be supported by funds from the CTF. The Bank has been active since 2008 in assisting the Government of Kazakhstan (the “Government”) through a technical cooperation programme in supporting the preparation of legislation to support RES development which has involved extensive stakeholder dialogue with the Ministry of Industry and New Technologies (MINT). In 2012, during the early stages of renewable energy programme development for Kazakhstan, the EBRD launched the assignment Kazakhstan Renewable Energy Development Framework and Regulatory Support (TCS number 34068). This assignment was to provide technical assistance in renewable energy regulatory support and institution building to the Kazakhstan Ministry of Industry and New Technologies (MINT; subsequently renamed the Ministry of Environment and Water Resources, or MEWR). Included in that assignment was a Renewable Energy Market Study, which included extensive stakeholder dialogue to establish the appropriate structure for renewable energy regulation in Kazakhstan. A number of key stakeholders and interested parties were identified at that stage, including local authorities and regulators at different levels, potential donor agencies, scientific and research institutes, and private developers. All targeted groups were contacted, and a series of individual meetings and workshops were organized and undertaken.
12.2 KAZREFF SER CONSULTATIONS
The Kazakhstan Renewable Energy Financing (KazREFF) undertook a large stakeholder engagement exercise alongside the Strategic Environmental Review (SER) of the potential effects of implementing renewable energy projects funded under KazREFF. The SER consultations were undertaken in three stages:
• Stage 1 (between April and July 2013). In Stage 1, the information about the KazREFF SER and SER Scoping Report was disclosed to with 30 representatives of various stakeholder groups; 13 of whom were individually interviewed. Representative stakholders included representatives of local authorities, manufacturers, developers and consultants involved in the development and implementation of renewable energy projects in Kazakhstan. The initial list of stakeholders resulting from stakeholder identification and analysis was expanded and amended where necessary. • Stage 2 (between July 2013 and September 2013). In Stage 2, the SER Environmental Scoping Report was published on the KazREFF SER website at http://www.kazreff-
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ser.com. EBRD conducted half-day scoping meetings on 16 and 18 July 2013 in Astana and Almaty, respectively, to encourage broad stakeholder participation in the development of the SER. Outreach activities, including mailing, emailing and telephoning contacts, were undertaken with 86 organizations representing a variety of stakeholders in the Astana and Almaty areas including government, developers, non- governmental organizations (NGOs), consultants, and advisory bodies. Eighteen organizations representing a variety of stakeholders participated in the meetings. • Stage 3 (June 2014 through October 2014). In Stage 3, the Draft SER report was disclosed and initiated formal 120-day public consultation period, where all stakeholders had an opportunity to provide comment on the disclosed Draft SER report. During this timeframe, two workshops were held to both inform and educate stakeholders about the SER and the KazREFF.
12.3 PUBLIC DISCLOSURE AND CONSULTATIONS DURING PROJECT Add details of any public disclosure / consultation undertaken to date as part of this project.
12.4 OTHER CONSULTATIONS DURING THE PROJECT Add details of any other consultation that may have occurred as part of the project, for example with authorities to obtain necessary permits.
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13.0 Stakeholder Identification and Communication Methods
In order to define a communication process in line with EBRD PR10, company name XXX has identified several stakeholder groups that may be interested and/or affected by the Project development and implementation. The stakeholders identified include: • Internal stakeholders, such as company name XXX employees and construction contractors’ workers
• External stakeholders, such as o governmental authorities, o non-governmental organisations and o local residents.
Others who wish to be included in the list can contact company name XXX and be put on the mailing list for information on reporting, meetings, or other consultation opportunities.
Table 1 describes the stakeholder engagement programme and communication process by providing contact details of certain stakeholders, and identifying communication methods and specific media that will be used to notify stakeholders of information. Any suggestions for improvement of proposed communication methods or media are welcomed and can be submitted via the contact information at the end of this document.
Table 1. Stakeholder engagement programme for the Project Stakeholder group Description Communication method / Proposed Media channel and contact information (where applicable) Internal Stakeholders Employees XXX For example… Company website?? - Internal newsletters www.kazreff.com ?? - Emails - Grievance procedure - Bulletin boards - Union meetings - Inserts with payslips Temporary Construction XXX For example… XXX Workers, subcontractors - Internal newsletters - Emails - Grievance procedure - Bulletin boards - Union meetings - Inserts with payslips Unions: XXX For example… XXX • XXX - Official correspondence.
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Table 1. Stakeholder engagement programme for the Project Stakeholder group Description Communication method / Proposed Media channel and contact information (where applicable) - Union newsletter. - Information on request to union representatives. External Stakeholders Population in XXX XXX XXX Newspapers: XXX Radio: XXX Company website?? www.kazreff.com ?? Local authorities and public enterprises: For example… XXX For example… XXX Water Company - Communication via official letters and meetings Public Health Institute XXX For example… XXX - Ongoing working linkages with the Institute County / city XXX For example… XXX administration - Ongoing working linkages with the authorities - Official correspondence - Meetings State level authorities: - Ukrainian Water XXX For example… XXX Authority - Official correspondence - Ministries - Meetings • XXX
Other relevant external stakeholders For example… XXX - Meetings (invitation to public Company website?? Local Tourist Board consultation meetings) www.kazreff.com ?? Others..
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14.0 Disclosure of Information and Stakeholder Engagement Programme
14.1 DISCLOSURE OF GENERAL INFORMATION Provide details of general information disclosure – website, company reports etc
14.2 DISCLOSURE OF INFORMATION RELEVANT TO PROJECT To meet the environmental and social requirements and performance standards of EBRD and EU, company name XXX will develop, disclose to the public and then implement an Environmental and Social Action Plan (ESAP), which will identify mitigation measures to minimise, reduce, eliminate or control potential adverse impacts on environment and people.
The final version of ESAP will be published on company name XXX official website (or KazREFF website?) and printed copies will be available on request from XXX (contact information available in the table above).
The local population will receive timely information (through the local media listed in the table above and announcements regarding grievance management in relation to construction activities, safety measures in the vicinity of the construction site, traffic management, employment opportunities and opportunities for service provision (catering, accommodation of workers, laundry services, etc.) and any other information identified through the development of the ESAP.
Annual project progress reports, including environmental and social impacts, health and safety performance and implementation of the external grievance mechanism will also be disclosed on company name XXX official website (or KazREFF website?) and will be available on request XXX (contact information available in the table above).
14.3 STAKEHOLDER ENGAGEMENT PROGRAMME Consultations and disclosure of information for local public
Public consultations will be held after a draft Environmental and Social Action Plan has been developed. Add details of proposed consultation. For example - who will manage it, when will it take place, and with whom?
Other stakeholder engagement activities Add details of proposed consultation. For example - who will manage it, when will it take place, and with whom?
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15.0 Timetable
Stakeholder(s) and engagement Issues / documents Possible dates activity(ies) During the development of ESAP and NTS XXX XXX XXX XXX XXX XXX When the ESAP/SEP/NTS are completed All stakeholders Publish ESAP, SEP and NTS (in XXX English and Ukrainian) and inform all stakeholders through local media. Include responses to comments, suggestions which were not incorporated in the documents. Before construction Contractors / temporary workers Agree construction related XXX grievance management, inform all stakeholders; Code of conduct for temporary workers, trainings Local population Information on safety measures XXX Traffic Management Plan Employment opportunities and opportunities for service provision During construction and operation Public consultation meetings if Implementation of the ESAP, new XXX necessary (determined in cooperation impacts, revision of documents, with EBRD) implementation of SEP, processing and responding to grievances
After construction
Ongoing meetings and cooperation, throughout the life of the project, with the following external stakeholders: • XXX
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16.0 Public Grievance Mechanism
The objective of a grievance procedure is to ensure that all comments and complaints from any project stakeholder, including local/regional authorities, residents of nearby residential areas, company name XXX employees, company name XXX contractors’ staff and other interested parties, are considered and addressed in an appropriate and timely manner. All grievances will be acknowledged and responded to within a reasonable timeframe. company name XXX will accept all comments and complaints associated with the project. A sample of a Comments and Complaints Form is shown in Appendix A. The comments and complaints will be summarised and listed in a Complaints/Comments Log Book, containing the name/group of commenter/complainant, date the comment was received, brief description of issues, information on proposed corrective actions to be implemented (if appropriate) and the date of response sent to the commenter/complainant. Any person or organisation may send comments and/or complaints in person or via post, email, or facsimile using the contact information specified in Section 8.0 below.
All comments and complaints will be responded to either verbally or in writing, in accordance with preferred method of communication specified by the complainant in the Comments and Complaints Form. Comments will be reviewed and taken into account in the project preparation; however they may not receive an individual response unless requested.
All grievances will be registered and acknowledged within 5 days and responded to within 20 working days. Company name XXX will keep a grievance log and report on grievance management, as part of annual project progress reports, available at the company name XXX website and on request at add contact details.
Comments and concerns regarding the project can be submitted in writing in the following ways: • electronic form on company name XXX website or KazREFF website?: add details • email: XXX • by post or hand delivered to (see example grievance form attached): – XXX • by phone: – XXX
Provide contact person and specify contact details Individuals who submit their comments or grievances have the right to request that their name be kept confidential.
During construction, grievances in relation to construction activities will be managed by company name XXX and construction contractor. Local residents will be informed about the contractors contact information before construction begins, through the local media (listed in the table above) and announcements in public places.
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A separate grievance mechanism is available for workers, both employees of company name XXX and the contractors. 17.0 Roles and Responsibilities
Provide contact person and specify contact details will have the overall responsibility for handling the consultation and information disclosure process, including organisation of consultation process, communication with identified stakeholder groups, collecting and processing comments/complaints, and responding to any such comments and complaints. Depending on the nature of a comment/complaint, some comments or complaints will be provided to the appropriate person in the company for a response.
Name of the person and title Affiliation XXX Company: XXX Postal Address: XXX Telephone: XXX E-mail address: XXX Hotline: XXX
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APPENDIX A Comments and Complaints Sample Form FORM FOR COMMENTS, COMPLAINTS AND REPORTS OF INDIVIDUALS Reference No: Full Name
Contact Information By Post: Please provide mailing address: and Preferred method ______of communication ______
Please mark how you wish to be contacted By Telephone: ______(mail, telephone, e-
mail). By E-mail ______
Description of Incident or Grievance: What happened? Where did it happen? Who did it happen to? What is the result of the problem? Source and duration of the problem?
Date of Incident/Grievance
One time incident/grievance (date ______) Happened more than once (how many times? _____) On-going (currently experiencing problem)
What would you like to see happen to resolve the problem?
Signature: ______Date: ______Please return this form to: XXXXXXXX Address ______: Tel.: ______or E-mail: ___
ERM 85 KasREFF SER RPER SOLAR – June 2014
CONTENTS
Kazakhstan Renewable Energy Financing Facility (KazREFF)
PROJECT NAME
Environmental and Social Action Plan - Solar Photovoltaic
DATE
Prepared for:
ERM 86 KasREFF SER RPER SOLAR – June 2014
CONTENTS
1 PROJECT OVERVIEW 88 1.1 Project approach 88 1.2 Scope of this ESAP 88 1.3 ESAP for solar photovoltaic projects 90
ERM 87 KasREFF SER RPER SOLAR – June 2014
PROJECT OVERVIEW
– PROJECT APPROACH To encourage businesses to pursue sustainable energy projects, the European Bank for Reconstruction and Development (EBRD) has launched the Kazakhstan Renewable Energy Financing Facility (KazREFF). KazREFF aims to ‘provide development support and debt finance to renewable energy projects which meet required commercial, technical and environmental standards’. KazREFF not only provides tailor-made financing, but also provides technical assistance for businesses and local authorities based on information gathered and analysed by stakeholders to promote projects that are often challenging to finance and implement. KazREFF is part of the EBRD’s Sustainable Energy Initiative (SEI) which addresses the challenges of climate change and energy efficiency. Since the launch of the SEI in 2006, the EBRD has remained at the forefront in helping countries from Central Europe to Central Asia secure sustainable energy supplies and finance the efficient use of energy that will cut demand and imports, reduce pollution, and mitigate the effects of climate change. In co-operation with the national authorities in Kazakhstan, EBRD commissioned a Strategic Environmental Review (SER) for the KazREFF programme, focusing on renewable energy technologies in optimal areas of Kazakhstan. The renewable energy technologies specifically reviewed in the SER include small hydropower, on-shore wind, solar photovoltaic, and biogas technologies. Four Environmental and Social Action Plan (ESAP) templates have been produced – one for each of the renewable energy technologies – to provide a framework for further development at the inception of a given renewable energy project that is seeking funding from KazREFF. The SER and associated Environmental and Social Action Plans comply with the EBRD’s Environmental and Social Policy and its Public Information Policy.
– SCOPE OF THIS ESAP This ESAP is for the solar photovoltaic renewable energy scenario; It includes a series of actions to be undertaken in order to manage – that is, to plan and implement specific measures to avoid, reduce, control, or otherwise mitigate – potential environmental, occupational health and safety, and social impacts during construction and operation9. This ESAP should be considered as a template which will be reviewed and amended by project proponents who wish to develop specific solar photovoltaic projects funded by KazREFF in the future; and will be part of the contract between the project developer and EBRD. It is envisaged that EBRD will require performance of the required actions to be regularly reported and that it will periodically monitor implementation of the ESAP. The table below presents the actions required by this ESAP, organised by the EBRD’s Performance Requirements. These actions should be added to as befits the individual project situation; If there is a good reason to remove an action from the table this can be agreed with the EBRD during the development of the project. The table shows the source and timing of
9 For purposes of this ESAP, “construction” includes all actions in the field to construct the project, including support and ancillary facilities such as construction camps, roads, temporary or permanent buildings, staging areas, etc. “Operation” means routine and non-routine operation and maintenance and support facilities, and “project performance” includes the entire period of construction and operation.
ERM 88 KasREFF SER RPER SOLAR – June 2014
the requirement and the criteria by which performance of the action will be evaluated. Implementation of all the actions will be the responsibility of project developer. When other companies perform work under contract, the developer will be responsible for those contractors’ compliance with the requirements of the ESAP. This is expected to be accomplished by inclusion of appropriate requirements in contracts and subcontracts, and by direct oversight and supervision by the developer as needed. As specified in various required actions, or as otherwise agreed by the parties, once produced, a project-level ESAP may be further revised from time to time during project performance. No changes to the project-level ESAP will allow violations of Kazakhstan law or of EBRD requirements for environmental and social performance. Additionally, it should be fully understood by all parties that this ESAP does not supersede any local or national laws; the developer must comply with all applicable laws and regulations governing the development of the proposed facilities.
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KAZAKHSTAN RENEWABLE ENERGY FINANCING FACILITY (KAZREFF) – ESAP FOR SOLAR PHOTOVOLTAIC PROJECTS Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility 0 Prepare and submit reports on status of ESAP EBRD PR1 Each six months Submission reports on environmental, implementation and environmental and social during construction, occupational health and safety, and performance, including resolution of grievances. annually thereafter social (ESHS) performance 1. Environmental and social planning and management 1.1 Achieve and maintain environmental and social Best international Ongoing Include in ESHS report the status of management systems equivalent to ISO 14001. management practices. environmental and social management systems PR1 1.2 Achieve and maintain an occupational health Best international Ongoing Include in ESHS report the status of OHS and safety (OHS) management system to OHSAS management practices. management systems 18001 or equivalent for all companies associated PR1 with energy generation, transmission and distribution. 1.3 Appoint responsible manager(s) for Best international Throughout - Appointment of corporate ESHS environmental and occupational health and management practices. construction and manager safety issues. Train foremen and appropriate operation PR1 - Training of foremen and other staff staff on each construction team and ensure operations meet the relevant requirements of this - Ultimate goal: full compliance with ESAP and, as needed, the requirements of ESAP EBRD’s Performance Requirements. - Include in ESHS report updates on appointment(s) and training 1.4 Develop comprehensive waste management Best international Prior to and during - Preparation and implementation of plans for the project. Plans should include (at a management practices. construction waste management plans minimum): PR1 - Include in ESHS report information
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility - Procedures for proper handling of all waste on plan preparation and waste generated at the construction or operational management compliance status site (including hazardous and non-hazardous waste); - Methods to verify proper off-site management of related wastes by contract waste managers; and, - Measures to minimise waste generation and maximise reuse and recycling. Note that wastes include paper, printer cartridges, lights, and office waste as well as construction and industrial waste 1.5 Establish corporate policy and procedures for Best international Prior to and during ESHS reports to EBRD on: oversight of contractor (if project proponent is management practices. construction - Programme description not also contractor) ESHS performance during PR1 construction, to include (at a minimum): - Highlights of performance (appointments, inspections, etc.) - Inclusion of appropriate ESAP and other legal requirements in contracts, including - Training requirement for staff/management training; - Contractor summaries (both at - Assignment of clear responsibilities within contractor level and compiled project developer for contractor oversight of the level) in terms of environmental and projects; OHS performance summaries - Regular inspections of sites and contractors’ construction camps; - Contractor reports on performance sufficient to allow inclusion of data in ESHS reports to the Bank, and to allow developer to
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility determine if corrective actions are needed; and, - Verification of training and professional credentials for contractor environmental and OHS managers and staff. 1.6 Obtain all required permits for the projects and Local regulatory Prior to construction - Identify permits required and comply with permit requirements. requirements and during received in ESHS reports; and, operation, as PR1 - Report on compliance in ESHS applicable reports 1.7 Monitor performance of project during operation PR1 During operation Submission of monitoring reports against the environmental and social standards demonstrating that predicted and objectives set and submit regular reports to environmental and social effects are being satisfactory mitigated for. EBRD at agreed timescales and for an agreed period (likely to be a number of years). 2. Performance Requirement 2: Labour and Working Conditions 2.1 Evaluate HR management system and PR2 Prior to construction - Until complete, include in ESHS procedures against EBRD requirements and report status of required and Kazakhstan law, including specifically completed updates to HR systems; provisions covering: - Report annually on key worker data, - terms of employment and dismissal; including dismissals and new hires, status of medical checks, etc.; and, - grievance mechanism; - Include in ESHS report data on - discrimination, harassment, violations and numbers of workers in various human rights; categories (management, skilled, - proscription of forced and child labour; unskilled, etc.), and breakdown by gender. - mandatory medical checks for new hires;
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility and, - social leave/benefits. Update system/policies as necessary to ensure compliance. 2.2 As part of policy development under item 1.5 PR2 Prior to contracting - Preparation and implementation of above, develop and implement a contractor plan; and, management plan for the project, and procedures - Report on contractors’ compliance ensuring contractor’s compliance with EBRD PR and oversight results. 2 and Kazakhstan labour law. 2.3 Support local labour force by: Best international Throughout - No complaints from labour force; practices. construction and, - Providing realistic information on employment opportunities, with transparent PR2 - Include data on use of local labour in hiring practices; ESHS reports. - Advertise for all positions; - Employing local labour where possible; - Pay wages at least average for the area for comparable positions; and, - Construction camps must comply with Kazakhstan law and provide adequate heating, showering and cooking facilities. 2.4 Develop and implement an OHS plan to guide Best international Plan in place prior - Preparation and implementation of all project-related activities on the project sites practices. to construction (for OHS plans for projects; during construction and then throughout contractors, prior to PR2 - Review and approval of contractor operation. Also require contractor site operations). OHS plans; and, plan/compliance. Requirements to include (but Throughout not be limited to): - Include in ESHS reports to Bank data construction and ERM 93 KasREFF SER RPER SOLAR – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility - Job- and task-specific hazard analysis and operation. on performance by developer and controls for developer and contractor’s contractors (hours worked, accidents, activities; lost time, etc.). - Provision of PPE, requirements for use of PPE, and enforcement of PPE use; - Safety training for all personnel, covering hazards for their jobs; - Review and approval of contractors OHS plans, to meet same standards as developer’s plan; - Oversight of contractor OHS implementation, including mandatory reporting; and, - Recording incident statistics, including total work hours.
2.5 Location and life activities of construction camps Best international At all times Compliance shall meet the requirements of Kazakhstan law practices. construction camps Include data on incidents in ESHS and EBRD PR2. PR2 are occupied reports 3. Performance Requirement 3: Pollution Prevention and Abatement 3.1 Implement mitigation measures and best Best international Throughout Minimal dust generation management practices to prevent / reduce / practices. construction and control air pollution from fugitive dust and operation PR3 vehicle / equipment emissions. - Control dust emissions in dry periods by using water or other dust suppression methods on roads and construction areas that may generate dust;
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility - Ensure efficient usage of delivery vehicles; including use of alternative and/or more efficient delivery methods (including for example rail, boat) during construction to optimise the emissions to atmosphere per payload; - Ensure all vehicles carrying spoil and all stockpiles are covered; - Switch vehicles and equipment off when not in use; and, - Keep all motorised equipment and vehicles well-maintained to reduce emissions. 3.2 Develop erosion, sediment and water quality Best international Throughout Mitigated adverse impacts on water control plan for all areas where the ground will practices. construction quality be disturbed during construction. Plan should (at PR3 Report on impacts in ESHS reports. a minimum): - Specify use of good housekeeping practices and best management practices to minimise surface water and stormwater runoff to watercourses and aquatic habitat (especially in critical areas or time periods for aquatic life). For example, siltation dispersal, such as settling ponds, using silt curtains along any nearby waterways, straw bales, check-dams, and seeding; - Keep hard-standing areas and road surfaces clean from mud and oil build up; - Keep stockpiles covered, minimise bare ERM 95 KasREFF SER RPER SOLAR – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility ground near rivers; - Store hazardous and potentially polluting materials in bunded, secure, areas away from watercourse and pathways to watercourses (e.g. drains, ditches); - Use kerbed/ bunded areas to prevent run off to river; - Silt collected in any device or structure should be cleaned away regularly; - Inspections of vehicles and equipment for leaks before use near or in water; and, - Particular attention should be given to avoiding steep slopes and implementing erosion control measures, and promptly re- vegetating cleared land with appropriate native species. 3.3 Implement measures to prevent / reduce / Best international Throughout Mitigation in place for potential adverse control ground contamination as a result of spills practices. construction and impacts of ground contamination. of fuel, lubricants and other chemicals. operation PR3 - Store fuels and oils in bunded containers with 110% capacity; - Ensure drip-trays are in place where fuels or oils are stored or used; - Identify a designated bunded refuelling location; - Educate drivers and equipment operators in
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility proper fuel management, including clean-up of spills; and, - Make spill kits available, and use if necessary to clean up oil spills etc before contaminants can enter the ground or watercourses. 3.4 Ensure appropriate containment and disposal of Best international Throughout Reduction in the risk of water / land construction wastewater, including sanitary practices. construction and pollution and impacts on ecology water and storm water. All sanitary and storm operation PR3 water to be collected and delivered to a nearby waste water treatment works. 3.5 Developer to ensure that the project team has a Best international Throughout Potential major incidents identified and high level of preparedness for emergencies (such practices. construction and avoided through emergency planning; if as earthquakes and major dam failures where operation major incidents occur, these are handled PR3 PR4 applicable) and that an appropriate emergency according to the planned procedures. plans is in place and understood by developer and contractor staff. Include the local community in the emergency plan. 3.6 Develop plans to reduce project-related Best international Planning prior to GHG emissions minimised greenhouse gas (GHG) emissions practices. construction and GHG emissions reported to EBRD in implementation - Establish baseline GHG emissions; PR3 ESHA report. throughout - Estimate construction and operation GHG construction and emissions and take steps to reduce these operation during project design; and, - Record actual GHG emissions during construction and operation. 3.7 Develop reinstatement plans for working areas Best international Planning prior to Working areas reinstated with native including for the re-vegetation of areas cleared construction and vegetation where appropriate and as
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility prior to, or during, construction. practices. implementation soon as practicable following following construction (it is recognised that could Given the requirement for keeping solar panels PR3 construction. take a number of months or in some clear of vegetation and easily maintained, it is cases years). likely that, when operational, the areas directly under solar panels will not be substantially re- vegetated. However, areas outside of those directly used for the panels should be reinstated. 3.8 Develop soil protection plan to include: Best international Prior to construction Mitigated for potential adverse impacts practices. upon soils. - Site selection and facilities arrangement (including transmission lines, access roads, PR3 PR4 etc) to avoid or minimise displacement of productive agricultural lands; - Measures to minimise compaction and other alteration of soil composition across working area; and, - Soil erosion across the working area. 4. Performance Requirement 4: Community Health & Safety and Security 4.1 Develop and implement – and require PR4 Throughout - Public notices contractors to implement – procedures to protect construction and - Security training public health and safety, to include (but not be operation limited to): - Include in ESHA report to Bank data on notices, training, etc. - Traffic management plan for all drivers and equipment operators (see 4.2 below); - Public notice of construction operations near areas open to the public; - Methods to identify and prevent spread of
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility those communicable diseases that can be transmitted by the project components or its workforce (including contractors); - Methods to prevent and minimise exacerbating impacts caused by natural hazards (such as landslides or floods); - Security as needed to prevent unauthorised access to project locations, with appropriate training for guards to be guided by the principles of proportionality, good international practice and Kazakhstan law; and, - Hazard notices/signs/barriers to discourage/prevent access to energised components or other dangerous areas. 4.2 Develop and implement a Traffic Management - Best international Throughout Traffic management plan Plan. practices construction and Include in ESHS reports data on all operation - Design routes so as to avoid schools, - PR4 accidents hospitals, and other areas where there may be heavy pedestrian or child use; - Notify communities and place signs on public roads prior to periods of heavy use; - Place warning signs along the perimeter of construction areas; - Confine construction activities to daylight hours; - Establish and enforce strict speed limits on- ERM 99 KasREFF SER RPER SOLAR – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility and off-site; - Provide training to all drivers, enforce compliance with traffic plan; and, - Identify and implement measures to reduce construction traffic where possible, for example through car sharing and use of bicycles etc. 4.3 Develop a noise monitoring and mitigation PR2, PR4 Establish baseline Robust baseline programme that will establish a pre-construction prior to construction Minimal off-site disturbance baseline and ensure construction and operational Monitor noise noise is within Kazakhstan law and to minimise Early awareness of potential noise periodically off-site disturbance to local population. impacts, allowing mitigation to be put in throughout place as required Avoidance and mitigation measures for noise, construction should include consideration of: - Proper siting of development and access routes to avoid close proximity to sensitive noise receptors (e.g. residences, hospitals and schools); - Controls on construction and operation hours; - Controls on type of construction and maintenance plant/vehicles; - Controls on type of delivery vehicles used, routes used for deliveries and timing of deliveries; and, - Noise screening of works during
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility construction. 4.4 Establish and enforce clear rules for workers Best international At all times when Include in ESHS report information on (including contractor employees) in construction practices construction camps complaints and incidents involving camps to prevent off-site disturbance incidents are occupied workers, and contractor/developer involving local residents. responses 4.5 Avoid or mitigate for visual impact of glint Best international Prior to construction Minimal off-site disturbance (which occurs when the sunlight strikes a solar practices
panel at a particular angle) through careful siting to avoid sensitive receptors. 5. Performance Requirement 5: Land Acquisition, Involuntary Resettlement and Economic Displacement 5.1 Avoid siting projects where they will cause PR5 PR4 Prior to construction Project siting in area of least disturbance disruption or displacement to established to communities Best international communities, farms and homes, or users of practices grazing land where possible through thorough consideration of alternatives. 5.2 If displacement is unavoidable, plan to improve PR5 PR4 Prior to construction Sustainable improvements to socio- or, at a minimum, restore the livelihoods and economic status of any displaced persons Best international standards of living of any displaced persons to practices pre-project levels. Displaced persons could include those who have legally recognisable rights or claims to the land, those with customary clams to the land, those with no legally recognisable rights or clams to the land, seasonal resource users such as herders/fishing families, hunter and gathers who may have interdependent economic relations with communities located within the project area.
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility 5.3 Attempt to reach negotiated settlements with all PR5 Prior to construction Amicable agreements avoiding the need affected individuals / households for involuntary resettlement 5.4 If required, compensation to be provided at just PR5 Prior to construction Amicable agreements. replacement value, as determined by court Include information on certified valuators. This will take the form of acquisition/resettlement/ compensation replacement by a similar property or cash actions in ESHS report to Bank. compensation. 6. Performance Requirement 6: Biodiversity, Conservation and Sustainable Resource Management 6.1 Undertake pre-construction ecological surveys Best international Prior to construction Survey reports, focussed on area of and associated assessments of the project practices. proposed construction footprints (including ancillary works such as PR6 improvements to transmission lines and access roads) and surrounding areas to establish a robust baseline. Surveys and assessments should be included for terrestrial ecosystems and aquatic ecosystems as befits the specific project and situation. However, it is envisaged that for solar photovoltaic development surveys will particularly be needed for the following: - Terrestrial flora (including protected habitats); - Birds (in particular implications of land take on potential nesting and foraging habitats); - Wide-ranging mammals (including, bats, otter, brown bear, bison, lynx and wildcat); and,
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility - Where appropriate, other terrestrial fauna (such as reptiles and invertebrates). 6.2 Develop an Ecosystem Protection Plan following Best international Develop plan prior Production of an Ecosystem Protection the ecological surveys. practices. to construction and Plan follow plan during Follow the Biodiversity Mitigation Hierarchy: to PR6 construction. Avoid, Minimise, Mitigate and Offset likely adverse effects. This plan to cover the construction and operational phases and to include consideration of all species and habitats applicable to the project, including provisions to: - Avoid, or mitigate for, siting of solar photovoltaic panels or associated transmission lines in areas recognised as important for bird nesting or foraging; - Avoid, or mitigate for, siting solar photovoltaic panels or associated structures in areas recognised as important for bat roosting and/or foraging; - Mitigation for potential light disturbance to bats and other nocturnal species; - Identify and avoid or mitigate for project impacts upon species utilising key crossing points (crossing roads, transmission lines, etc). Mitigation may include, for example, such inclusions as aerial bat crossings, mammal underpasses, speed restricted crossing points and fencing, and / or ERM 103 KasREFF SER RPER SOLAR – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility restrictions upon vehicle movements during key migratory periods or times of day. 6.3 Following construction, re-grade and re-vegetate Best international End of construction Reduced adverse effects on flora and as much disturbed area as is practicable with practices. fauna native grass and shrub species (it is noted that it PR6 will not be possible to fully re-vegetate in areas directly under, or surrounding, solar panels). 6.4 Avoid development within sites protected for Best international Prior to construction Reduced adverse effects on flora and their biodiversity under international or practices. fauna Kazakhstan law (habitats and/or species) PR6 6.5 Avoid, or mitigate for, siting of development in Best international Prior to construction Reduced adverse effects on nature areas important for nature tourism practices. tourism PR6 8. Performance Requirement 8: Cultural Heritage 8.1 Undertake archaeological desk study and site PR8 Prior to construction Survey report, focussed on area of investigations where necessary to identify the proposed construction. likelihood of presence of artefacts or other items of cultural significance.
8.2 Develop measures to avoid direct impacts on PR8 Prior to construction Protection of cultural heritage protected cultural heritage sites and their Include information on finds in ESHS settings (including UNESCO sites and those on report to Bank. the tentative list); and avoid, or where necessary mitigate for, impacts upon Registered Cultural Heritage Sites, Zones and Settlements, and unregistered or previously undiscovered sites by following a staged approach to cultural heritage
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility studies involving qualified expertise and in consultation with the EBRD. 8.3 Before (and if needed, during) major earthworks, PR8 Throughout Protection of cultural heritage ensure the supervision of an archaeologist from a construction Include information on finds in ESHS competent conservatory institution to prevent report to Bank. destruction or theft of found objects and building remains with scientific or material value. 8.4 Develop a chance find procedure PR8 Prior to construction Protection of cultural heritage 8.5 Develop measures to avoid, or where not PR8 Prior to construction Protection of cultural practices and possible to avoid, mitigate for potential loss or resources disruption to cultural practices or resources. Include information on finds in ESHS report to Bank. 8.6 Undertake a Landscape and Visual Impact Best international Prior to construction Protection of landscapes Assessment (LVIA) of the project, including practices. consideration of the potential visual impacts of PR8 the solar photovoltaic panels and associated infrastructure from all relevant viewing angles when considering locations. 8.7 Develop a Landscape Protection Plan following Best international Prior to construction Protection of landscapes the LVIA. Follow the Mitigation Hierarchy: to practices. Avoid, Minimise, Mitigate and Offset likely PR8 adverse effects upon the natural features and landscapes that have archaeological, paleontological, historical, architectural, religious, aesthetic or other cultural significance. This plan to cover the construction and operational phases and to consider the inclusion
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility of the following aspects where applicable: - Screening of works and operations (for example by using natural features such as tree lines, or by careful placement of earthworks); - Sensitive placement and route placement of power transmission lines, access roads and other associated work; and, - Routing of roads and transmission lines along existing cuttings or linear features to reduce on setting. 10. Performance Requirement 10: Information Disclosure and Stakeholder Engagement 10.1 Develop a Stakeholder Engagement Plan, PR10 Prior to construction Review and approval by EBRD including a Grievance Mechanism (SEP) 10.2 Complete EBRD ESIA requirements for Category PR10 Prior to construction Disclosure through suitable means, to be B projects with a disclosure package, to be agreed with EBRD, which could include: agreed with EBRD, comprising of at least the - Flyers to local residents; SEP, this Environmental and Social Action Plan and a Non-technical summary of the - Posters in local venues/ public halls; environmental and social assessment - Information on KazREFF and/or undertaken. developer’s websites; - Public meetings; and/or, - Other, as specified in SEP. 10.3 Implement the agreed SEP, inform stakeholders PR10 Throughout project Include in ESHS report: of activities and progress, and receive and - details on grievances and resolution; respond to grievances.
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility and, - consultations and other outreach to the community, including authorities
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Prepared For: Consultancy Contract C26157REV/JPNS-2013- 02-01 Kazakhstan Renewable Energy Financing Facility (KazREFF) - Strategic Environmental Review
Renewable Project Environmental Review Report – Small Scale Hydropower
June 2014
ERM Japan Ltd. The Landmark Tower Yokohama 19th Floor, 2-2-1 Minatomirai, Nishi-ku YOKOHAMA 220-8119 Japan
The world's leading sustainability consultancy
Contents
1.0 INTRODUCTION 4
2.0 RESOURCE AVAILABILITY AND POTENTIAL 5
2.1 RESOURCE AVAILABILITY 5
2.1.1 Rivers and Watersheds 7
2.1.2 Lakes and Dams 9
2.1.3 SSH resources 10
2.2 RESOURCE POTENTIAL 13
2.3 TRANSMISSION CAPACITY AND CONSTRAINTS 14
2.3.1 Existing Conditions 14
2.3.2 Anticipated Development 18
2.4 EXISTING PROJECTS 19
2.5 KNOWN PROPOSED PROJECTS 19
3.0 AVAILABLE AND PRACTICAL TECHNOLOGIES 21
3.1 TYPES OF SSH 21
3.1.1 Run-of-River 21
3.1.2 Water Storage (Reservoir) 22
3.1.3 Pumped storage 23
3.1.4 Rehabilitation of Existing Hydropower Plants 25
3.2 COMPONENTS 26
3.2.1 Dams, diversions and impoudments (reservoirs) 26
3.2.2 Turbine 27
3.2.3 Generator 28
3.2.4 Powerhouse 28
3.2.5 Penstock 29
3.2.6 Intake 29
3.2.7 Draft Tube and Tailrace 29
3.2.8 Automation System 29
3.2.9 Balance of Plant and Equipment 30
3.2.10 Access Roads 30
3.3 GRID CONNECTIVITY 30
3.4 SITE DESIGN AND CONFIGURATION 31
3.4.1 Construction 32
3.4.2 Commissioning, Operation, and Maintenance 33
3.4.3 Decommissioning 34
3.5 DEVELOPMENT COSTS 34
3.6 SUPPLY CHAIN IN KAZAKHSTAN 35
4.0 ENVIRONMENTAL AND SOCIAL CONSTRAINTS 36
5.0 KAZREFF PROJECT APPRAISAL - ENVIRONMENTAL AND SOCIAL PERFORMANCE REQUIREMENTS 39
5.1 EBRD REQUIREMENTS 39
5.1.1 Category A 40
5.1.2 Category B 41
5.2 KAZAKHSTAN REQUIREMENTS 41
5.3 KAZREFF APPRAISAL PROCESS 43
5.3.1 Initial Screening 44
5.3.2 Documentation Review and Approval/Feedback 44
6.0 APPENDICES 46
1.0 INTRODUCTION
This Renewable Project Environmental Review (RPER) Report for Small Scale Hydropower in Kazakhstan is one of four separate reports (other RPER reports were prepared for solar photovoltaic, wind, and biogas) that have been prepared by Environmental Recourses Management (ERM) for the European Bank for Reconstruction and Development (EBRD). These RPER reports are prepared to support the Kazakhstan Renewable Energy Financing Facility (KazREFF) Strategic Environmental Review (SER) and provide a resource to provide guidance to developers and their consultants, as well as technical evaluators of proposed renewable projects, by identifying areas of good potential and the nature and scale of technologies that can be applied in different parts of Kazakhstan.
Small scale hydroelectric projects (SSH) are defined by the Republic of Kazakhstan as those with nameplate capacities less than or equal to 35 MW (AF-Mercados EMI, 2013).
The source documents which have informed this RPER report are as follows:
• ERM KazREFF Strategic Environmental Review, Final Inception Report, 29 May 2013; • ERM KazREFF Strategic Environmental Review, Draft Scoping Report, 21 May 2013; • Mercados Energy Markets International, Kazakhstan Renewable Energy Market Study, Draft Final Report, July 2013 (ÅF-Mercados EMI (2013)); • Black and Veatch, Renewable Energy in Ukraine Technical Report: Small Hydro, 1 September 2011 (Black and Veatch 2011).
These sources have been supplemented by additional research carried out by ERM and additional sources of data identified in the text.
ERM 4 KasREFF SER RPER SSH – June 2014
2.0 RESOURCE AVAILABILITY AND POTENTIAL
This section of the report identifies the characteristics of the areas of Kazakhstan that would support small scale hydropower projects and defines the areas were SSH development is technically feasible. It also assesses the nature and extent of constraints to SSH development.
2.1 RESOURCE AVAILABILITY
Kazakhstan is the world’s ninth largest country being some 2.7 million km2 in extent. Figure 1 shows the different oblasts of Kazakhstan. The western regions are dominated by extensive lowlands that include Aral and Caspian Seas, while the centre of the country is characterised by rolling hills with peaks up to 1,565 m. The south eastern and south western parts of the country are bordered by mountain ranges. Approximately 10 per cent of the country is occupied by mountains (Figure 2).
Figure 1 Location Map
ERM 5 KasREFF SER RPER SSH – June 2014
Figure 2 Topography Map
About 90 per cent of the Kazakhstan is arid with low humidity, high evaporation, and limited water resources. Water availability is estimated at 20,0001 – 37,0002 m3/km2 and is one of the lowest in Eurasia. Low water availability is a limiting factor for natural and land resources development (T.T. Sarsenbekov, S.K. Ahmetov). Kazakhstan has scarce water resources in comparison with the republics of the European and Siberian parts of the CIS, but it is higher than the Central Asian states. The total annual average surface water river resource is 100.53 km3.
The per capita water supply of Kazakhstan is approximately 6,000 m3 per person per year (UNEP/GRID-Arendal, 2005). Comparison of water resources across a range of years shows a strong water deficit both country- wide and regionally. The water resource deficit under average conditions reaches 60 per cent, and by separate regions (the Central Kazakhstan) only 50- 10 per cent, and the deficit is due to irrigation. An especially critical situation is in the basins of transboundary rivers of Syr-Darya (1.2-3.5 km3), Urals (up to 1.7 km3), Ili, Shu, and Talas. The southern regions were the best provided regions.
The water resource deficit is driven by natural conditions (90 per cent of the runoff takes place during the spring period), formation of about half of the flow (56.5 km3) on the territory of neighbouring countries, extensive use, excessive unrecoverable water consumption for irrigation, and water losses.
1 Sarsenbekov and Ahmetov, undated. 2 UNEP/GRID-Arendal, 2005. 3 http://enrin.grida.no/htmls/kazahst/soe2/soee/nav/water/water.htm
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In addition, the surface water resources in the republic are distributed extremely unevenly and are subject to considerable time (monthly, seasonal) fluctuations.
A key difficulty is a reduction of the quantity and decline of the lake system condition. In addition to water storage, these resources provide natural regulation for water balance and suitable environments for ichthyofauna and ornithofauna habitat. In the last 15 years in Northern Kazakhstan, the lake areas have shrunk by 12 per cent.
2.1.1 RIVERS AND WATERSHEDS
Kazakhstan’s surface water resources consist of four major hydrologic regions, which encompass collections of river basins: 1) the Ob river region draining to the Arctic Ocean, 2) the Caspian Sea region, 3) the Aral Sea region, and 4) internal lakes, depressions or deserts region. Further Divisions are eight Basins Waterworks Departments (BWD) established by the Republic of Kazakhstan to manage water resources. Table 1 summarizes the primary river basins of Kazakhstan and the comparison to the BWDs, which are shown in Figure 3.
Table 1 River basin summaries
ADB Basin Syr Darya Lake Chu-Talas Ob-Irtysh Ural Balkhash
Kazakhstan Aral-Syr- Lake Chu (Shu)-Talas Irtysh, Ishim, Aral-Syr- Basin Darya Balkash - Tobol-Turgai, Darya; Ural Waterworks Alakol Nura-Sarysu Caspii Department
Central Kazakhstan, Kazakhstan Kazakhstan, Kazakhstan Kazakhstan Asian Kyrgyz Kyrgyz countries in Republic, Republic basin Tajikistan, Uzbekistan
Source Naryn and Ili, Karatal, Chu River, fed Irtysh River Ural River Karadarya Aksu, mainly by tributary of rivers Lepsi, Chu- glaciers and the Ob); Sarysu, melting snow; Tobol and Kapal, and Talas River, Ishim Koksu formed by the (tributaries of rivers confluence of the Irtysh the Karakol and River). Uchkosha rivers.
Discharge to Aral Sea Lake Desert sink Arctic Ocean Caspian Balkhash Sea
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Basin area 782,617 512,015 Chu: 62,500; 1,673,470 244,334 (km2) Talas: 52,700;
Total: 115,200
Share of 5.4 1.9 Chu 3.0, Talas: 3 0.9 irrigated 3.0 cropland (% of basin Total: 6.0 area)
Source: excerpt from ADB, 2010
Figure 3 Primary river basins of Kazakhstan
Source: United Nations Development Programme in Kazakhstan
There are approximately 39,000 rivers and streams, 7,000 of which are over 10 km long. Surface water resources are extremely unevenly distributed within the country and are marked by significant perennial and seasonal dynamics. Except for the Tobol, Ishim, and Irtysh rivers (the Kazak names for which are, respectively, Tobyl, Esil, and Ertis), portions of which flow through Kazakhstan, all of Kazakhstan's rivers and streams are part of landlocked systems. They either flow into isolated bodies of water such as the Caspian Sea or simply disappear into the steppes and deserts of central and southern Kazakhstan. Many rivers, streams, and lakes are seasonal, evaporating in summer. The three largest bodies of water are Lake Balkhash, a partially fresh, partially saline lake in the east, near Almaty, and the Caspian and Aral Seas, both of which lie partially within Kazakhstan (Wikipedia, accessed July 2013). Central Kazakhstan has only 3 per cent of total water resources in the country. The western and southwestern regions (Atyrau, Qyzylorda and in
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particular Mangystau region) are significantly water deficit; there is hardly any fresh water. The Balkhash-Alakol and Irtysh (Ertis) river basins in the east and northeast account for almost 75 per cent of surface water resources generated within the country. About 90 per cent of the runoff occurs in spring, exceeding reservoir storage capacity (UNDP, 2003).
2.1.2 LAKES AND DAMS
The Caspian Sea is the largest lake in the world. Its level currently varies significantly. During the 1990s, the Caspian Sea level rose by about 2 m, which resulted in waterlogging of towns and villages, and the loss of agricultural land. On the other hand, the level and volume of the Aral Sea has dramatically decreased, mainly because of irrigation development upstream. This has resulted in environmental problems, which have been tentatively addressed by the Central Asia Interstate Commission for Water Coordination (ICWC).
Excluding the Caspian and Aral seas, there are 48,262 lakes, ponds and reservoirs that cover 45,000 km2 with an estimated volume of water 190 km3. The number of small lakes, with a surface area of less than 1 km2, accounts for 94 per cent of these lakes but only 10 per cent of the total area. There are 3,014 large lakes that have a surface area of more than 1 km2, with a total surface area of 40,800 km2, including 21 lakes that are over 100 km2 with a total surface area of 26,900 km2, or 59 per cent of the total; 45 per cent of all lakes are in the north, 36 per cent in the center and south and 19 per cent in other regions (UNDP, 2003). The largest lakes are: Lake Balkhash, 18,000 km2, volume 112 km3; Lake Zaisan about 5,500 km2; and Lake Tengiz, with an area of 1,590 km2. The main natural depression is the Arnasay depression where Lake Aydarkul, with a capacity of 30 km3, was created artificially with water released from the Chardarya reservoir and with the return flow from the Hunger steppe irrigated land, which is shared with Uzbekistan.
Kazakhstan is dominated by vast desert plains and high mountain ranges to the east of the plains, which create particularities in the normal water cycle where glaciers play an important role, being the only freshwater reservoirs. The majority of glaciers are located in the south and east at more than 4,000 m above sea level. There are 2,724 glaciers covering 1,963 km2. The glaciers contain 95 km3 of water, which is almost equal to the annual flow of all rivers in the country (UNDP, 2003).
More than 200 water reservoirs have been constructed, for a total capacity of 95.5 km3, not counting ponds, small reservoirs and seasonally regulated reservoirs (UNDP, 2003). There are 19 large reservoirs, with a capacity of over 0.1 km3 each, accounting for 95 per cent of total capacity. Most reservoirs are designed for seasonal flow regulation, only about 20 reservoirs are regulated year-round. The largest reservoirs, with a capacity of over 1 km3 are Bukhtarma on the Irtysh River, with a total capacity of 49.6 km3,
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Kapshagay on the Ili River in the Balkhash basin with 18.6 km3, Chardarya on the Syr-Darya River at the border with Uzbekistan with 5.2 km3, Shulba on the Irtysh River with 2.4 km3. Most are multipurpose: hydropower production, irrigation and flood control. The reservoirs in the eastern and southeastern regions are mainly used for agriculture and in the central, northern and western regions for drinking water and industry. Bukhtarma, Shulba, Kapshagay and Chardarya are all connected to hydroelectric power stations to generate electricity (UNDP, 2003 and 2004).
Reservoir capacity in the Irtysh river basin is the largest in Kazakhstan. Besides the Bukhtarma and Shulba, an additional reservoir has been constructed on the Irtysh River, the Ust-Kamenogorsk reservoir, total capacity 0.7 km3, which regulates the river’s flow (UNDP, 2004).
2.1.3 SSH RESOURCES
Kazakhstan appears to have significant SSH potential albeit somewhat restricted to the more mountainous and forest steppe regions of the country based on the two key elements of water availability and the usefulness of that water in space and time relative to the practical considerations of energy demand timing and demand centres. According to the Ministry of Environmental Protection of the Republic of Kazakhstan (MEP) and other sources, the most significant hydro resources are concentrated in the East and South regions of the country on rivers Irtysh, Ili and Syrdarya.
Favourable regions include the area beginning in the northeast adjacent to the Russian border and following the eastern and south-eastern borders along China and Kyrgyzstan. Based on ERM’s analysis presented below, there may also some hydro potential in the northwest region of Kazakhstan in the Ural- Caspii River Basin. The climate, hydrology, and geography of the inner expanses of the country do not readily lend themselves to hydropower development although there may be occasional opportunities associated with multi-purpose projects. Figure 4 shows these areas of greatest SSH potential.
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Figure 4 Areas of significant SSH potential in Kazakhstan
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In addition, ERM developed a simple methodology for evaluating hydro potential for sample riverine locations associated with known river flow gauges. The first step was to establish the typical grade or slope and potential elevation difference that may be available as net head or stage difference at each gauge. This was accomplished by considering elevation differences based on data acquired from the digital elevation models (DEMs). Elevations were assessed at 5 km upstream and 5 km downstream of the known gauge. The difference in these elevations was assumed to be the potential available head. A flow-duration curve was prepared for each gauge. The flow at 20 per cent exceedance was utilized to establish the theoretical turbine capacity for a hypothetical project and then energy for each 5per cent increment in exceedance from the flow-duration curve was calculated to roughly establish the overall energy available from the system based on the assumed criteria. No attempt was made to optimize the potential power either in terms of number of units, size of units, or types of runners. The capacity factor for the system was then determined by taking the calculated energy divided by the theoretical maximum energy. This approach provides a coarse determination of potential for hydro from these gauge locations.
The analysis indicated a total energy and power potential of approximately 314 GWhs of energy and 57 MWs of capacity for these 8 gauges as presented in Table 2. These preliminary estimates are based on run-of-river type operations with no consideration for storage. Capacity factors ranged from 41 per cent to 69 per cent which are well within the range of capacity factors for viable hydropower projects. Based on flow-duration curves developed from each gauge, there is sufficient potential energy to warrant an investigation as to probable hydropower development in certain regions as identified and ranked in Table 3. A simplified ranking of rivers based on a limited review of gauge data indicates that the Chu-Talas, Irtysh, Aral-Syr- Darya, and Ural-Caspii basins have the highest potential for hydro development. The Chu and Ural Rivers produce the largest capacity and highest energy opportunities based on this limited analysis. It is important to note that more up to date flow information should be considered and evaluated prior to any decisions regarding these rankings.
Table 2 Energy estimate summary - eight gauges
Gauge Energy Average Estimated Capacity Basin Location; River (GWh) flow head (m) factor landform region (m3/s) Chu 84.31 68.6 18 69 % Chu Southern (Shu)- Kazakhstan; Talas mountain/desert interface Ilek 1.71 15.2 7 44 % Ural- Northwest Caspii Kazakhstan; steppe Ishim 32.83 38.6 42 41 % Irtysh North-central
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Kazakhstan; forest steppe Karatal 19.16 55.8 6 60 % Balkash- Southeastern Alakol Kazakhstan; Mountain/desert interface Karaturgay 0.30 9.1 3 48 % Tobol- Central Turgai Kazakhstan; steppe Nura 6.80 11.1 18 42 % Nura- North-central Sarysu Kazakhstan; steppe Syr-Darya 32.72 547.5 1 62 % Aral-Syr- (Mainstem river) Darya south-central Kazakhstan; desert Ural 83.83 297.8 8 44 % Ural- (Mainstem river) Caspii Northwest Kazakhstan; steppe
Table 3 Relative ranking of hydropower potential (1 = highest, 8 = lowest)
Gauge Energy Flow Head Capacity Rank Sum Basin River factor
Chu 1 3 3 1 8 Chu (Shu)-Talas
Ural 2 2 4 5 13 Ural-Caspii
Syr-Darya 4 1 8 2 15 Aral-Syr-Darya
Ishim 3 5 1 8 17 Irtysh
Karatal 5 4 6 3 18 Balkash-Alakol
Nura 6 7 2 7 22 Nura-Sarysu
Ilek 7 6 5 6 24 Ural-Caspii
Karaturgay 8 8 7 4 27 Tobol-Turgai
2.2 RESOURCE POTENTIAL
Due to Kazakhstan’s hydropower potential and the increased demand for electricity in the country, the RoK government issued a series of actions and targets for the hydropower development. “The Action Plan for development of alternative and renewable energy in Kazakhstan for 2013-2020 (herein after called “Action Plan”)” was issued in 2013. The Action Plan calls for the
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implantation of 31 RES facilities with 1,040 MW total capacity by 2020 with 14 hydropower stations totalling a capacity of 170 MW (includes large and small scale hydropower).
The second plan, the “CONCEPT for transition of the Republic of Kazakhstan to Green Economy (herein after called “CONCEPT”)” was approved by the President of the Republic of Kazakhstan in May 2013 and integrated scenarios for power sector development from 2030 and 2050. This plan calls for a total hydropower capacity (including large and small scale hydropower) of 4 GW by 2030 through 2050. Given that Kazakhstan is currently generating approximately 3 GW from hydropower, the plan is calling for the development of an additional 1 GW by 2030.
Kazakhstan has very large coal, oil, gas and uranium resources that are all being actively exploited. The country is the third largest producer of crude oil in Central Asia, behind Russia and China and has the third largest reserves outside of the OPEC member countries. One result of the abundance of energy resources has been the lack of a driver for developing hydroelectric energy on the basis of a scarcity of indigenous energy resources. Nevertheless, other drivers needed to be (and were) identified such as the need to reduce greenhouse gas emissions, to strengthen local power supply and to act as an economic stimulus4.
2.3 TRANSMISSION CAPACITY AND CONSTRAINTS
To realise the SSH potential of Kazakhstan, specific locations will need to be in proximity to existing transmission lines and the existing electricity grid will need to have adequate capacity to receive the power generated. Sites that are situated a great distance from load centres or major transmission lines face greater development costs and are generally less favourable than sites with better access to these facilities. Larger projects are able to locate farther away from transmission while smaller projects are located closer to transmission, due to economies of scale of larger projects to absorb higher transmission costs5.
2.3.1 EXISTING CONDITIONS
The grid in Kazakhstan is state-owned and operated by the Kazakhstan Electricity Grid Operating Company (KEGOC). There are also 21 regional energy companies (RECs) that distribute electricity on a regional monopoly basis. Due to the size of Kazakhstan the network is characterised by long distance transmission. The Kazakhstan transmission network dates back to the Soviet era and has a history of underinvestment. However at present it
4 Lessons learnt from the UNDP-GEF project “Kazakhstan — Wind Power Market Development Initiative, UNDP Kazakhstan, 2011. 5 Black & Veatch 2011
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has sufficient capacity and no voltage problems. The majority of the population is connected to the grid, less than 5 per cent of the population, located primarily in rural areas, are without electricity. However, in some areas power cuts or discontinuous supply are not uncommon due to grid capacity issues and a lack of local generation facilities. In addition, in some regions the industrial base has expanded and investment in power infrastructure has failed to keep pace. Figure 5 shows the areas of greatest population density and domestic energy demand in Kazakhstan.
Figure 5 Population Map by Oblast
The electricity grid is separated into three regions west, north and south (Figure 6). It has a general north-south split in generation and demand with approximately 80 per cent of the electricity being produced in the north near coal reserves and 70 per cent being used in the same industrialised region (UNDP/GEF 2011). The transmission system operates at 500 kV and 220 kV and consists of 24,101 km of 35 - 1150 kV overhead transmission lines and 74 power substations with an installed capacity of 34,408 MVA (see Figure 7). A 1,100 km 500 kV electricity transmission system has connected the north and south regions since 2009. Due to demand growth in the southern zone the transmission lines connecting north and south are fully loaded, and in the period of peak demand (winter) they are reported to be occasionally overloaded.
The northern electricity grid contains links to Russia and Central Asia and the southern network contains links to Kyrgyzstan and Uzbekistan. The west of the grid is isolated from the remainder of the national electricity system and has interconnections with Russia.
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From 2011 to 2013 power consumption significantly exceeded energy production, which, taken into account transmission losses has highlighted a deficit of approximately 800 MW. This deficit is currently overcome by importing electricity from neighbouring countries. Demand is projected to reach 145 TWh by 2030 from the current level (CAGR of 2.6 per cent) (Åf- Mercados EMI 2013).
Figure 6 Transmission Regions in Kazakhstan
658 209 700 1173 1180 390 3195 480 850 1720 1609 700 160 95 337 1823
348
90 1862 160
160 320 1020 860 1620 1020
Source: Åf-Mercados EMI (2013)
The proximity of existing transmission lines to areas of high SSH potential creates conditions that favour the successful integration of SSH development in Kazakhstan. In particular developing SSH projects in the south could help solve the problem of the overload of the north-south transmission lines. The northern zone has an excess of generation, but development would still be an advantage in order to reduce the power imports from neighbouring Russia. The western grid operates separately and currently has a load shortage of about 100 MW, which is also covered by power import from Russia. Unfortunately, it does not appear that there is significant SSH development potential in this part of the grid that could reliance on imports from Russia.
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Figure 7 Transmission System Map
Information published by the Design Research Institute “Kazgidro” LLP was available to provide a general assessment of the SSH potential in Kazakhstan. This information, along with grid capacity information, is presented in Table 4.
Table 4 SSH Potential and Grid Capacity in Kazakhstan
Region Subregion SSH Sum SSH Grid Potential a Potential for capacity b (MW) Region (MW) West Kazakhstan 0 West Atyrau 0 0 601 Mangystau 0 Qyzylorda 142 South Kazakhstan 142 South 1230 718 Jambyl 134 Almaty 812 Aqtobe 3 Kostanay 3 North Kazakhstan 0 North Aqmola 3 411 2,708 Pavlodar 0 Qaraghandy 3 East Kazakhstan 399
TOTAL 1,641 4,027
a Design Research Institute “Kazgidro LLP” b Based on expert judgement, taking 20 per cent of installed capacity as the guiding rule of thumb. Source: Åf-Mercados EMI (2013)
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Table 4 also provides an overview of the distribution of SSH power in Kazakhstan and the grid capacity by region.
The table shows that there is little SSH potential in the West grid and ample capacity; therefore, any SSH development in this part of the grid could be installed with little adverse impact. Additional the North grid could accommodate the entire potential for SSH development. Development of SSH in the South grid area, which also has the greatest potential, is constrained by the grid capacity. Based on this information, only approximately 60 per cent of SSH potential could be connected to the grid in its current state. In order for Kazakhstan to achieve its entire potential for SSH development the South grid would require upgrading. However, the proposed target of generating an additional 1,000 MW by hydropower, including SSH, generated by 2030 are achievable with the existing transmission grid.
There are some additional considerations that need to be taken into account which may present barriers to SSH development. The west, due to its isolation may have stability problems if no grid development projects are implemented. For a power grid to remain stable, the frequency and phase of all power generation units must remain synchronous within narrow operational limits. SSH power generation is not constant and as the western grid has limited connections it may not be able to handle small frequency changes. The north, however, has a balancing advantage, due to sufficient transmission capacity to the Russian grid, which has a relatively stable power system. This region also has the highest potential capacity and strong connections to the southern region.
2.3.2 ANTICIPATED DEVELOPMENT
The suitability of the above regions for development of SSH power assumes that there is no investment in the electricity grid of Kazakhstan. However it should be noted that considerable network development both on-going and planned is being undertaken by Government of the RoK and KEGOC.
Projects planned, or currently being implemented, include:
• Modernization of the national electrical network (NEN) to be completed by 2016. The project comprises reconstruction of the majority of substations and construction of some new transmission lines; • Construction of a 500 kV substation "Alma" ( located in the area of Almaty) with connection to the NEN This will eliminate the overloading of existing "Almaty" substation and ensure the reliability of power supply to the Almaty region; and
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• Reconstruction of a 220 kV overhead line central main substation in Astana.
There are also plans for connecting the western grid to the national grid by 2030.
2.4 EXISTING PROJECTS
Hydropower is well developed in Kazakhstan and there are many active large hydropower plants and SSH plants operating; these are presented in Table 5.
Table 5 Existing Hydropower Plants
Power plant Generation Power capacity (MW) produced (GWh) Large Hydropower Plants TOO "AES Shulbin HPP" 702.0 1,446.1 Buhtarmin HPP AO "Kazcink" 675.0 2,541.2 Kapshagajsk HPP AO "AlJeS" 364.0 1,000.0 Ust-Kamenogorsk HPP 331.2 1,496.7 Moinak HPP 300.0 1,000.0 Shardara HPP 100.0 400.0 GTS KPK 50.0 200.0 Cascade of Almaty HPP AO "AlJeS" 49.2 210.0 SSH TOO "LKHPP Company" 13.8 50.0 Karatal HPP-1 10.1 60.0 HPPs of Taldykorgan 7.1 20.0 Issyk HPP-2 TOO "JenergoAlem" 5.1 10.0 Karatal HPP-2 4.4 10.0 Karatal HPP-3TOO ASPMK-519 4.4 10.0 Karatal HPP-4 TOO ASPMK-519 3.1 12.7 RPG Severvodkhoz 1 HPP at Ishim river 2.0 5.8 TT-Group 1 HPP at Aksu river 2.0 6.5 Zaisanskaya HPP 2.0 7.3 Hydroenergy Company 2 HPP at Merke river 1.8 5.2 Georgievskaya HPP 1.7 4.9 Remkomstroy 1 HPP at Merke river 1.5 4.3 Urdzharskaya HPP 0.2 0.6 Source: Åf-Mercados EMI (2013)
2.5 KNOWN PROPOSED PROJECTS
Mercados identified additional known planned large scale and SSH projects in their market study. These are presented in Table 6. All of the proposed SSH projects identified below are located in Almaty oblast in the south grid.
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Table 6 Planned Hydropower Development
Power plant Year Generation Power capacity (MW) produced (GWh) Large Hydropower Plants Bulkakskaya HPP 2015 68.0 200.0 Kerbulak HPP 2016 40.6 140.1 Expansion of Shardara HPP 2016 16.0 64.0 Expansion of Cascade of Almaty 2016 12.8 44.2 HPP Expansion of Kapshagajsk HPP 2016 70.0 241.4 Planned HPP in South 2017 40.0 160.0 Kazakhstan Planned HPP in East Kazakhstan 2017 1007.0 4671.0 Planned HPP in Almaty 2017 1023.5 4716.9 SSH Karatal river SSH 2014 3.5 19.3 Issyk river SSH 2014 5.0 27.6 Baskan river SSH 2014 4.4 24.0 Source: Åf-Mercados EMI (2013)
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3.0 AVAILABLE AND PRACTICAL TECHNOLOGIES
This section looks at the type of technology that would be employed for SSH development in Kazakhstan. It details the types of SSH, components of typical projects, and the key activities to be take into consideration for the construction, operation, and decommissioning of a potential site. It also discusses the current status of the hydroelectric power supply chain in Kazakhstan.
3.1 TYPES OF SSH
Small scale hydroelectric projects (SSH) are defined by the Republic of Kazakhstan as those with nameplate capacities less than or equal to 35 MW (Af-Mercados Emi, 2013). SSH differs from large scale hydroelectric development primarily in the storage of water and the infrastructure and equipment required. Large scale hydroelectric generally involves development of high head dams and reservoirs with large storage capacities. SSH relies on smaller head structure and operate with low or near zero storage. These types of facilities are called “run-of-river” because they operate based on the natural hydrology of the river, though they may have some storage capacity for peaking or pulsing. Other SSH may involve storage reservoirs that are less dependent on the natural river flows and provide more predictability and control over energy generation by providing for at least several days of storage. This section also describes pumped-storage, which is not typically SSH, but may present some potential for integration with other renewable energy projects such as solar and wind since it can act as a “battery” and provide energy when solar and wind projects are not generating. The following sections describe in more detail these types of hydroelectric projects.
3.1.1 RUN-OF-RIVER
In a run-of-river development, the natural flow of the river remains relatively unaltered with the potential exception of water chemistry, most notably oxygen or temperature. If the flow is diverted, then there is the potential for significant change in the flow of water in a specific reach of the river (the bypass reach). A run-of-river project does not require a large reservoir and projects tend to be on a smaller scale. Run-of-river projects require a consistent and steady flow. Typically, a run-of-river plant has storage for no more than 48 hours of water supply. Figure 8 shows a schematic of a run-of- river hydropower project.
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Figure 8 Typical run-of-river hydroelectric project
Source: www.cleantechinvestor.com
The advantage of a run-of-river project is that it typically has a smaller environmental footprint than other types of projects and potentially smaller impacts to the environment. The disadvantage of a run-of-river project is the lack of storage; therefore, lower reliability in terms of power or capacity. Simply put, run-of-river projects can be similar to solar and wind projects in terms of intermittency and lack of dispatchability.
3.1.2 WATER STORAGE (RESERVOIR)
Storage regulation developments are projects that include a reservoir that captures water during times when less energy is required and stores it for use during times when it is needed. Conventional storage water projects are not usually considered “small hydro” but in order to differentiate the alternative forms of hydro, this discussion has been included. Figure 9 shows a typical water storage hydroelectric project cross-section.
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Figure 9 Typical hydroelectric project with storage
Source: Black & Veatch (2011)
Alternating current (AC) electrical energy is a product that is consumable only at the time it is manufactured; therefore, has no direct storage. To overcome the inability to store the product, potential energy is stored in the form of water in a reservoir. Through storage, a project becomes dispatchable and thus has assigned capacity. These types of projects can have secondary or ancillary benefits such as flood control, irrigation, water supply, and recreation opportunities. The challenge for projects of this type is the relative impact they may have on natural river flow as well as the upstream areas that they may permanently flood to develop the storage. Additional concerns are associated with potential impacts on the aquatic habitat and populations, downstream water availability, sediment budget and the eventual long terms effects that will occur both upstream and downstream of these projects as the river system equilibrates to the new hydrologic regime.
3.1.3 PUMPED STORAGE
An important observation from this review of hydro potential (albeit not directly associated with SSH but directly correlated to renewable resources) is the opportunity for pumped storage projects in support of other forms of renewable resources. There appears to be excellent opportunity in Kazakhstan to develop wind and solar power in which pumped storage hydro could serve as an outstanding partner to firm these otherwise variable, intermittent forms of energy. Pumped storage systems also provide ancillary electrical grid services such as network frequency control and reserve generation. This is due to the ability of pumped storage plants, like other
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hydroelectric plants, to respond to load changes within seconds. Pumped storage hydropower is the largest and most reliable form of energy storage available for alternating current electricity. Given the combined opportunity to develop wind and solar in the country’s interior and the potential for hydro along Kazakhstan’s borders, there is an apparent natural complement among these renewable energy resources that could be exploited as part of a larger, low carbon, renewable resource initiative.
Normally, a discussion concerning pumped storage would not be included in a review of SSH; however, since pumped storage may be a very important part of the overall generational mix associated with the overarching discussion of renewable energy sources including wind and solar, it has been included from a contextual perspective. Pumped storage is a type of hydroelectric power generation that stores energy in the form of water in an upper reservoir, pumped from a second reservoir at a lower elevation. During periods of high electricity demand, the stored water is released through turbines in the same manner as a conventional hydro station. Excess energy, usually at lower cost during the night and on weekends, is used to recharge the reservoir by pumping the water back to the upper reservoir. In the context of integration with wind and solar, it may be possible to use excess solar energy during the day to recharge a pumped-storage reservoir and use the hydroelectricity at night. For wind, the reservoir could be recharged when wind is driving turbines and generation switched to hydroelectric when the wind is low. In both cases, this integration must build-in excess capacity in the solar or wind facilities to provide capacity to recharge the reservoir. Figure 10 presents a schematic of a pumped storage system.
Figure 10 Typical pumped storage system
Source: Hydro Equipment Association
Reversible pump/turbine and motor/generator assemblies act as both a pump and a turbine. Pumped storage stations are unlike traditional hydro stations as they are a net consumer of electricity. In reality, pumped storage plants are transmission facilities and they can be very economical, from an
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overall system operation perspective, due to peak/off-peak price differentials and, more importantly, the provision of ancillary grid services.
Pumped storage historically has been used to balance load on a system and allow large, thermal generating sources to operate at optimum conditions. Pumped storage is the largest-capacity and most cost-effective form of grid energy storage currently available. Pumped storage systems also provide ancillary electrical grid services such as network frequency control and reserve generation. This is due to the ability of pumped storage plants, like other hydroelectric plants, to respond to load changes within seconds. The original economic model that supported or justified pumped storage projects was associated with large, base load thermal cycle facilities such as nuclear that could not easily be modulated. Pumped storage offered an opportunity to take advantage of the cheaper, off peak excess energy to pump and then utilize that storage during peak, higher price periods to support overall demand.
Pumped storage is now being applied to firm the variability of renewable power sources, such as wind and solar generation. Pumped storage can absorb excess generation (or negative load) at times of high output and low demand, and release that stored energy during peak demand periods, proving to be an enabling technology for growing renewable power.
Wind power is a generating technology that is included in many countries’ electrical systems and permits a substantial reduction in emissions of greenhouse gases. However, the increasing penetration of this technology in current electricity systems requires a substantial increase in the resources required to balance generation and demand, as well as additional investments to guarantee the continuity of electricity supply when wind intensity is low.
Of all of the available technologies in current electricity systems, pumped- storage plants constitute the most attractive option for firming the variability of wind. Accordingly, Iberdrola is involved in the development of several of these plants. When completed in 2018, they will provide nearly 1,750 MW of capacity to the electrical system in Spain and Portugal (Montero and Pérez, 2009).
Given the flow-duration characteristics of many of the rivers and basins in Kazakhstan where there are large but very short flow periods, pumped storage may be an alternative worthy of investigation and consideration.
3.1.4 REHABILITATION OF EXISTING HYDROPOWER PLANTS
Rehabilitation of existing hydro projects entails rehabilitating and/or replacing one or more components at an existing facility, while utilizing some or most of the existing infrastructure. Many of these sites have old dams as
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well. When rehabilitating an old facility, careful attention to the civil, electrical, and mechanical components is critical to evaluating rehabilitation needs and estimating the cost of the project. Blending old construction with new is challenging. This is particularly true with civil works such as dams, penstocks, gates, draft tubes, intakes and powerhouse. Mechanical and electrical equipment such as generators, turbines, wicket gates, intake gates and trash racks, governors, substations and control panels all require careful and detailed inspections to assure that rehabilitation is feasible and cost effective compared to complete replacement. Antiquated control panel components are usually replaced because control equipment is usually matched to mechanical and electrical equipment.
Building a new facility is typically more straight forward but costs are higher per kilowatt of installed capacity. It is easier to demolish a facility and build from the ground up compared to retrofitting in components that are rebuilt, repaired, and/or rehabilitated into civil structures. However, there may be advantages to refurbishing an existing facility that already has environmental impacts, rather than in areas without any hydro structures in place.
3.2 COMPONENTS
Traditional hydroelectric power is generated by converting the potential energy of water as it moves from a higher elevation to a lower elevation and passes through a turbine to drive an electric generator. The amount of kinetic energy captured by a turbine is a function of the head and the water flow rate through the turbine. The building blocks for the projects identified in the SER are generally the same. They include turbines, generator sets, powerhouse, penstock, intake, control systems, and tailrace. The hydropower facilities considered in this report use the same general components but may require somewhat different configurations.
3.2.1 DAMS, DIVERSIONS AND IMPOUDMENTS (RESERVOIRS)
An impoundment is the general classification for a structure that is built across a river used to support a variety of water related purposes. A dam is a type of impoundment that can be large or small that is used to provide head or store river volume. A diversion is another type of impoundment. It typically is a dam at a lower elevation that channels or directs all or a portion of river flow towards an intake or other water control structure. Usually, the potential head and flow rate for a hydroelectric facility improves with the construction of a dam and reservoir. This, in turn, increases the potential installed hydroelectric turbine and generator capacity. This is accomplished by increasing gross head, storing inflow, providing increased discharge to the turbine-generator set, and retaining excess river flow as stored volume at a higher head for use at a later date.
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3.2.2 TURBINE
All hydropower facilities include turbines for power generation. There are two primary types of turbine classes that are used for hydroelectric power generation: impulse turbines and reaction turbines, with design variations available for each class.
Table 7 displays turbine designs by class, typical installed capacity range and hydropower facility type where they are installed. It is important to note where overlaps in turbine type selection occur. They are due to other factors (cost, flow variability, for example) that are important in the selection of turbines for a given installation. From Figure 11, note that for a 10 MW or less installation (micro, mini, and SSH), all of the turbine designs listed in Table 7 may be suitable, depending on site conditions. Environmental impact considerations are generally the same for any turbine type. Water quality characteristics are generally the same comparing upstream and downstream flows. Turbines do allow for some alteration of dissolved oxygen by injection and a small hydro project can increase dissolved oxygen by allowing spillway discharge of river flow. Some differences that exist for these turbines include fish passage--possible for reaction turbines and not possible for impulse turbines.
Table 7 Turbine types
Turbine Turbine Class Capacity Range Facility Types* Design (MW) Pelton Impulse 0.5 – 150 M, Mi, S, Med, L Crossflow Impulse 0.1 – 1.0 M, Mi
Turgo Impulse (variant of Pelton) 0.75 – 5.0 M, Mi, S
Francis Reaction (fixed runners) 0.5 – 800.0 Mi, S, Med, L
Kaplan Reaction (variable pitch 0.1 – 100 M, Mi, S, Med runners) M=Micro (<0.1 MW) Mi=Mini (0.1 MW – 1.5 MW) S=Small (1.5 MW – 30 MW) Med=Medium (30 MW – 100 MW) L=Large (100 MW+) Source: Black & Veatch (2011)
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Figure 11 Turbine applications
Source: Black & Veatch (2011)
3.2.3 GENERATOR
The generator is connected and rotated by the turbine. The turbine turns a shaft which rotates a series of magnets past copper coils and a generator to produce electricity. Electricity is produced as the rotors spin past the stationary wiring. Hydropower generators (as with other power generation) are matched and sized to the hydro turbines that rotate them. In Figure 11, the black lines labeled MW are the capacity rating of the generator that will produce that level of generation given the turbine type, flow and head selected.
3.2.4 POWERHOUSE
The powerhouse is a structure, typically reinforced concrete of one or two levels (stories), of which its primary function is to house the turbine(s), generator(s), control systems, and related equipment. Depending on where the powerhouse is sited it can be made as a watertight facility (if located in a floodplain) to prevent flood waters from damaging the generator and other electrical equipment housed inside. Often electricity is routed from the powerhouse to a step-up transformer for interconnection to a transmission line, but it is also possible for the transformer to be housed within or on top of the powerhouse.
Other facilities typically housed within the powerhouse structure may include the bypass or in-stream flow release valve and shutoff valves for use when the turbine is to be taken out of service or in cases when the flows exceed the capacity of the turbine. If these components are not able to be housed within the powerhouse then a separate valve house structure will be needed. Also contiguous to the powerhouse is the draft tube and tailrace that
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return turbine discharge to the receiving river. Some micro and small mini hydro projects may not require a powerhouse at all and are designed to be exposed to all weather operations. Pipeline installations, where the turbines are installed directly in the pipes, are an example where a powerhouse is not always required.
3.2.5 PENSTOCK
The penstock is a pipeline which directs water from the inlet at the intake structure or dam and conveys it to the powerhouse. These are often above ground for small scale hydropower facilities but may be tunnelled as well. Penstocks may be elevated above ground if needed, and penstock components may include thrust blocks, expansion joints, supports (roller or fixed), flow meters, and valves and appurtenances. Access to the penstock is needed for inspection and maintenance activities
3.2.6 INTAKE
An intake directs water flow into the penstock(s). In a run-of-river system, and intake weir is constructed to draw water from the river creating a small “headpond” of water. As part of an impoundment structure or an intake facility, intakes require some similar design components. For example, an intake will need to be screened with a steel grate to prevent elements such as large logs from entering the penstock. Intakes will also need to have a valve installed so that flow to the penstock can be stopped for inspection and maintenance of the penstock, or in the case of emergency shutdown of the penstock.
3.2.7 DRAFT TUBE AND TAILRACE
The draft tube conveys water from the turbine discharge to the tailrace and dissipates its energy such that impacts to the receiving body of water are minimized. It is hydraulically important and if poorly designed can increase hydraulic friction losses significantly, thereby decreasing available gross head and overall generation potential. The tailrace is the connector channel (typically an open channel that returns turbine discharge from the draft tubes to the water source at reasonable open channel flow velocities. Designs vary depending on turbine type. Poorly designed tailraces can also decrease net head and increase hydraulic losses.
Cut-off gates or stop logs are usually included in tailrace design to isolate the tailrace from the draft tube for turbine and draft tube maintenance.
3.2.8 AUTOMATION SYSTEM
These are the systems that are used to adjust settings on the turbine and generator, and control the transfer of electricity from the hydropower project
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to the substation. The important environmental feature of control systems is the use of telemetered environmental data as input to decisions related to how the hydropower project is operated. The data can include, for example, river flow and hydropower discharge, quality parameters for supporting low flow, fisheries, water quality (pollutant levels), reservoir elevation, environmental releases, and or other required discharges.
The hydro facilities considered in this report contain most or all of these components. Since the hydro projects are 35 MW or below, they fall into three typical size classes -- mini, micro, and small. Table 7 identifies these size ranges for the hydropower project components. In reality, the dimensions can vary widely based on a number of site specific conditions.
3.2.9 BALANCE OF PLANT AND EQUIPMENT
Typically, Balance of Plant and Equipment includes the equipment/systems such as power transformers, power evacuation systems, auxiliary transformers, control cables, switchgears, battery & battery chargers, and lighting. It may also include cooling water systems, drainage systems & dewatering systems, compressed air system, and HVAC systems. Even though these particular components may not be part of the primary generation associated with a hydroelectric plant they are equally important to the ultimate generation, transmission, operations and maintenance of the overall plant and as such, just as critical. Facility reliability and availability is in many cases, driven by the performance of the ancillary and support equipment.
3.2.10 ACCESS ROADS
During the construction and operation phases SSH facilities will normally require adequate means of vehicular access. Stone and aggregate for access tracks and hard standing, concrete and steel for foundations, and cabling to transfer electricity, for example, will all need to be transported to site.
3.3 GRID CONNECTIVITY
Hydro plants use water flow to spin a turbine that drives an induction generator. Induction generators require reactive power, depending on the output power and power factor correction, which can cause self-excitation, thus increasing harmonic content. Increasing harmonic content can create stability concerns for an interconnection, especially within weaker power systems (e.g. radial distribution lines). Induction generators also have sub transient reactance inherent to the machine, which contributes to high fault current at lower voltages. Different padmount transformer configurations can also increase or decrease the amount of fault current onto the system, so it is important to design the system to keep the zero sequence impedance to a minimum, but still have a ground reference (so no overvoltage scenarios
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occur). Series neutral reactors or resistors can be added to the neutral connections of the collection system to increase the zero sequence impedance, thus decreasing the fault current.
Hydro projects up to 35 MW in size should typically be interconnected at distribution voltages. It is usually too costly to facilitate an interconnection at a higher voltage; however, there are no technical constraints to doing so. At distribution voltages, it is more reliable to interconnect directly to a substation, not tap a line, due to the fault contribution to the system. This type of interconnection would require a generation tie line from the project site to the substation, so siting of the tie line may pose an issue.
Ancillary benefits for hydropower include electric grid services such as load following, the ability to produce power when electricity demand is highest, and the ability to turn on quickly. The value of hydropower includes operating efficiency improvements, fleet support, technology upgrades to increase operating range and services, and faster co-optimization in electricity markets.
The operation of electricity systems depends on rapid and flexible generation sources to meet peak demands, maintain the system voltage levels, and quickly re-establish supply after a blackout. Energy generated by hydroelectric installations can be injected into the electricity system faster than that of any other energy source. The capacity of hydroelectric systems to reach maximum production from zero in a rapid and foreseeable manner makes them exceptionally appropriate for addressing alterations in the consumption and providing ancillary services to the electricity system, thus maintaining the balance between the electricity supply and demand.
Hydroelectric power plants with accumulation reservoirs offer incomparable operational flexibility, since they can immediately respond to fluctuations in the demand for electricity. The flexibility and storage capacity of hydroelectric power plants make them more efficient and economical in supporting the use of intermittent sources of renewable energy, such as solar or wind energy.
3.4 SITE DESIGN AND CONFIGURATION
There are many factors which establish the feasibility of a potential site for the development of new hydropower projects and contribute to the determination of which facilities are most appropriate for a particular site. Chief among such considerations are the head and flow characteristics of a particular site, which dictate the power capacity and energy production capability of a facility at that site. The availability of such data also plays a role in the selection of an appropriate site.
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The quality of the resource is an obvious primary consideration; however, there are some other significant issues in Kazakhstan, identified in the SER that should be considered when siting power facilities:
• Cumulative impact of water availability - Consideration should be given to the impact of other hydropower facilities upstream on the same river reach on the operation of any planned SSH facility. Operation and activities at upstream hydropower facilities can adversely affect the availability of water resource for potential development downstream. In addition, the potential for developing downstream resources is impacted by siting a new facility and should be considered.
• Seismicity, mudflows, and landslides - Geology, geotechnical, and seismic conditions must be considered and evaluated. These will guide design and identify potential hazards such as risk/landslide potential, earthquake and vibration events and overall structural stability of the project area. The designs should consider low probability events such as major earthquakes (consistent with the seismic potential and history of the area) and the effects of land or rockslides that can catastrophically enter a reservoir, creating tsunami-like waves or at a smaller scale, suddenly overtop the dam.
• Proximity to transmission grid and loading – In general, facilities should be located proximate to existing substations with capacity on the transmission grid. SSH power facilities become to become less economical at increasing distances from substations due to the costs associated with extending distribution or transmission lines to the power plant.
3.4.1 CONSTRUCTION
Construction activities will vary significantly for a new project with an impoundment as compared to a retrofit project. Major construction activities are identified in the following sections for each of these project types.
3.4.1.1. SMALL HYDRO
Major on-site construction activities associated with a new impoundment hydropower project will vary from project to project, but significant activities will likely include:
• Topographical survey; • Hydrological analysis of long term stream flow; • Geotechnical investigations and drilling; • Construction of access roads; • Installation of river diversion;
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• Mobilization of cranes and other major equipment; • Excavation works for temporary and permanent civil structures (dam, waterway, powerhouse); • Construction of concrete or earthen dam, including vibration and compaction of material; • Installation of hydraulic steel structures; • Placement and installation of major equipment, valves, turbines, generator; and • Installation of electrical work (conduits, station power, transformer, transmission lines).
3.4.1.2. RETROFIT AND REHABILITATION AT EXISTING AND RETIRED SITES
Constraints to the site, limited work space, potential for damage to existing but usable facility components and structures is significant, and safety on the worksite is more challenging. Environmental control of construction materials, liquids, waste disposal, and flood protection are all more challenging in an old site being rehabilitated versus a new construction site. Construction work and site plans are important planning and operational tools. Pollution Prevention Plans need to be developed and included in site work plans.
Major on-site construction activities associated with a retrofitting an existing hydropower project will vary from project to project, but significant activities will likely include:
• Installation of hydraulic steel structures; • Placement and installation of major equipment, valves, turbines, generator; • Installation of electrical work (conduits, station power, transformer, transmission lines); and • In cases, where the civil works need refurbishment as well certain existing structures are rehabilitated.
3.4.2 COMMISSIONING, OPERATION, AND MAINTENANCE
Once construction is complete, the SSH plant is commissioned. Commissioning involves standard tests for electrical infrastructure and turbines.
Throughout the construction and development stages, regulatory review and compliance oversight will occur in which authorities must be assured that the project will operate as close as possible to the anticipated project criteria and established limits.
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3.4.3 DECOMMISSIONING
The projected operational lifetime of a typical hydropower plant is 40 to 50 years. After this period there are two options, repowering the site and replacing existing equipment or decommissioning the site, removing the equipment and other major structures and restoring the stream/river and site..
Prior to decommissioning, a decommissioning method statement, detailing or how the site will be restored is usually prepared and approved by the relevant authorities. A key part of the decommissioning for a SSH facility will be restoration of the stream. The decommissioning programme should include plans for restoring the stream to pre-development function and value while preventing erosion and degradation of the stream.
3.5 DEVELOPMENT COSTS
The estimation of investment costs for SSH was developed using ÅF- Mercados EMI (2013) assumptions in the regional FIT modelling report. The estimated of SSH investment costs in the Asian Region are presented in Table 8. It should be noted that capital costs also vary widely with site conditions.
Table 8 Capital and Operating Expenses for Typical SSH
Item Cost (USD) Plant $1,679/kW
Planning $283/kW
Electrical Installation (grid $283/kW infrastructure)
Other infrastructure $566/kW
TOTAL CAPITAL COSTS $2,828/kW
Service and Spare Parts $27.5/MWh
Insurance $7.5/MWh
Administration $9.0/MWh
Other O&M $6.0/MWh
TOTAL OPERATING COSTS $50.0/MWh Source: ÅF-Mercados EMI (2013)
Table 9 presents the comparative costs for various forms of hydropower plants.
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Table 9 Comparative Hydropower Plant Costs
Hydropower MW Installed Cost (US Discussion Technology Range $/kW) Conventional 50 $1,000-$5,000 A mature technology, conventional hydro Hydro (average) falls at the lower end of the range of installed (impoundment) costs, particularly for upgrade projects at existing sites. New dams and greenfield sites are more expensive. Microhydro < 0.1 $4,000-$6,000 The installed cost for low-impact hydro systems is not expected to decline in the near term. Run of River Approx. $1,500- $6,000 Similar to conventional hydro, installed costs (diversion. 10 for run-of-river can vary widely. Pumped Storage >500 $1,010-$4,500 Traditional pumped storage is a proven technology and costs are not expected to decline going forward. The new underground pumped storage technology has been quoted at $2,000/kW and cost declines can be expected going forward, if the concept proves itself. Source: National Hydropower Association (2013) at http://www.hydro.org/why- hydro/affordable/
3.6 SUPPLY CHAIN IN KAZAKHSTAN
Hydropower is a mature, well understood industry in Kazakhstan Hydropower development history in Kazakhstan suggests that there are industry stakeholders-- engineering firms, equipment suppliers, developers (owners), hydropower operators, and contractors with the necessary experience to support the industry.
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4.0 ENVIRONMENTAL AND SOCIAL CONSTRAINTS
A detailed assessment of environmental and social constraints related to SSH (and the other three RES evaluated) is provided in the SER Report. Environmental and social factors that could significantly impact the effectiveness, economic feasibility, and therefore, the siting of these facilities are addressed in Section 3.7 of this RPER. In addition, there are areas of high environmental and/or social sensitivity the proximity of which should also be strongly considered. These environmental and/or social high sensitivity areas are discussed in detail in the SER and are summarized in this section.
• Essential Habitat for Protected Aquatic Species - SSH development along river/stream segments that are essential habitat for protected aquatic species should be avoided. When siting facilities in, or upgradient of, a stream that provides essential aquatic habitat for protected species, a more detailed assessment of environmental effects and additional impact mitigation measures will be required.
• Anadromous Fish – The creation of impounded SSH systems along river/stream segments that support anadromous fish migration should be avoided. When creating impounded SSH facilities along rivers that support anadromous fish movement, a more detailed assessment of environmental effects and additional impact mitigation measures will be required.
• Forested Areas - Potential SSH sites in forested areas, would be discouraged given the relative lack of this habitat and the abundance of un-forested areas throughout the country. When siting facilities within a forested area is unavoidable, a more detailed assessment of environmental effects and additional impact mitigation measures will be required.
• Protected/Designated Lands - Potential SSH sites in or near other areas afforded legal protection, including National Parks, and preserved lands would be discouraged given the relative lack of this habitat and the abundance of un-forested areas throughout the country. When siting facilities within a protected/designated area is unavoidable, additional impact mitigation measures will be required.
• Cultural heritage - Special care should be taken to avoid siting SSH facilities at or within the viewshed of known and tentative UNESCO World Heritage sites due to the global uniqueness of these areas. Special care should also be taken to avoid placing SSH facilities on or near locally-registered cultural heritage sites. Given the low actual elevation of potential SSH facilities, the viewshed for SSH facilities is somewhat limited. Therefore, a viewshed buffer of 5km should be
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placed around known and tentative UNESCO and national heritage features for SSH facility development. When siting facilities within a viewshed buffer is unavoidable, a more detailed assessment of environmental effects and additional impact mitigation measures will be required. Cultural heritage features themselves would be considered exclusion zones.
• Cumulative effects – Special consideration should be given to the impact of other hydropower facilities upstream on the same river reach on the operation of any planned SSH facility. Operation and activities at upstream hydropower facilities can affect the availability of water resource. In addition, the potential for developing downstream resources is impacted by siting a new facility and should be considered. Potentially significant cumulative effects associated with SSH are presented in Table 6. Guidance for cumulative impact assessment at the development-specific level is available for RES from a number of different sources. These will be used as required by the Project Implementation Unit to establish the methodology for specific financed projects where there are potential cumulative impacts. A list of the most recent and relevant guidance and research is provided below:
o International Fiance Corporation (IFC), Good Practice Handbook: Cumulative Impact Assessment and Management: Guidance for the Private Sector in Emerging Markets, August 2013.
o World Bank. 2012. “Sample Guidelines: Cumulative Environmental Impact Assessment for Hydropower Projects in Turkey.” Energy Sector Management Assistance Program. https://www.esmap.org/node/2964.
o Bérubé, Michel. 2007. “Cumulative effects assessment at Hydro-Québec: what have we learned?” Impact Assessment and Project Appraisal 25(2): 101–109.
o Bonnell, S., and K. Storey. 2000. “Addressing cumulative effects through strategic environmental assessment: a case study of small hydro
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Table 10 Cumulative effect issues associated with SSH power generation and mitigation measures
Valued Geographic Temporal Issue Potential Mitigation Measures Resources Boundary Boundary SMALL HYDRO Design requirements for specific Water Project The cumulative effect realized when facilities to prevent entrainment and multiple SSH facilities (impoundment resources construction Extent of river allow fish passage, regional planning or RoR) are concentrated in high water Aquatic until measures to limit compounding energy areas biodiversity demobilisation effects on small streams. Design requirements for specific Water Project The cumulative effect associated with facilities to prevent entrainment and resources construction placing multiple impoundments on a Extent of river allow fish passage, regional planning Aquatic until single waterway measures to limit impoundments on biodiversity demobilisation existing rivers
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5.0 KAZREFF PROJECT APPRAISAL - ENVIRONMENTAL AND SOCIAL PERFORMANCE REQUIREMENTS
SSH projects funded under KazREFF will be subject to the following environmental and social requirements, as stipulated by EBRD:
• The EBRD’s Environmental and Social Policy (2008) and its associated Performance Requirements. • Applicable requirements of Kazakhstan, including but not limited to those related with environmental impact assessments, environmental permitting, labour, public consultation, resettlement and compensation, occupational health and safety, community health and safety, and emergency response. • Relevant European Union Directives and requirements • International best practices, including those promulgated by other international financial institutions, the International Labour Organisation, and others.
5.1 EBRD REQUIREMENTS
Projects would need to adhere to the EBRD Environmental and Social Policy and its associated Performance Requirements (PR), which cover the following areas:
• PR 1: Environmental and Social Appraisal and Management • PR 2: Labour and Working Conditions • PR 3: Pollution Prevention and Abatement • PR 4: Community Health & Safety and Security • PR 5: Land Acquisition, Involuntary Resettlement and Economic Displacement • PR 6: Biodiversity Conservation and Sustainable Resource Management • PR 7: Indigenous Peoples • PR 8: Cultural Heritage • PR 9: Financial Intermediaries (FI) • PR 10: Information Disclosure and Stakeholder Engagement
Depending upon the scale of KazREFF project, EBRD would require a series of environmental documents to be produced in order to gain EBRD funding. Projects are screened at an early stage and placed into one of the four following categories, depending on the level and type of environmental and social due diligence that is required:
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• Category A projects are those with potentially significant and diverse environmental and social impacts, requiring detailed impact assessments • Category B projects are those with environmental and social impacts that are site-specific and can be addressed through readily available management and mitigation techniques • Category C projects have minimal environmental or social impacts • FI projects are where the EBRD is investing in a Financial Intermediary, such as a bank or equity fund.
This categorization reflects: (i) reflect the level of potential environmental and social effects and issues associated with the proposed project; and (ii) determine the nature and level of environmental and social investigations, information disclosure and stakeholder engagement required for each project, taking into account the nature, location, sensitivity and scale of the project, and the nature and magnitude of its possible environmental and social effect and issues.
Due to the relatively small scale of the potential KazREFF projects, most would likely fall under Category B, as the potential adverse environmental and/or social effects that they may give rise to are typically site-specific, and/or readily identified and addressed through mitigation measures. However, the siting of SSH facilities within or near sensitive/protected areas or in situations where impacts could be more severe may result in these being classified as Category A projects. This determination is made by EBRD and KazREFF in the initial project phases.
5.1.1 CATEGORY A
If a project is considered to be a Category A project, it is usual to expect that it would require the development and disclosure of an Environmental and Social Impact Assessment Package including:
• An ESIA; • A Non-Technical Summary (NTS); • An Environmental and Social Action Plan (ESAP); • A Stakeholder Engagement Plan (SEP); • A Land Acquisition Plan (if land acquisition is required); • A Resettlement Action Plan (if population displacement is required).
Disclosure of these documents generally allows for a 120 day public consultation period, after which the documents are finalized, published, and financing may be secured. In general, the timeframe for completing the environmental and social review process for a Category A project typically takes 9 to 12 months to complete.
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5.1.2 CATEGORY B
If categorized as a Category B project, there are less detailed documentation requirements due to the lesser potential for significant environmental and social impact. EBRD typically requires the development and disclosure of:
• A Project Summary Document; • A Project Fact Sheet or Non-Technical Summary (NTS);
For Category B projects, EBRD also typically reviews, but does not require disclosure of:
• An Environmental and Social Action Plan (ESAP); • A Stakeholder Engagement Plan (SEP); • An Environmental and Social Due Diligence (ESDD) document that demonstrates compliance with PR1
Disclosure of these required documents generally allows for a 30 day public consultation period, after which the documents are finalized, published, and financing may be secured. In general, the timeframe for completing the environmental and social review process for a Category B project typically takes 3 to 6 months to complete.
5.2 KAZAKHSTAN REQUIREMENTS
Specific requirements for EIA procedures for all categories of economic activity are established by the document “Instruction on Environmental Impact Assessment at the Development of Prior Planned, Planned, Prior Project, and Project Documentation”. This guide contains:
• A list of activities which require implementation of the EIA procedure in full;
• A list of activities for which the full EIA procedure is proposed to the State Environmental Expertize (SEE) on the basis of preliminary expertise or by applying a set of criteria determined in normative documents; and
• A list of activities with insignificant environmental impact, for which only the preparation of an "Environmental impact statement" is sufficient for submission to the SEE.
Projects in Kazakhstan are classified by the Sanitary and Epidemiological Services (SES) of MOH according to five danger levels with one being the highest as defined by norms and standards in relation to human health and safety. The sensitivities of projects are measured by the SES Danger/Sanitary Categories. The categories are:
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• Danger/Sanitary Categories 1 & 2 projects have levels of severity/danger that trigger a full EIA. • Danger/Sanitary Category 3 projects are considered to have lower levels of severity/danger and as such a lesser assessment is undertaken, although still referred to as an Environmental Assessment. • Danger/Sanitary Category 4 & 5 projects are considered to present considerably lower risks of severity/danger and generally do not warrant an assessment beyond the initial screening.
The SES Danger/Sanitary Categories relate to four categories of RoK EIA (Оценка воздействия на окружающую среду - OVOS). The EIA/OVOS Categories are:
• Category I - Sanitary Class/Danger Categories 1 and 2 plus investigations and extractions of minerals, except for common minerals. Risks are high and approval by MOEP is required. A Category I EIA/OVOS is categorically required obligatory for large scale including road construction project with four lanes or more. • Category II - Sanitary Class/Danger Category 3 plus extractions of ubiquitous minerals, forestry activities and special uses of water. Risks are ranked as Medium High and approval is required from TEPO(s). • Category III - Sanitary Class/Danger Category 4 Risks are ranked as Low and approval is required from TEPO(s). • Category IV - Sanitary Class/Danger Category 5 plus projects involving animals, except recreational fishing and hunting. Risks are ranked as Low and approval is required from local administrations.
SEE reviews are conducted at end of each stage in the process and before proceeding to the next stage. Reviews are conducted first at the Oblast level and then by MEWR and other agencies as appropriate to the nature of the Project and the level of EIA Categorization. Under Kazakhstan regulations, the EIA process has three stages:
• Preliminary EIA (Environmental Impact Assessment - Pre-OVOS)
• Preparation of the EIA (OVOS). EIAs are obligatory for large scale projects.
• Preparation of an "Environmental Protection Section". The Environmental Protection Section is prepared in the detailed design stage in the event that mitigation measures defined in the EIA (OVOS) are required.
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At each stage of the EIA process, the developer is required to prepare an "Environmental Impact Statement", which is a compulsory annex to each EIA document. The "Environmental Impact Statement" must be presented in the package of documents for submission to the SEE for consideration. Reviews are conducted at the end of each stage, first at the Oblast level and the by MEWR and other agencies as appropriate for the project and EIA Category.
Public hearings or public consultations are required at all stages of EIA. The detailed requirements for public participation are reflected in the Environmental Code, Articles 57 and 60-67 and the “Rules of access to environmental information relate dot EIA procedure and decision-making process on intended economic and other activity”. Minutes from these hearings are filed as part of the EIA documentation.
The process provides for a preliminary review period of two weeks and a final review period of up to 90 days after which the EIA authors are required to defend the EIA at a consultation session with all stakeholders in attendance (usually not the general public). Once complete, the EIA is revised; a final document is prepared; and a formal OVOS certificate is issued to the Proponent, but usually only after another 30-day waiting period, allowing for any additional comments. This certificate allows the project to proceed with other approvals that may be required. Based on this information, it may take up to a year to complete the EIA process in Kazakhstan.
Based on additional guidance provided in the RoK EIA regulations, it is likely that SSH projects (and in fact, all RES projects) would be considered Category II and would require Category II EIA/OVOS documentation. However, the siting of SSH facilities within or near sensitive/protected areas may result in these being classified as Category I projects. This determination is made by MoE at the preliminary EIA stage.
The OVOS process was evaluated against the EBRD Environmental and Performance Standards to identify gaps areas that may be not be satisfied by the OVOS process. This gap analysis is provided in Appendix A.
5.3 KAZREFF APPRAISAL PROCESS
All projects considered for financing through KazREFF will under a detailed appraisal process in order to:
• Determine each project’s ability to meet EBRD environmental and social performance requirements; • Determine each project’s ability to meet EBRD RoK EIA regulations • Ensure that projects are technically feasible
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• Identify significant issues and constraints that may negatively impact KazREFF’s ability to finance each project from an environmental and social perspective • Provide simplified guidance and resources to project proponents (and their environmental consultants) in order to more easily comply with EBRD and Kazakh requirements
The appraisal process will be developed and implemented by the Project Implementation Unit.
5.3.1 INITIAL SCREENING
The appraisal process includes an initial screening of the project proposal against the criteria presented in this RPER, the SER report, and consideration of key environmental and social issues. This initial screening is conducted after the project proponent completes the Environmental and Social Issues Checklist – Small Scale Hydropower provided in Appendix B. This checklist includes identification of key environmental and social issues related to SSH (and cumulative impacts) and is reviewed by KazREFF’s environmental and social review team. Based on the review of the checklist, the project’s EBRD category will be determined and specific documentation requirements will be communicated to the project proponent.
Once the EBRD requirements have been identified, KazREFF environmental and social review team will provide support to project proponents to comply with the Kazakh EIA regulations. In general, information gathered through the initial screening process can be useful in developing the preliminary EIS documentation required for the initial stage of the Kazakhstan EIA.
5.3.2 DOCUMENTATION REVIEW AND APPROVAL/FEEDBACK
Based on the initial screening and categorisation, the project proponent will then be expected to complete the preparation of required documentation.
Templates for the typical documents expected to support SSH projects (under Category B) are provided in Appendix C and include templates for the NTS (Appendix C.1), the SEP (Appendix C.2), and the ESAP (Appendix C.3). If a project is determined to be a Category A project, an ESIA would be required. Due to the very specialized nature of an ESIA, an ESIA template has not been provided. However, information in the SER report will be extremely useful to identify information necessary for the preparation of these documents. The information in the SER identifying the environmental baseline, the anticipated effects, and mitigation strategies should also be very useful to inform the Kazakh EIA.
All projects will be expected to comply with EBRD PR1 through 10. Important information for assessing the significant environmental and social
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effects and avoidance, minimization, and/or mitigation of those effects is provided in the SER.
The required documents will be submitted to, and reviewed by, KazREFF environmental and social review team. The KazREFF environmental and social review team will work with the developer to ensure submitted information is sufficient to demonstrate compliance with EBRD’s PRs.
In addition, KazREFF environmental and social review team will review the progress of the Kazakh EIA and can, if requested, provide technical input and guidance on the process and content. KazREFF environmental and social review team will request updates from the project proponent on the progress of the project through the Kazakh EIA stages until final approval is received.
Once the required environmental and social documentation for KazREFF review has been found to be in compliance with the EBRD and the final Kazakh EIA is approved, KazREFF environmental and social review team will reflect that in the Project Screening Report.
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6.0 APPENDICES
A - Gaps between EBRD PR for ESIA and Kazakhstan EIA Requirements
B – Environmental and Social Issues Checklist – SSH
C – Environmental and Social Templates
C.1 – Non-Technical Summary (NTS)
C.2 – Stakeholder Engagement Plan (SEP)
C.3 – Environmental and Social Action Plan (ESAP) – SSH
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Kazakhstan Renewable Energy Financing Facility (KazREFF) - Strategic Environmental Review
Appendix A – Gaps between EBRD PR for ESIA and Kazakhstan EIA requirements
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Appendix A: Gaps between EBRD PR for ESIA and Kazakhstan EIA requirements
EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement PR 1: Environmental and All EBRD-financed projects undergo The EIA is obligatory for all sectors of None Social Appraisal and environmental and social appraisal economic and other activities that may Management directly or indirectly impact the environment and public health.
The EIA process is performed on the strength of commitment, integration (magnitude), alternative, adequacy, preservation, compatibility, flexibility, and public participation.
Categorization and EIA magnitude Economic activities subjected to the EIA None procedure are categorized as I, II, III, and IV, The EBRD categorizes proposed projects as “A”, of which categories I and II cause major “B”, and “C”. impacts on the environment. A project is classified as Category A when it could result in potentially significant and diverse According to the requirements, there is the adverse future environmental and/or social list of projects (economic activities) for impacts and issues which, at the time of which the EIA is recommended to be categorization, cannot readily be identified or performed in full (for example, oil industry assessed and which require a formalized and and crude oil refineries, thermal power participatory assessment process carried out by stations, chemical installations, pipelines independent third party specialists in accordance for transport of gas, oil or chemicals, etc.) with the PRs (Appendix 1 to the EBRD ESP). and the list of projects (economic activities) for which the requirements to carry out a A proposed project is classified as Category B comprehensive assessment are imposed by when the potential adverse environmental and / State review authorities on the basis of a or social impacts that it may give rise to are preliminary review or by applying
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement typically site-specific, and/or readily identified thresholds defined by regulations and addressed through mitigation measures. (agriculture, forestry, mining industry, These impacts could be from past, current or power industry, wind farms, etc.). future activities. Due diligence requirements may vary depending on the project and will be agreed with the EBRD on a case-by-case basis, in accordance with PR 1.
A proposed project is classified as Category C when it is likely to result in minimal or no adverse environmental or social impacts and therefore requires no further environmental and social appraisal beyond categorization.
Based on the KazREFF SER, it is anticipated that most funded projects will fall within Categories B or C. EIA stages The EIA process comprises the following None stages: 1) preliminary EIA (stage 1); 2) EIA that is performed for a complete and comprehensive analysis of potential effects of the project or further economic and other activities, substantiation of alternatives, and development of an environmental management plan (programme) (stage 2); 3) “Environmental Protection” section that constitutes part of the design documentation and contains engineering solutions aimed at prevention of adverse
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement impacts on the environment (stage 3).
The EIA format, completeness of studies, scope of used documents, levels and degree of detail of environmental scientific & design surveys depend on the design stage as well as on magnitude and intensity of impacts caused by projected economic and other activities on human health and environment.
EIA is an integral part of pre-design and design documents. Preliminary environmental and social assessment Through Pre-EIA activities, the potential None (Pre EIA) trends of changes in environmental and socioeconomic components as well as Through appraisal activities, the client will impacts on both the society and consider in an integrated manner the potential environment are identified. environmental and social issues and impacts associated with the proposed project. The No need in computations of the pollution appraisal process will be based on recent level for certain environmental information, including an accurate description components (air, soils, water, subsoil and delineation of the client’s business or the resources). project, and social and environmental baseline data at an appropriate level of detail. The Pre-EIA documents are disclosed for public appraisal should also identify applicable laws and by a project initiator. regulations of the jurisdictions in which the project operates that pertain to environmental Pre-design appraisal documents (business- and social matters, including those laws plans, feasibility studies) and main pre- implementing host country obligations under design documents such as “Investment international law (for example, commitments substantiation” and Pre-EIA documents are
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement related to land use planning and protected area submitted to the State Environmental management). Review (SER).
A positive Conclusion issued by the SER in favour of the project initiator, serves as a guide for making decisions to initiate designing of specific facilities and structures in accordance with the most rational option selected in the course of Pre-EIA development. Environmental and Environmental and social impacts and issues will The EIA process comprises an assessment None social appraisal (EIA) be appraised in the context of the project’s area of impacts on: mechanism of influence. Environmental and social issues and impacts will also be analysed for the relevant • atmospheric air stages of the project cycle. These may include • water resources; preconstruction, construction, operations, and • subsoil resources; decommissioning or closure and reinstatement. • industrial and domestic waste; Where relevant, the appraisal will also consider • physical impacts; the role and capacity of third parties, such as • lands and soils; local and national governments, contractors and • flora; suppliers, to the extent that they may influence • fauna; the project, recognizing that the client’s ability to • socioeconomic environment; address these risks and impacts will depend on its • environmental risks from planned control and influence over the third party actions. activities in the region The appraisal will also consider potential trans-
boundary and global issues, such as impacts from A project initiator discloses EIA documents effluents and emissions, increased use or for the public. contamination of international waterways, greenhouse gas emissions, climate change mitigation and adaptation issues, and impacts on endangered species and habitats.
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement
PR 2: Labour and At a minimum, the client’s human resources Labor relationship in the Republic of Labor relationship issues Working Conditions policies, procedures and standards shall be Kazakhstan is regulated by the Labor Code are not reflected in typical designed to: establish and maintain a sound and it does not constitute part of the EIA Kazakh EIA documents. This worker-management relationship; promote the process. would be a gap if not fair treatment, non-discrimination and equal addressed in a project- opportunity of workers; promote compliance Issues related to labor and working specific ESMP. with any collective agreements to which the conditions and safety are considered in the client is a party, national labour and employment “Environmental risk assessment in laws, and the fundamental principles and key connection with planned activities in the regulatory standards embodied in the ILO region” section. conventions that are central to this relationship; protect and promote the health of workers, especially by promoting safe and healthy working conditions.
PR 3: Pollution The client will avoid the release of pollutants or, Measures aimed at prevention and None Prevention and when avoidance is not feasible, minimize or abatement of environmental pollution are Abatement control their release. This applies to the release specified in EIA documents (“Atmospheric of pollutants due to routine, non-routine or Air”, “Water Resources”, and “Waste” accidental circumstances with the potential for sections). These measures provides for local, regional, or trans-boundary impacts. In introduction of low-waste and waste-free addition, the client should examine and technologies and special measures on i) incorporate in its operations energy efficiency prevention (abatement) of air emissions; ii) measures and measures to conserve water and adverse impact mitigation; iii) air quality other resources, consistent with the principles of monitoring; iv) amounts and chemical cleaner production. The client will avoid or composition of wastewater discharges; v) minimize the generation of hazardous and non- substantiation of the introduction of water hazardous waste materials and reduce its circulating systems and wastewater reuse harmfulness as far as practicable. systems, recycling of sludge from wastewater treatment facilities; vi)
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement groundwater protection against pollution and depletion; and vii) recommendations related to recycling, treatment and disposal of all types of waste and waste recycling/waste disposal technologies. PR 4: Community Health Requirements relating to: infrastructure and EIA documents comprise a section titled None & Safety and Security equipment safety; hazardous materials safety; “Assessment of environmental risks for the community exposure to disease; emergency environment and community health in preparedness and response; and security connection with planned economic personnel requirements. These requirements are activities”. This section contains i) focused on avoidance or prevention of risks and recommendations on prevention of and impacts rather than their minimization and response to emergencies; ii) consideration mitigation. of emergency probability; sources and kinds of emergencies and frequency of their occurrence as well as forecasts of their impacts on the environment and community. PR 5: Land Acquisition, The following requirements are considered in the Issues related to land acquisition and Kazakhstan EIA regulations Involuntary course of project design: carrying out of involuntary resettlement are regulated by do not contain Resettlement and consultations; grievance mechanism; the Land Code of the Republic of requirements related to Economic Displacement resettlement planning and implementation; Kazakhstan. But the Pre-EIA documents to land acquisition, Resettlement Action Plan; livelihood restoration be submitted to the SER for reviewing involuntary resettlement framework; compensation and benefits for should contain a copy of document for the and economic displaced persons; displacement; physical right of land use in the subject territory. displacement. displacement; economic displacement; and loss of public amenities. PR 6: Biodiversity Through the environmental and social appraisal The EIA process also includes an None Conservation and process, the client will identify and characterize assessment of impacts on vegetation in the Sustainable Resource the potential impacts on biodiversity likely to be project influence area (the presence of Management caused by the project. The extent of due diligence medicinal herbs; rare, endemic and Red should be sufficient to fully characterize the risks Data Book-listed plat species), green space
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement and impacts, consistent with a precautionary condition; forecasted changes of the approach and reflecting the concerns of relevant vegetation cover in the project stakeholders. The client will seek to avoid implementation area and impacts of these adverse impacts on biodiversity. changes on life and health of local communities; recommendations for conservation of vegetation communities, improvement of their condition, flora conservation and revegetation; recommendation for vegetation monitoring, etc.
Furthermore, the EIA documents contain a baseline assessment of aquatic and terrestrial fauna (the presence of rare, endangered and Red Data Book-listed fauna species); measure to conserve and reproduce the integrity of natural communities and species diversity of aquatic and terrestrial fauna; food potential improvement; a wildlife monitoring programme. In addition, the presence of natural territories and landmarks under special protection in the territory of potential construction operations is considered. PR 7: Indigenous In projects where Indigenous Peoples are likely to The Kazakhstan legislation does not specify The Kazakhstan EIA Peoples be affected, the client is required to carry out an requirements related to Indigenous procedure does not assessment of impacts on Indigenous Peoples. Peoples consider issues related to Depending upon the outcome of this, the client is Indigenous People. expected to first avoid adverse effects and where However, this is not this is not feasible, to prepare and Indigenous typically an issue in
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement Peoples’ Development Plan so as to minimize Kazakhstan, where there is and/or mitigate any potential adverse impacts. no indigenous population. The client is also expected to implement a specific grievance mechanism and determine appropriate modalities for compensation and benefit-sharing.
PR 8: Cultural Heritage At an early stage of the environmental and social EIA documents contain a section devoted None appraisal, the client should identify if any cultural to territories, landmarks and sites under heritage is likely to be adversely affected by the special protection. Cultural heritage is project, and assess the likelihood of any chance regulated by the RK Law “On Protection finds. The client will ensure that provisions for and Use of Historical and Cultural Heritage managing chance finds, defined as physical Sites and Objects” dated July 2, 1992. cultural heritage encountered unexpectedly Companies, institutions, organizations, during project implementation, are in place. Such educational institutions, public provisions shall include notification of relevant organizations and individuals will support competent bodies of found objects or sites; an authorized relevant body in alerting project personnel to the possibility of implementation of measures aimed at chance finds being discovered; and fencing-off protection, preservation and use of the area of finds to avoid any further disturbance historical and cultural heritage sites. or destruction.
PR 9: Financial Not applicable Not applicable Not applicable Intermediaries (FI)
PR 10: Information “Information Disclosure and Stakeholder Public opinion is given proper weight in the Kazakhstan requirements Disclosure and Engagement” specifies requirements relating to process of EIA development. Public opinion do not specify a detailed Stakeholder stakeholder identification, development of a consideration format depends on the procedure for stakeholders Engagement Stakeholder Engagement Plan, information significance of planned economic activities identification and disclosure, meaningful consultations, and and the extent of project influence on the engagement or the grievance mechanism. environment and community health; much grievance mechanism
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement depends on stakeholders. The procedure procedure. and dates of public consultations is regulated by environmental supervisory authorities.
Public opinion is mainly considered through public consultations. The results of public consultations are recorded in the form of a report where all key issues and disagreements between stakeholders and a client are recorded. Stakeholders’ comments and proposals are considered in design documents. Written proposals and comments from stakeholders (as an independent form of public opinion consideration) are collected for individual less significant projects of economic activities. At subsequent stages of project design, the procedure of public opinion consideration can be carried out through collection of written proposals and comments in respect of EIA findings for a certain industrial operation.
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Kazakhstan Renewable Energy Financing Facility (KazREFF) - Strategic Environmental Review
Appendix B – Environmental and Social Issues Checklist – Small Hydropower
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Please read this before completing the questionnaire: 1. This questionnaire is the first stage in the Bank’s environmental and social due diligence process. The more comprehensive the answers given, the less need will there be for the Bank to request further information. Please, therefore, try to answer the questions as fully and openly as possible. 2. The questionnaire makes reference to both “the Project”, the business activity for which EBRD funding is sought, and “the Company”, which is the corporate entity that is ultimately responsible for the Project. The Project may affect the whole Company or may only relate to one element within the Company. The Bank needs to understand both issues related to the Project being financed by the Bank and the impacts and issues associated with the Company as a whole. 3. There are a number of questions where further information is requested if a positive response is given. Additional information can be provided either in the questionnaire’s boxes or in separate documents.
PROJECT NAME: PROJECT LOCATION: Map Provided? Yes / No Company Name: Company Address: Country: Town/Location: Business Sector/Activities: Person completing questionnaire:
Name: Title: Date: Telephone: Mobile: E-mail:
Company authorised representative (e.g. Environmental Manager): I certify that, to the best of my knowledge and belief, the information contained in this questionnaire accurately represents current or future operations.
Signature:
Title: Date:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE COMPANY PROFILE
A) Ownership: • Private ownership %: ______• Public ownership %: ______B) Year of foundation: ______
C) Sector of operation and main products: ______
D) Describe the main activities of the Company and its holdings including any solar photovoltaic or other renewable energy projects (include a description of the corporate structures and controls that are used to manage/oversee individual projects, including this one):
PROJECT DESCRIPTION
A) Technical information: Start of construction (planned date) Start of operation (planned date) Installed capacity (MW) Annual net generation (MWh) Type of solar photovoltaic panels (eg fixed tilt or axis-tracking; crystalline or thin-film?) Are data on solar irradiation available (yes/no) Solar irradiation measuring period (start date / end date) Daily average of solar irradiation at Project site (kWh/m2) Distance to interconnection grid (km): Voltage level of interconnection grid (kV): Voltage level of overhead line to interconnection point (kV): Land area required (m2)
B) Status of project development: yes no
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE The project is still in its conceptual phase (we have only a project idea)? Technical design has started? Technical design is completed? Quotations / proposals from equipment suppliers have been received?
C) Summary of information on Environmental Impact Assessment: Is Environmental Impact Assessment (EIA) required? (yes/no) Has EIA been completed? (yes/no) If EIA is available, has it observed any adverse environmental impacts? If yes, describe them and any associated mitigation measures in Section 1b. If EIA is required but not available, when will it be completed?
D) Siting, design and key environmental and social considerations:
1. Describe the Project and provide a map showing its components, including the solar panel infrastructure (photovoltaic modules, inverters, racking transformer and sub-station (and approximate layout)), roads, transmission lines, grid connections and other required facilities. 2. How were environmental and social issues incorporated into the siting and design optimisation process (see also questions under PR1 and PR6 below)? 2.1 What studies have been completed relating to potential impacts on local communities and other land-users? 3. Solar resource issues – please describe: 3.1 Understanding of the operational regime for each facility and for operations in tandem; 3.2 Solar resource measurements and other meteorological data and monitoring information; 4. How have climate-change related variables been accommodated? PR1 - Environmental and Social Appraisal & Management Environmental and Social Appraisal 1.a Has the Company made an assessment of the Yes: No: environmental and social impacts of its operations? If yes, please provide a summary of that assessment:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE 1.b Has an Environmental and Social Impact Assessment Yes: No: (ESIA) been completed for this Project? If yes, please summarise the conclusions of the ESIA, including required/recommended mitigation, and send a copy/summary: 1.c Have relevant discussions been held with Yes: No: environmental regulators on the ESIA for the Project? If yes, please summarise: 1.d Is there an Environmental and Social Action Plan (ESAP) Yes: No: for the Project construction, operation and If yes, please summarise: decommissioning? 1.e Have any site investigations been performed to check Yes: No: the suitability of the site and characterise If yes, please provide a list of the studies: environmental and social baseline conditions, such as soil, water quality and groundwater testing, slope stability, survey for flora and fauna including bat, bird and water species, or the situation of nearby communities? 1.f What are the relevant Company’s Corporate Social Responsibility Standards? 1.g What processes are in place to manage environmental issues (such as the presence of sensitive species)? 1.h Will / does the Project involve significant excavations, Yes: No: demolitions, movement of earth, flooding or other If yes, please provide details: changes in the physical environment? 1.i What soil erosion/sedimentation mitigation/control procedures will be in place for the construction and operational phases of the Project? Environmental Management 1.j Who is responsible for environmental management at Name/title:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE the Company? Phone/mobile: Email: Who is responsible for social management / community Name/title: relations at the Company? Phone/mobile: Email: Who is, or will be, responsible for environmental Name/title: management for the Project? Will that person be on- Phone/mobile: site during construction and operation? Email: Who is, or will be, responsible for social management / Name/title: community relations for the Project? Will that person Phone/mobile: be on-site during construction and operation? Email: 1.k Does the Company have an Environmental and Social Yes: No: Management System (ESMS)? If yes, is the ESMS compliant with any internationally Yes: No: recognised systems such as ISO 14,001, OHSAS 18,001, SA 8000 or EMAS? 1.l Does the Company periodically prepare a summary Yes: No: report on environmental performance (or If yes, please provide a copy of the most recent report(s) sustainability) for shareholders, stakeholders, or others? How often? 1.m Does the Company routinely provide environmental Yes: No: training for Company personnel? If yes, please describe the training provided: Will the Company train workers for the Project? For Yes: No: construction and/or operation? If yes, which workers will be trained? What kind of training? Contractor management 1.n Will the Company use contractors during the Yes No
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE construction and/or operational phases of the Project? If yes, please provide details: 1.o Are prospective contractors required to submit Yes No environmental, health and safety, and/or labour information with bid documents (that is, do solicitations for proposals require such information)? 1.p Is a contractor’s past EHS performance considered Yes No during evaluation of bids? If yes, please describe how (including whether it is used as a pass/fail factor or as part of the overall score: 1.q Does the Company monitor performance of its Yes: No: contractors regarding environmental, health and safety, If yes, how often? How does the Company deal with poor and labour/human resources? performance? 1.r How will the contractors be managed to ensure they have processes in place to anticipate and respond to emerging risks and opportunities, associated with the Project? PR 2 – Labour and Working Conditions 2.a Who is responsible for Human Resources (HR) Name/title management at the Company? Phone/mobile: Email: 2.b Does the Company have written HR policies setting out Yes: No: its approach to managing its workforce? 2.c Are all workers provided with written information Yes: No: about their terms and conditions of employment? 2.d Has the Company ever been found in violation of any Yes: No: country’s labour and/or social security laws? If yes, please describe the circumstances Have these resulted in any penalties, fines, major Yes: No: recommendations or corrective action plans? If yes, please describe:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE 2.e Are employees free to form, or join, a workers’ Yes: No: organisation (e.g. a trade union) of their choosing? What percentage of the workforce belongs to such an organisation? 2.f Is the Company covered by a collective bargaining Yes: No: agreement? 2.g How does the Company interact with workers’ organisations and provide information to them? 2.h Does the Company have a grievance mechanism which Yes: No: allows employees to raise workplace concerns? If yes, please describe: How many grievances were received from employees Number: during the previous year? Please summarise the issues raised in grievances and how the company has addressed them: 2.i Have there been any strikes or other collective disputes Yes: No: related to labour and working conditions at the If yes, please describe the nature of the dispute and how it was Company in the past three years? resolved: Have there been any court cases related to labour Yes: No: issues? If yes, please summarise contested issues and outcome: Have there been any other significant labour issues Yes: No: raised by the media or by non-governmental organisations? If yes, please describe: 2.j Are there policies or terms and conditions covering Yes: No: employment of young persons under age 18? If yes, please describe What is the minimum legal working age? How does the Company verify the age of employees? Does the Company apply any restrictions to the tasks Yes: No:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE that can be done by younger workers? If yes, please describe: 2.k Are employees free to leave the premises when they Yes: No: are not required to work or with appropriate due cause? Does the Company retain any identity documentation Yes: No: from the employees? If yes, please explain which documents and why: Are employees free to resign from their jobs? Yes: No: If yes, please describe the notice and other procedural requirements? 2.l Does the Company have a policy for setting wages? Yes: No: How do the Company’s wage levels compare to comparable employers in your sector? 2.m Does the Company anticipate any redundancies or Yes: No: retrenchment in the next three years? If yes, please describe and explain the reason(s): 2.n Does the Company have policies or terms and Yes: No: conditions covering non-discrimination and equal If yes, please describe: opportunities in employment? 2.o Are any criteria other than compliance with job Yes: No: requirements (e.g., gender, ethnicity, nationality, If yes, please specify those criteria: religion, political or trade union affiliation) applied for recruitment / promotion / access to training / benefits? 2.p How many workers does the Company employ? Please provide numbers for men and women separately. How many are...: Direct: Seasonal: Full-time: Part-time: How many sub-contractors does the Company employ and what is the role of these sub-contractors? 2.q Will there be employment opportunities for local Yes: No:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE stakeholders? If yes, please describe these opportunities: How many non-skilled workers will be employed for the Construction: Operation: Project during construction and then operation? How many non-skilled workers are expected to be Near-by areas: Within the Country: recruited from nearby areas? From the country? What proportion of managers and skilled workers are Near-by areas: Within the Country: expected to be recruited from nearby areas? From the country? Occupational Health and Safety 2.r Who is responsible for health & safety management at Name/title: the Company and/or Project? Phone/mobile: Email: Is there an emergency response plan for dealing with Yes: No: natural disasters, such as earthquakes? (This is also relevant to PR-4 Community Health, Safety and If yes, please describe and provide a copy: Security) Is there sufficient information to confirm that Yes: No: construction will not result in land slips or other environmentally damaging incidents? (This is also If yes, please describe: relevant to PR-4 Community Health, Safety and Security) 2.s Does the Company have a Health & Safety Yes: No: Management System? Is the system compliant with an international health & Yes: No: safety standard such as OHSAS18001? 2.t Is the Company compliant with national requirements Yes: No: for health & safety? 2.u Is there a current Health & Safety Action Plan for the Yes: No:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE Company? If yes, please provide a copy of the latest update. Do project-specific health and safety plans (typically) go Yes: No: beyond the requirements of host countries? If yes, please summarise (typical) differences: 2.v Does the Company keep any statistics on Yes: No: • Fatalities; If yes, please provide health and safety statistics for the last three • Lost time accidents; years of operations. • Lost workdays resulting from incidents; and/or • Total staff hours worked? 2.w Have any Company operations been cited for violations Yes: No: of national or other health and safety standards and If yes, please summarise the circumstances and the outcome procedures in the last 3 years? 2.x Is there (or will there be) a Health and Safety Plan for Yes: No: this Project? If yes, please describe what it covers (or will cover)?
Will workers be required to undergo health and safety Yes: No: training? If yes, please indicate how often and what type(s) of training 2.y How does the Company ensure that workers employed by its contractors, sub-contractors or labour agents are protected by the same labour and health and safety standards as those that apply to the Company’s own employees? PR 3 – Pollution Prevention and Abatement Environmental Compliance 3.a In the last 3 years, has the Company been cited for any Yes: No: violations of environmental permits or regulations? If yes, please describe circumstances and outcomes: 3.b Has the Company applied for, and/or received, the Yes: No: required environmental permits and licences to Please list required permits and licenses, and their status (issued, construct the Project? To operate? applied for, etc.)
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE Construction: Operation: 3.c Which agencies and authorities will be primarily responsible for overseeing environmental performance of the Project? Air Emissions 3.d Does the Company produce air emissions? Yes: No: If yes, please describe the main sources, types and quantities of air emissions produced by the company: 3.e Please describe any measures taken to reduce emissions and prevent air pollution. 3.f Please provide monitoring data for total air emissions. Water Use 3.g What will be the main sources of water for the Project during construction and operation? How much water will the Company use at each phase of the Project? Have permits been issued? Yes: No: Will any water require treatment prior to use? Yes: No: If yes, please describe use, amount to be treated and treatment method: Wastewater Discharges 3.h What are the sources, types and quantities of effluent discharges that will produced by the Company during the Project? 3.i How much wastewater will be generated during Construction: Operation: construction and operation? How will wastewater be managed and discharged?
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE Is any wastewater treatment required prior to Yes: No: discharge? If yes, please describe: Solid Waste Management 3.j What are the types and quantities of solid wastes produced by the Company? How are these wastes disposed of? 3.k Are any hazardous wastes produced and how are these Yes: No: stored and disposed of? If yes, please describe: 3.l Does the Company implement any measures to reduce Yes: No: / reuse / recycle any solid wastes at its facilities? If yes, please summarise: Are contractors required to implement these Yes: No: measures? Hazardous Material Management 3.m What hazardous materials will used by the Company in the Project (such as flammable, explosive, reactive, radioactive and toxic substances) and in what quantities? What measures and procedures are in place for the handling and storage of such materials? 3.n Has the Company suffered any environmental incidents Yes: No: or accidents (such as spills, tank ruptures, explosions, If yes, please describe: etc.) during the previous three years at any of its facilities? 3.o Does the Company prepare Environmental Incident Yes: No: Reports, or similar, when an environmental accident or If yes, please describe the reporting system and indicate the relevant incident occurs? authorities you report to:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE 3.p Will fuel or other hazardous materials be stored and/or Yes No used for this Project? If yes, what materials will be used/stored? How much of each? How will they be used/stored? PR 4 - Community Health, Safety & Security 4.a How far are the nearest villages/towns/cities from the Please describe and include a map: Project site? How far from the Project site are the nearest occupied
houses and/or workplaces? 4.b Will the Company’s activities pose any material risks to, Yes: No: or have any significant impacts on, the health and If yes, please describe: safety of local communities or people? Yes: No: Has a public health assessment been undertaken? If yes, please describe:
4.c Has the Company developed measures to prevent Yes: No: and/or mitigate any such impacts? If yes, please describe:
4.d Has the Company consulted with locally affected Yes: No: community(ies) and stakeholders to discuss the Project If yes, please describe: and measures to be taken to reduce impacts, in order to understand any concerns and address issues associated with potential public health effects? How have impacts of the project on affected communities (if any) been identified and addressed? 4.e Will there be security guards to control entry to the Yes: No: Project site during construction and/or operation? If yes, will they be armed? How will they be trained?
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE Will security be outsourced to a separate company? Yes: No: If yes, what criteria did the Company use to select the security contractor? PR 5 - Land Acquisition, Involuntary Resettlement and Economic Displacement 5.a Does the Company have a person in charge of land Yes: No: acquisition and/or expropriation? Name: Title: Phone/mobile: Email: 5.b Have any structures or land already been acquired by Yes: No: the Company in connection to the Project? If yes, please provide details. 5.c How much land will need to be permanently acquired by the Company for the Project (including power- generating infrastructure, control centre, roads, transmission lines and other related facilities)? How much land will have to be temporarily occupied (e.g. for storage, access to construction sites, accommodation of workers)? 5.d Has the Company already identified owners and users Yes: No: of affected land and structures (for example, from Land If yes, please provide details: Books, Cadastre or through a field survey)? Have any negotiations with land/structure Yes: No: owners/users or any expropriation procedure been If yes, please provide details: initiated (including request for public interest)? What is the land currently being used for? Will land that is not needed by the Company continue Yes: No: to be used by others (such as land between buildings/generating infrastructure)?
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE 5.e Will any people need to be relocated to new houses, Yes: No: new farm land and/or lose access to other valuable If yes, please provide details. assets? 5.f Will the Company acquire land and/or pay for Yes: No: temporarily using it? If yes, how much land will be acquired and/or require payments for use? How will the amount to be paid for purchase or usage be determined? How will the Company proceed if agreement cannot be reached with owner(s)? Is there a written land acquisition plan for the Project? Yes: No: If yes, please provide details: 5.g Will any businesses / economic activities, both formal Yes: No: and informal, in the area be affected by construction If yes, please provide details: activities (e.g. tourism activities)? Does the Company have plans to compensate affected Yes: No: people for loss of business or economic activity? If yes, please provide details: 5.h Is there any resettlement required for this project? Yes No If yes, please provide details: If so, is there a Resettlement Action Plan? Yes No If yes, please provide details: PR 6 – Biodiversity Conservation & Sustainable Management of Living Resources 6.a How far is the Project from the nearest protected or Please provide a list with distances and provide a map showing the designated areas, or areas important for local Project and nearest protected/important areas. biodiversity, including Natura 2000 sites, national parks, Ramsar Sites (wetlands), etc.? 6.b Does the site provide habitat for any protected or Yes: No:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE sensitive species of plants or animals? If yes, please provide details: 6.c What habitat mapping or species surveys have been completed? 6.d Which habitat areas/species would be impacted by ancillary works, transmission lines, construction access roads, other construction activities etc? 6.e Is there any other baseline environmental data on Yes: No: wildlife of the area not already covered above or in the If yes, please provide further details: Project Description section? 6.f Is there any further information on potential impacts to Yes: No: species or habitats that have not been covered above If yes, please provide further details: or in the Project Description section? PR 7 – Indigenous Peoples Are there any indigenous peoples likely to be impacted by the project? Yes: No: If yes, please provide details: PR 8 – Cultural Heritage 8.a Is the Project located in or near a cultural heritage site Yes: No: recognised by the country in which the project is If yes, please provide details: located, or where artefacts have been found in the past (including UNESCO World Heritage Sites and those on the tentative list, Registered cultural heritage sites, zones and settlements)? 8.b Is the Project located on or near to a place of worship, Yes: No: cemetery or other place of importance and value to a If yes, please provide details: community? 8.c Has the Company consulted with the national, regional, Yes: No: and/or local agency(ies) responsible for protecting If yes, please provide details: cultural resources? ERM 73 KasREFF SER RPER SSH – June 2014
ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE 8.d Has the risk to cultural heritage sites and areas of Yes: No: archaeological interest been assessed and managed? If yes, please describe: PR 9 – Financial Intermediaries Not relevant for KazREFF PR 10 – Information Disclosure & Stakeholder Engagement 10.a Who will be affected by the Project, including the workforce and local communities? How and to what extent? 10.b Does the Company have a person in charge of Yes: No: communications with local communities? Name: Title: Phone/mobile: Email: 10.c Has the Company established a mechanism through Yes: No: which members of the public can raise concerns or If yes, please provide details: grievances concerning the Company’s environmental and social practices? 10.d Has the Company established a regular means for Yes: No: communicating with affected community(ies)/people If yes, please describe: (e.g. newsletter, email, helpline, open day)? 10.e Is the Company aware of any issues, concerns or Yes: No: positive feedback brought to the Company’s attention If yes, please describe: by members of the community, non-governmental organisations (NGOs), or the media? 10.f Has the company undertaken any consultations with Yes: No: stakeholders – including national, regional, and local If yes, please describe: authorities, NGOs, businesses, citizens? 10.g Does the Company have plans to implement Yes: No: ERM 74 KasREFF SER RPER SSH – June 2014
ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE community development activities (e.g. is there a If yes, please describe: corporate social responsibility plan)?
(end of questionnaire)
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Kazakhstan Renewable Energy Financing Facility (KazREFF) - Strategic Environmental Review
Appendix C – Environmental and Social Templates
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Kazakhstan Renewable Energy Financing Facility (KazREFF)
TEMPLATE - PROJECT NAME
DATE
Non Technical Summary of Environmental and Social Considerations
Prepared for:
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CONTENTS
1 Introduction 79 2 Description of the Proposed Development 80 3 Environmental, Health, Safety and Social Review 80
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7.0 Introduction
Add summary of company proposing development – i.e private / public owned, company structure and operations Add summary of project proposals – i.e type of power plant, size and location Add summary of environmental studies undertaken to date – i.e an ESIA?, specialist surveys? (Company name XXX) has approached the European Bank for Reconstruction and Development (EBRD) for financing. The project is thus subject to EBRD’s 2008 Environmental and Social Policy and has been determined as a Category XXX project (add details of whether it is a category A or B project). EBRD has conducted an environmental and social due diligence assessment of the project and supported the development of applicable environmental and social documentation, namely a Stakeholder Engagement Plan, an Environmental and Social Action Plan, and this Non Technical Summary (also add reference to other relevant documents if appropriate eg an ESIA, specialist studies). This document provides in a non-technical manner an overview of the proposed development plans. The document also provides a summary of potential environmental and social impacts and other environmental and social issues relevant to the proposed activities. Appropriate measures to mitigate key adverse environmental and social effects that may arise during project construction and operation are also provided. This NTS document and other materials will be placed in the locations shown below on (add disclosure date XXX). During a 60 / 120 (delete as appropriate) -day period beginning on (add disclosure date XXX), anyone can provide comments and recommendations on the environmental, social and other aspects of the project. Comments can be made at public consultations to be held at the locations shown below, and may be submitted to the address below. Environmental and social documents will be available for review during normal business hours at the following location: XXXX (add details)
Meetings at which anyone can make comments will be held as follows: XXXX (add details) The dates and times of public meetings will be announced at least three weeks before the meeting(s), and advertised in local mass media. For further information on this project, or to provide comments on the project or the environmental and social documentation, please contact: Comments may be submitted to: Name Contact information Address: Complete all contact Phone: details Email:
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8.0 Description of the Proposed Development
Add project description – • prospective annual electricity generation, • equipment to be installed, • permitting requirements, • Location, size, (including location map(s)
9.0 Environmental, Health, Safety and Social Review
Key Environmental and Social Elements Several documents collectively make up the environmental and social documentation for the project. The Non Technical Summary is described above, while the other documents are described here. Environmental and Social Action Plan (ESAP) As part of the environmental and social due diligence evaluation, a wide review was conducted of corporate environmental, health, safety and social management arrangements. From the overall review, an Environmental and Social Action Plan (ESAP) has been developed which lists key actions to ensure areas for improvement can be implemented and include mitigation measures discussed above. This ESAP is being disclosed for public comment; key mitigation measures are described below. Stakeholder Engagement Plan (SEP) (Insert company name XXX) has prepared a Stakeholder Engagement Plan (SEP) for the Project. The SEP will guide (insert company name XXX) in communicating with people, institutions and any other stakeholders who may be affected by or interested in the implementation of Project. (Insert company name XXX) has assigned a social liaison officer, who will be responsible for keeping open dialogue with stakeholders groups and local public. This SEP is being disclosed for public comment. At any time before and during construction and operation, any stakeholder will have a chance to raise any concerns, provide comments and feedback about the Project. All such comments and grievances from people will be accepted, processed and answered by (insert company name XXX) in a timely manner.
Key Features Key environmental features and sensitive locations from a social perspective in relation to the site include:
XXX – add details
Potential Impacts and Mitigation Measures ERM 80 KasREFF SER RPER SSH – June 2014
The EBRD’s environmental and social diligence evaluation determined that the project could have negative impacts on environmental resources and on people if they are not controlled carefully. Therefore, the EBRD will require (insert company name XXX) to implement many actions (“mitigation measures”) to prevent, reduce, or mitigate impacts on people and the environment. A summary of key impacts and mitigation measures have been identified, and they are summarised in Appendix A.
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Overview of Potential Impacts and Mitigation
Resource Potential Impact / Issue of Concern Mitigation
For example … Climate and Air Quality
Geology, Geohazards and Soils
Surface Water & Groundwater
Water Supply
Ecosystems and Flora & Fauna Noise
Waste Management
Cultural Heritage Tourism
Visual Landscape
Socio-economics
Traffic Management
Occupational Health & Safety Public Health & Safety
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Others…
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Kazakhstan Renewable Energy Financing Facility (KazREFF)
TEMPLATE - PROJECT NAME
DATE
Stakeholder Engagement Plan
Prepared for:
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CONTENTS 1 Introduction 86 1.1 Background 86 1.2 Description of the Proposed Development 86 1.3 Overview of XXX (add company name) 86 1.4 Objectives of the Stakeholder Engagement Plan (SEP) 86 1.5 Structure of SEP 87 2 Regulatory Context 88 2.1 Kazakhstan requirements for stakeholder engagement/ public consultation 88 2.2 EBRD requirements for stakeholder engagement and public consultation 88 3 Summary of previous stakeholder engagement 90 3.1 EBRD previous stakeholder engagement and consultations in Kazakhstan 90 3.2 KazREFF SER Consultations 90 3.3 Public disclosure and consultations during project 91 3.4 Other consultations during the project 91 4 Stakeholder Identification and Communication Methods 92 5 Disclosure of Information and Stakeholder Engagement Programme 94 5.1 Disclosure of general information 94 5.2 Disclosure of information relevant to Project 94 5.3 Stakeholder engagement programme 94 6 Timetable 95 7 Public Grievance Mechanism 96 8 Roles and Responsibilities 97
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1 Introduction
1.1 BACKGROUND Add summary of company proposing development – i.e private / public owned, company structure and operations Add summary of project proposals – i.e type of power plant, size and location Add summary of environmental studies undertaken to date – i.e an ESIA?, specialist surveys? (Company name XXX) has approached the European Bank for Reconstruction and Development (EBRD) for financing. The project is thus subject to EBRD’s 2008 Environmental and Social Policy and has been determined as a Category XXX project (add details of whether it is a category A or B project). EBRD has conducted an environmental and social due diligence assessment of the project and supported the development of applicable environmental and social documentation, namely a Stakeholder Engagement Plan, an Environmental and Social Action Plan, and a Non Technical Summary of the environmental and social considerations (also add reference to other relevant documents if appropriate eg an ESIA, specialist studies). To meet EBRD requirements for stakeholder engagement and public consultation and disclosure (EBRD Performance Requirement PR10), a stakeholder and public engagement process with development of a Stakeholder Engagement Plan (SEP) will also be directly applied to this project. These details are laid out in this document, the SEP. EBRD considers stakeholder engagement as an essential part of good business practices and corporate citizenship, and a way of improving the quality of projects. In particular, effective community engagement is central to the successful management of risks and impacts on communities affected by projects, as well as to achieving enhanced community benefits.
1.2 DESCRIPTION OF THE PROPOSED DEVELOPMENT Add project description – • prospective annual electricity generation, • equipment to be installed, • permitting requirements, • Location, size, (including location map(s)
1.3 OVERVIEW OF XXX (ADD COMPANY NAME) Add summary of company proposing development – i.e private / public owned, company structure and operations
1.4 OBJECTIVES OF THE STAKEHOLDER ENGAGEMENT PLAN (SEP) This SEP has been developed with the aim of explaining how company name XXX will communicate with people and institutions who may be affected by or interested in the Project, at various stages of project preparation and implementation. The plan includes a
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grievance mechanism for stakeholders to raise any concerns related to the project for company name XXX attention. 1.5 STRUCTURE OF SEP The remainder of this SEP is organised as follows: • Chapter 2 briefly describes applicable regulations and requirements for stakeholder engagement and public consultations. • Chapter 3 summarises previous and on-going stakeholder engagement and public consultation activities. • Chapter 4 identifies stakeholders and describes communication methods with them. • Chapter 5 describes stakeholder engagement program and disclosure of information. • Chapter 6 describes roles and responsibilities for handling the consultation and information disclosure process. • Chapter 7 describes a grievance mechanism by which feedback, comments, concerns and complaints may be communicated to company name XXX and how these grievances and comments will be handled.
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2 Regulatory Context
2.1 KAZAKHSTAN REQUIREMENTS FOR STAKEHOLDER ENGAGEMENT/ PUBLIC CONSULTATION Kazakhstan is a signatory for Aarhus Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters (UNECE)6. The convention is designed to improve the way ordinary people engage with government and decision-makers on environmental matters. Consequently, citizens of Kazakhstan are entitled to be informed about all environment related issues pertaining to the project and it is the responsibility of public authorities, local authorities, or government departments to reveal such environmental information. National legislation also foresees broad public involvement in decision-making process. Further details to be added….
2.2 EBRD REQUIREMENTS FOR STAKEHOLDER ENGAGEMENT AND PUBLIC CONSULTATION Since EBRD may be involved in funding the Project, the Project must meet the best international practices and requirements for stakeholder engagement and public consultations as specified in the EBRD Environmental and Social Policy of 2008.
The principles, requirements, methodological and procedural aspects of stakeholder engagement for EBRD Category A and B projects are described in detail in PR10 “Information Disclosure and Stakeholder Engagement 7 . PR10 outlines a systematic approach to stakeholder engagement that will help clients build and maintain over time a constructive relationship with their stakeholders, including the locally affected communities.
As required, the following important stages shall be implemented for the Project engagement and consultation process: - Identification of project stakeholder groups. Identification of stakeholders, including members of the public who could be affected by the Project construction and operation. - Stakeholder engagement process and information disclosure. During this step, company name XXX is to ensure that identified stakeholders are appropriately engaged on environmental and social issues that could potentially affect them through a process of information disclosure and meaningful consultation. - Meaningful consultation. The consultation process will be based on the disclosure of information relevant to the Project activities and operations. The consultation process will be undertaken in a manner that is inclusive and culturally appropriate for all stakeholders, including effected communities and vulnerable groups.
6 UNECE Aarhus Convention on access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters
7 EBRD Environmental and Social Policy 2008 (http://www.ebrd.com/downloads/about/sustainability/2008policy.pdf)
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- Grievance mechanism. Maintaining a grievance process by which the general public and other stakeholders can raise concerns, and which will be handled in a prompt and consistent manner.
The stakeholder engagement process and SEP preparation was also guided by the IFC Good Practice Handbook8 that defines the best practice approach to stakeholder engagement.
8 http://www.ifc.org/ifcext/enviro.nsf/AttachmentsByTitle/p_StakeholderEngagement_Full/$FILE/IFC_StakeholderEngagement.pdf
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3 Summary of previous stakeholder engagement
3.1 EBRD PREVIOUS STAKEHOLDER ENGAGEMENT AND CONSULTATIONS IN KAZAKHSTAN The European Bank for Reconstruction and Development (”EBRD” or the “Bank”) has made RES a key priority for investment in its countries of operation and has reviewed a number of early stage RES projects in Kazakhstan. The Bank has gained initial approval from the Clean Technology Fund (CTF) for concessional finance of up to $110 million to help create markets for power from RES in Kazakhstan. The Bank is now in the process of establishing dedicated financing facilities to enable it to provide finance to both larger and smaller RES projects in Kazakhstan (up to €10 million per project). This will be supported by funds from the CTF. The Bank has been active since 2008 in assisting the Government of Kazakhstan (the “Government”) through a technical cooperation programme in supporting the preparation of legislation to support RES development which has involved extensive stakeholder dialogue with the Ministry of Industry and New Technologies (MINT). In 2012, during the early stages of renewable energy programme development for Kazakhstan, the EBRD launched the assignment Kazakhstan Renewable Energy Development Framework and Regulatory Support (TCS number 34068). This assignment was to provide technical assistance in renewable energy regulatory support and institution building to the Kazakhstan Ministry of Industry and New Technologies (MINT; subsequently renamed the Ministry of Environment and Water Resources, or MEWR). Included in that assignment was a Renewable Energy Market Study, which included extensive stakeholder dialogue to establish the appropriate structure for renewable energy regulation in Kazakhstan. A number of key stakeholders and interested parties were identified at that stage, including local authorities and regulators at different levels, potential donor agencies, scientific and research institutes, and private developers. All targeted groups were contacted, and a series of individual meetings and workshops were organized and undertaken.
3.2 KAZREFF SER CONSULTATIONS
The Kazakhstan Renewable Energy Financing (KazREFF) undertook a large stakeholder engagement exercise alongside the Strategic Environmental Review (SER) of the potential effects of implementing renewable energy projects funded under KazREFF. The SER consultations were undertaken in three stages:
• Stage 1 (between April and July 2013). In Stage 1, the information about the KazREFF SER and SER Scoping Report was disclosed to with 30 representatives of various stakeholder groups; 13 of whom were individually interviewed. Representative stakholders included representatives of local authorities, manufacturers, developers and consultants involved in the development and implementation of renewable energy projects in Kazakhstan. The initial list of stakeholders resulting from stakeholder identification and analysis was expanded and amended where necessary. • Stage 2 (between July 2013 and September 2013). In Stage 2, the SER Environmental Scoping Report was published on the KazREFF SER website at http://www.kazreff-
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ser.com. EBRD conducted half-day scoping meetings on 16 and 18 July 2013 in Astana and Almaty, respectively, to encourage broad stakeholder participation in the development of the SER. Outreach activities, including mailing, emailing and telephoning contacts, were undertaken with 86 organizations representing a variety of stakeholders in the Astana and Almaty areas including government, developers, non- governmental organizations (NGOs), consultants, and advisory bodies. Eighteen organizations representing a variety of stakeholders participated in the meetings. • Stage 3 (June 2014 through October 2014). In Stage 3, the Draft SER report was disclosed and initiated formal 120-day public consultation period, where all stakeholders had an opportunity to provide comment on the disclosed Draft SER report. During this timeframe, two workshops were held to both inform and educate stakeholders about the SER and the KazREFF.
• 3.3 PUBLIC DISCLOSURE AND CONSULTATIONS DURING PROJECT Add details of any public disclosure / consultation undertaken to date as part of this project.
3.4 OTHER CONSULTATIONS DURING THE PROJECT Add details of any other consultation that may have occurred as part of the project, for example with authorities to obtain necessary permits.
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4 Stakeholder Identification and Communication Methods
In order to define a communication process in line with EBRD PR10, company name XXX has identified several stakeholder groups that may be interested and/or affected by the Project development and implementation. The stakeholders identified include: • Internal stakeholders, such as company name XXX employees and construction contractors’ workers
• External stakeholders, such as o governmental authorities, o non-governmental organisations and o local residents.
Others who wish to be included in the list can contact company name XXX and be put on the mailing list for information on reporting, meetings, or other consultation opportunities.
Table 1 describes the stakeholder engagement programme and communication process by providing contact details of certain stakeholders, and identifying communication methods and specific media that will be used to notify stakeholders of information. Any suggestions for improvement of proposed communication methods or media are welcomed and can be submitted via the contact information at the end of this document.
Table 1. Stakeholder engagement programme for the Project Stakeholder group Description Communication method / Proposed Media channel and contact information (where applicable) Internal Stakeholders Employees XXX For example… Company website?? - Internal newsletters www.kazreff.com ?? - Emails - Grievance procedure - Bulletin boards - Union meetings - Inserts with payslips Temporary Construction XXX For example… XXX Workers, subcontractors - Internal newsletters - Emails - Grievance procedure - Bulletin boards - Union meetings - Inserts with payslips Unions: XXX For example… XXX • XXX - Official correspondence.
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Table 1. Stakeholder engagement programme for the Project Stakeholder group Description Communication method / Proposed Media channel and contact information (where applicable) - Union newsletter. - Information on request to union representatives. External Stakeholders Population in XXX XXX XXX Newspapers: XXX Radio: XXX Company website?? www.kazreff.com ?? Local authorities and public enterprises: For example… XXX For example… XXX Water Company - Communication via official letters and meetings Public Health Institute XXX For example… XXX - Ongoing working linkages with the Institute County / city XXX For example… XXX administration - Ongoing working linkages with the authorities - Official correspondence - Meetings State level authorities: - Ukrainian Water XXX For example… XXX Authority - Official correspondence - Ministries - Meetings • XXX
Other relevant external stakeholders For example… XXX - Meetings (invitation to public Company website?? Local Tourist Board consultation meetings) www.kazreff.com ?? Others..
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5 Disclosure of Information and Stakeholder Engagement Programme
5.1 DISCLOSURE OF GENERAL INFORMATION Provide details of general information disclosure – website, company reports etc
5.2 DISCLOSURE OF INFORMATION RELEVANT TO PROJECT To meet the environmental and social requirements and performance standards of EBRD and EU, company name XXX will develop, disclose to the public and then implement an Environmental and Social Action Plan (ESAP), which will identify mitigation measures to minimise, reduce, eliminate or control potential adverse impacts on environment and people.
The final version of ESAP will be published on company name XXX official website (or KazREFF website?) and printed copies will be available on request from XXX (contact information available in the table above).
The local population will receive timely information (through the local media listed in the table above and announcements regarding grievance management in relation to construction activities, safety measures in the vicinity of the construction site, traffic management, employment opportunities and opportunities for service provision (catering, accommodation of workers, laundry services, etc.) and any other information identified through the development of the ESAP.
Annual project progress reports, including environmental and social impacts, health and safety performance and implementation of the external grievance mechanism will also be disclosed on company name XXX official website (or KazREFF website?) and will be available on request XXX (contact information available in the table above).
5.3 STAKEHOLDER ENGAGEMENT PROGRAMME Consultations and disclosure of information for local public
Public consultations will be held after a draft Environmental and Social Action Plan has been developed. Add details of proposed consultation. For example - who will manage it, when will it take place, and with whom?
Other stakeholder engagement activities Add details of proposed consultation. For example - who will manage it, when will it take place, and with whom?
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6 Timetable
Stakeholder(s) and engagement Issues / documents Possible dates activity(ies) During the development of ESAP and NTS XXX XXX XXX XXX XXX XXX When the ESAP/SEP/NTS are completed All stakeholders Publish ESAP, SEP and NTS (in XXX English and Ukrainian) and inform all stakeholders through local media. Include responses to comments, suggestions which were not incorporated in the documents. Before construction Contractors / temporary workers Agree construction related XXX grievance management, inform all stakeholders; Code of conduct for temporary workers, trainings Local population Information on safety measures XXX Traffic Management Plan Employment opportunities and opportunities for service provision During construction and operation Public consultation meetings if Implementation of the ESAP, new XXX necessary (determined in cooperation impacts, revision of documents, with EBRD) implementation of SEP, processing and responding to grievances
After construction
Ongoing meetings and cooperation, throughout the life of the project, with the following external stakeholders: • XXX
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7 Public Grievance Mechanism
The objective of a grievance procedure is to ensure that all comments and complaints from any project stakeholder, including local/regional authorities, residents of nearby residential areas, company name XXX employees, company name XXX contractors’ staff and other interested parties, are considered and addressed in an appropriate and timely manner. All grievances will be acknowledged and responded to within a reasonable timeframe. company name XXX will accept all comments and complaints associated with the project. A sample of a Comments and Complaints Form is shown in Appendix A. The comments and complaints will be summarised and listed in a Complaints/Comments Log Book, containing the name/group of commenter/complainant, date the comment was received, brief description of issues, information on proposed corrective actions to be implemented (if appropriate) and the date of response sent to the commenter/complainant. Any person or organisation may send comments and/or complaints in person or via post, email, or facsimile using the contact information specified in Section 8.0 below.
All comments and complaints will be responded to either verbally or in writing, in accordance with preferred method of communication specified by the complainant in the Comments and Complaints Form. Comments will be reviewed and taken into account in the project preparation; however they may not receive an individual response unless requested.
All grievances will be registered and acknowledged within 5 days and responded to within 20 working days. Company name XXX will keep a grievance log and report on grievance management, as part of annual project progress reports, available at the company name XXX website and on request at add contact details.
Comments and concerns regarding the project can be submitted in writing in the following ways: • electronic form on company name XXX website or KazREFF website?: add details • email: XXX • by post or hand delivered to (see example grievance form attached): – XXX • by phone: – XXX
Provide contact person and specify contact details Individuals who submit their comments or grievances have the right to request that their name be kept confidential.
During construction, grievances in relation to construction activities will be managed by company name XXX and construction contractor. Local residents will be informed about the contractors contact information before construction begins, through the local media (listed in the table above) and announcements in public places.
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A separate grievance mechanism is available for workers, both employees of company name XXX and the contractors. 8 Roles and Responsibilities
Provide contact person and specify contact details will have the overall responsibility for handling the consultation and information disclosure process, including organisation of consultation process, communication with identified stakeholder groups, collecting and processing comments/complaints, and responding to any such comments and complaints. Depending on the nature of a comment/complaint, some comments or complaints will be provided to the appropriate person in the company for a response.
Name of the person and title Affiliation XXX Company: XXX Postal Address: XXX Telephone: XXX E-mail address: XXX Hotline: XXX
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APPENDIX A Comments and Complaints Sample Form FORM FOR COMMENTS, COMPLAINTS AND REPORTS OF INDIVIDUALS Reference No: Full Name
Contact Information By Post: Please provide mailing address: and Preferred method ______of communication ______
Please mark how you wish to be contacted By Telephone: ______(mail, telephone, e-
mail). By E-mail ______
Description of Incident or Grievance: What happened? Where did it happen? Who did it happen to? What is the result of the problem? Source and duration of the problem?
Date of Incident/Grievance
One time incident/grievance (date ______) Happened more than once (how many times? _____) On-going (currently experiencing problem)
What would you like to see happen to resolve the problem?
Signature: ______Date: ______Please return this form to: XXXXXXXX Address ______: Tel.: ______or E-mail: ___
ERM 98 KasREFF SER RPER SSH – June 2014
CONTENTS
Kazakhstan Renewable Energy Financing Facility (KazREFF)
PROJECT NAME
Environmental and Social Action Plan – Small Hydropower
DATE
Prepared for:
ERM 99 KasREFF SER RPER SSH – June 2014
CONTENTS
1 PROJECT OVERVIEW 101 1.1 Project approach 101 1.2 Scope of this ESAP 101 1.3 ESAP for small hydropower projects 103
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9 PROJECT OVERVIEW
9.1 PROJECT APPROACH To encourage businesses to pursue sustainable energy projects, the European Bank for Reconstruction and Development (EBRD) has launched the Kazakhstan Renewable Energy Financing Facility (KazREFF). KazREFF aims to ‘provide development support and debt finance to renewable energy projects which meet required commercial, technical and environmental standards’. KazREFF not only provides tailor-made financing, but also provides technical assistance for businesses and local authorities based on information gathered and analysed by stakeholders to promote projects that are often challenging to finance and implement. KazREFF is part of the EBRD’s Sustainable Energy Initiative (SEI) which addresses the challenges of climate change and energy efficiency. Since the launch of the SEI in 2006, the EBRD has remained at the forefront in helping countries from Central Europe to Central Asia secure sustainable energy supplies and finance the efficient use of energy that will cut demand and imports, reduce pollution, and mitigate the effects of climate change. In co-operation with the national authorities in Kazakhstan, EBRD commissioned a Strategic Environmental Review (SER) for the KazREFF programme, focusing on renewable energy technologies in optimal areas of Kazakhstan. The renewable energy technologies specifically reviewed in the SER include small hydropower, on-shore wind, solar photovoltaic, and biogas technologies. Four Environmental and Social Action Plan (ESAP) templates have been produced – one for each of the renewable energy technologies – to provide a framework for further development at the inception of a given renewable energy project that is seeking funding from KazREFF. The SER and associated Environmental and Social Action Plans comply with the EBRD’s Environmental and Social Policy and its Public Information Policy.
9.2 SCOPE OF THIS ESAP This ESAP is for the small hydropower renewable energy scenario; It includes a series of actions to be undertaken in order to manage – that is, to plan and implement specific measures to avoid, reduce, control, or otherwise mitigate – potential environmental, occupational health and safety, and social impacts during construction and operation9. This ESAP should be considered as a template which will be reviewed and amended by project proponents who wish to develop specific small hydropower projects funded by KazREFF in the future; and will be part of the contract between the project developer and EBRD. It is envisaged that EBRD will require performance of the required actions to be regularly reported and that it will periodically monitor implementation of the ESAP. The table below presents the actions required by this ESAP, organised by the EBRD’s Performance Requirements. These actions should be added to as befits the individual project situation; If there is a good reason to remove an action from the table this can be agreed with the EBRD during the development of the project. The table shows the source and timing of
9 For purposes of this ESAP, “construction” includes all actions in the field to construct the project, including support and ancillary facilities such as construction camps, roads, temporary or permanent buildings, staging areas, etc. “Operation” means routine and non-routine operation and maintenance of the hydropower plant and support facilities, and “project performance” includes the entire period of construction and operation.
ERM 101 KasREFF SER RPER SSH – June 2014
the requirement and the criteria by which performance of the action will be evaluated. Implementation of all the actions will be the responsibility of project developer. When other companies perform work under contract, the developer will be responsible for those contractors’ compliance with the requirements of the ESAP. This is expected to be accomplished by inclusion of appropriate requirements in contracts and subcontracts, and by direct oversight and supervision by the developer as needed. As specified in various required actions, or as otherwise agreed by the parties, once produced, a project-level ESAP may be further revised from time to time during project performance. No changes will allow violations of Kazakhstan law or of EBRD requirements for environmental and social performance.
ERM 102 KasREFF SER RPER SSH – June 2014
KAZAKHSTAN RENWEABLE ENERGY FINANICNG FACILITYN (KAZREFF)
9.3 ESAP FOR SMALL HYDROPOWER PROJECTS Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, Measure of success completed etc.) 0 Prepare and submit reports on status of ESAP EBRD PR1 Each six months Submission reports on environmental, implementation and environmental and social during construction, occupational health and safety, and performance, including resolution of grievances. annually thereafter social (ESHS) performance 1. Environmental and social planning and management 1.1 Achieve and maintain environmental and social Best international Ongoing Include in ESHS report the status of management systems equivalent to ISO 14001. management practices. environmental and social management systems PR1 1.2 Achieve and maintain an occupational health Best international Ongoing Include in ESHS report the status of OHS and safety (OHS) management system to OHSAS management practices. management systems 18001 or equivalent for all companies associated PR1 with energy generation, transmission and distribution. 1.3 Appoint responsible manager(s) for Best international Throughout - Appointment of corporate ESHS environmental and occupational health and management practices. construction and manager safety issues. Train foremen and appropriate operation PR1 - Training of foremen and other staff staff on each construction team and ensure operations meet the relevant requirements of this - Ultimate goal: full compliance with ESAP and, as needed, the requirements of ESAP EBRD’s Performance Requirements. - Include in ESHS report updates on appointment(s) and training 1.4 Develop comprehensive waste management Best international Prior to and during - Preparation and implementation of plans for the project. Plans should include (at a management practices. construction waste management plans minimum): - Include in ESHS report information ERM 103 KasREFF SER RPER SSH – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, Measure of success completed etc.) - Procedures for proper handling of all waste PR1 on plan preparation and waste generated at the construction or operational management compliance status site (including hazardous and non-hazardous waste); - Methods to control odour and pests; - Methods to verify proper off-site management of related wastes by contract waste managers; and, - Measures to minimise waste generation and maximise reuse and recycling. Note that wastes include paper, printer cartridges, lights, and office waste as well as construction and industrial waste 1.5 Establish corporate policy and procedures for Best international Prior to and during ESHS reports to EBRD on: oversight of contractor (if project proponent is management practices. construction - Programme description not also contractor) ESHS performance during PR1 construction, to include (at a minimum): - Highlights of performance (appointments, inspections, etc.) - Inclusion of appropriate ESAP and other legal requirements in contracts, including - Training requirement for staff/management training; - Contractor summaries (both at - Assignment of clear responsibilities within contractor level and compiled project developer for contractor oversight of the level) in terms of environmental and projects; OHS performance summaries - Regular inspections of sites and contractors’ construction camps; - Contractor reports on performance sufficient to allow inclusion of data in ESHS reports to the Bank, and to allow developer to ERM 104 KasREFF SER RPER SSH – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, Measure of success completed etc.) determine if corrective actions are needed; and, - Verification of training and professional credentials for contractor environmental and OHS managers and staff. 1.6 - Obtain all required permits for the Local regulatory Prior to construction - Identify permits required and projects and comply with permit requirements. requirements and during received in ESHS reports; and, operation, as PR1 - Report on compliance in ESHS applicable reports 1.7 - Monitor performance of project during PR1 During operation Submission of monitoring reports operation against the environmental and social demonstrating that predicted standards and objectives set and submit regular environmental and social effects are being satisfactory mitigated for. reports to EBRD at agreed timescales and for an agreed period (likely to be a number of years). 2. Performance Requirement 2: Labour and Working Conditions 2.1 Evaluate HR management system and PR2 Prior to construction - Until complete, include in ESHS procedures against EBRD requirements and report status of required and Kazakhstan law, including specifically completed updates to HR systems; provisions covering: - Report annually on key worker data, - terms of employment and dismissal; including dismissals and new hires, status of medical checks, etc.; and, - grievance mechanism; - Include in ESHS report data on - discrimination, harassment, violations and numbers of workers in various human rights; categories (management, skilled, - proscription of forced and child labour; unskilled, etc.), and breakdown by gender. - mandatory medical checks for new hires; and,
ERM 105 KasREFF SER RPER SSH – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, Measure of success completed etc.) - social leave/benefits. Update system/policies as necessary to ensure compliance. 2.2 As part of policy development under item 1.5 PR2 Prior to contracting - Preparation and implementation of above, develop and implement a contractor plan; and, management plan for the project, and procedures - Report on contractors’ compliance ensuring contractor’s compliance with EBRD PR and oversight results. 2 and Kazakhstan labour law. 2.3 Support local labour force by: Best international Throughout - No complaints from labour force; practices. construction and, - Providing realistic information on employment opportunities, with transparent PR2 - Include data on use of local labour in hiring practices; ESHS reports. - Advertise for all positions; - Employing local labour where possible; - Pay wages at least average for the area for comparable positions; and, - Construction camps must comply with Kazakhstan law and provide adequate heating, showering and cooking facilities. 2.4 Develop and implement an OHS plan to guide Best international Plan in place prior - Preparation and implementation of all project-related activities on the project sites practices. to construction (for OHS plans for projects; during construction and then throughout contractors, prior to PR2 - Review and approval of contractor operation. Also require contractor site operations). OHS plans; and, plan/compliance. Requirements to include (but Throughout not be limited to): - Include in ESHS reports to Bank data construction and on performance by developer and - Job- and task-specific hazard analysis and operation. contractors (hours worked, accidents, controls for developer and contractor’s
ERM 106 KasREFF SER RPER SSH – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, Measure of success completed etc.) activities; lost time, etc.). - Provision of PPE, requirements for use of PPE, and enforcement of PPE use; - Safety training for all personnel, covering hazards for their jobs; - Review and approval of contractors OHS plans, to meet same standards as developer’s plan; - Oversight of contractor OHS implementation, including mandatory reporting; and, - Recording incident statistics, including total work hours.
2.5 Location and life activities of construction camps Best international At all times Compliance shall meet the requirements of Kazakhstan law practices. construction camps Include data on incidents in ESHS and EBRD PR2. PR2 are occupied reports 3. Performance Requirement 3: Pollution Prevention and Abatement 3.1 Examine in detail the potential impacts of the PR3 Prior to construction Surface water assessment reports. projects on the level and flow of surface waters compared to their natural state and considering existing demands upon water resources 3.2 Examine in detail the potential impacts of the PR3 Prior to construction Groundwater assessment reports. projects on the level and flow of groundwaters compared to their natural state. 3.3 Implement mitigation measures and best Best international Throughout Minimal dust generation management practices to prevent / reduce / practices. construction control air pollution from fugitive dust and
ERM 107 KasREFF SER RPER SSH – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, Measure of success completed etc.) vehicle / equipment emissions. PR3 - Control dust emissions in dry periods by using water or other dust suppression methods on roads and other areas that may generate dust; - Ensure efficient usage of delivery vehicles; including use of alternative and/or more efficient delivery methods (including for example rail, boat) during construction to optimise the emissions to atmosphere per payload; - Ensure all vehicles carrying spoil and all stockpiles are covered; - Switch vehicles and equipment off when not in use; and, - Keep all motorised equipment and vehicles well-maintained to reduce emissions. 3.4 Develop erosion, sediment and water quality Best international Throughout Mitigated adverse impacts on water control plan for all areas where the ground and practices. construction quality riverbed will be disturbed during construction. PR3 Report on impacts in ESHS reports. Plan should (at a minimum): - Specify use of good housekeeping practices and best management practices to minimise siltation dispersal, such as settling ponds, using silt curtains along all waterways, straw bales, check-dams, and seeding for example; - Keep hard-standing areas and road surfaces
ERM 108 KasREFF SER RPER SSH – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, Measure of success completed etc.) clean from mud and oil build up; - Keep stockpiles covered, minimise bare ground near rivers; - Store hazardous and potentially polluting materials in bunded, secure, areas away from watercourse and pathways to watercourses (e.g. drains, ditches); - Use kerbed/ bunded areas to prevent run off to river; - Particular attention should be given to minimising erosion and stormwater runoff into streams and aquatic habitat at critical areas or time periods for aquatic life; - Silt collected in any device or structure should be cleaned away regularly; and, - Inspections of vehicles and equipment for leaks before use near or in water. 3.5 Where applicable, onduct dredging in rivers only Best international Plan required before Agreement by authorities if there is no feasible alternative, and only after practices dredging Report to EBRD on planning and full consultation with authorities. If dredging of PR3 implementation rivers is needed, develop dredging management plan that requires, at a minimum: - Limit dredging to periods when there is no spawning or rearing of young fish. Seek advice from knowledgeable aquatic biologist to select periods of least impact on aquatic ecosystem;
ERM 109 KasREFF SER RPER SSH – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, Measure of success completed etc.) - Consider alternative dredging techniques to reduce impacts, including suction dredging; and, - Include dredged material in waste management plan under item 1.4 above. 3.6 Implement measures to prevent / reduce / Best international Throughout Mitigation in place for potential adverse control ground contamination as a result of spills practices. construction and impacts of ground contamination. of fuel, lubricants and other chemicals. operation PR3 - Store fuels and oils in bunded containers with 110% capacity; - Ensure drip-trays are in place where fuels or oils are stored or used; - Identify a designated bunded refuelling location; - Educate drivers and equipment operators in proper fuel management, including clean-up of spills; and, - Make spill kits available, and use if necessary to clean up oil spills etc before contaminants can enter the ground or watercourses. 3.7 Ensure appropriate containment and disposal of Best international Throughout Reduction in the risk of water / land construction wastewater, including sanitary practices. construction and pollution and impacts on ecology water and storm water. All sanitary and storm operation PR3 water to be collected and delivered to a nearby waste water treatment works. 3.8 Developer to ensure that the project team has a Best international Throughout Potential major incidents identified and high level of preparedness for emergencies (such practices. construction and avoided through emergency planning; if
ERM 110 KasREFF SER RPER SSH – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, Measure of success completed etc.) as earthquakes and major dam failures) and that PR3 PR4 operation major incidents occur, these are handled an appropriate emergency plans is in place and according to the planned procedures. understood by developer and contractor staff. Include the local community in the emergency plan. 3.9 Develop plans to reduce project-related Best international Planning prior to GHG emissions minimised greenhouse gas (GHG) emissions practices. construction and GHG emissions reported to EBRD in implementation - Establish baseline GHG emissions; PR3 ESHA report. throughout - Estimate construction and operation GHG construction and emissions and take steps to reduce these operation during project design; and, - Record actual GHG emissions during construction and operation. For small HPP projects which will include the damming of watercourses and creation of new reservoirs, particular consideration should be given to processes such as methanogensis which may affect the release of greenhouse gases; and measures should be planed to avoid or reduce this potential effect (such as removal of vegetation from areas which will be subject to flooding during the formation of new reservoirs). 3.10 Develop reinstatement plans for working areas Best international Planning prior to Working areas reinstated with including for the re-vegetation of areas cleared practices. construction and appropriate vegetation as soon as prior to, or during, construction. implementation practicable following construction (it is PR3 following recognised that could take a number of construction. months or in some cases years). 3.11 Plan and implement preventative and avoidance Best international Prior to construction Potential pre-construction and
ERM 111 KasREFF SER RPER SSH – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, Measure of success completed etc.) techniques to minimise the exacerbation of practices. construction stage landslide issues effects caused by landslides – which could arise identified and mitigated for. PR3 PR4 from land use changes due to project activities – through careful siting, land grading and planting. 3.12 Develop soil protection plan to include: Best international Prior to construction Mitigated for potential adverse impacts practices. upon soils. - Site selection and facilities arrangement (including transmission lines, access roads, PR3 PR4 etc) to avoid or minimise displacement of productive agricultural lands; - Measures to minimise compaction and other alteration of soil composition across working area; and, - Soil erosion across the working area (as separate to erosion of banks and river bed within the watercourse). 4. Performance Requirement 4: Community Health & Safety and Security 4.1 Develop and implement – and require PR4 Throughout - Public notices contractors to implement – procedures to protect construction and - Security training public health and safety, to include (but not be operation limited to): - Include in ESHA report to Bank data on notices, training, etc. - Traffic management plan for all drivers and equipment operators (see 4.2 below); - Public notice of construction operations near areas open to the public; - Methods to identify and prevent spread of those communicable diseases that can be
ERM 112 KasREFF SER RPER SSH – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, Measure of success completed etc.) transmitted by the project components or its workforce (including contractors); - Methods to prevent and minimise exacerbating impacts caused by natural hazards (such as landslides or floods); - Security as needed to prevent unauthorised access to project locations, with appropriate training for guards to be guided by the principles of proportionality, good international practice and Kazakhstan law; and, - Hazard notices/signs/barriers to discourage/prevent access to energised components or other dangerous areas. 4.2 Develop and implement a Traffic Management - Best international Throughout Traffic management plan Plan. practices construction and Include in ESHS reports data on all operation - Design routes so as to avoid schools, - PR4 accidents hospitals, and other areas where there may be heavy pedestrian or child use; - Notify communities and place signs on public roads prior to periods of heavy use; - Place warning signs along the perimeter of construction areas; - Confine construction activities to daylight hours; - Establish and enforce strict speed limits on- and off-site;
ERM 113 KasREFF SER RPER SSH – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, Measure of success completed etc.) - Provide training to all drivers, enforce compliance with traffic plan; and, - Identify and implement measures to reduce construction traffic where possible, for example through car sharing and use of bicycles etc. 4.3 Develop a noise monitoring programme that will PR2, PR4 Establish baseline Robust baseline establish a pre-construction baseline and to prior to construction Minimal off-site disturbance ensure construction and operational noise is Monitor noise within Kazakhstan law and to minimise off-site Early awareness of potential noise periodically disturbance to local population. impacts, allowing mitigation to be put in throughout place as required construction 4.4 Establish and enforce clear rules for workers Best international At all times when Include in ESHS report information on (including contractor employees) in construction practices construction camps complaints and incidents involving camps to prevent off-site disturbance incidents are occupied workers, and contractor/developer involving local residents. responses 5. Performance Requirement 5: Land Acquisition, Involuntary Resettlement and Economic Displacement 5.1 Avoid siting projects where they will cause PR5 PR4 Prior to construction Project siting in area of least disturbance disruption or displacement to established to communities Best international communities, farms and homes, or users of practices grazing land where possible through thorough consideration of alternatives. 5.2 If displacement is unavoidable, plan to improve PR5 PR4 Prior to construction Sustainable improvements to socio- or, at a minimum, restore the livelihoods and economic status of any displaced persons Best international standards of living of any displaced persons to practices pre-project levels. Displaced persons could include those who have legally recognisable rights or claims to the land, those with
ERM 114 KasREFF SER RPER SSH – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, Measure of success completed etc.) customary clams to the land, those with no legally recognisable rights or clams to the land, seasonal resource users such as herders/fishing families, hunter and gathers who may have interdependent economic relations with communities located within the project area. 5.3 Attempt to reach negotiated settlements with all PR5 Prior to construction Amicable agreements avoiding the need affected individuals / households for involuntary resettlement 5.4 If required, compensation to be provided at just PR5 Prior to construction Amicable agreements. replacement value, as determined by court Include information on certified valuators. This will take the form of acquisition/resettlement/ compensation replacement by a similar property or cash actions in ESHS report to Bank. compensation. 6. Performance Requirement 6: Biodiversity, Conservation and Sustainable Resource Management 6.1 Undertake pre-construction ecological surveys Best international Prior to construction Survey reports, focussed on area of and associated assessments of the project practices. proposed construction footprints (including ancillary works such as PR6 improvements to transmission lines and access roads) and surrounding areas to establish a robust baseline. Surveys and assessments should be included for terrestrial ecosystems and aquatic ecosystems as befits the specific project and situation. However, it is envisaged that for small HPP, surveys will particularly be needed for the following: - Fish and aquatic organisms; - Birds (including migratory species); and, - Wide-ranging mammals (including bats,
ERM 115 KasREFF SER RPER SSH – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, Measure of success completed etc.) otter, brown bear, bison, lynx and wildcat). 6.2 Develop an Ecosystem Protection Plan following Best international Develop plan prior Production of an Ecosystem Protection the ecological surveys. Follow the Biodiversity practices. to construction and Plan Mitigation Hierarchy: to Avoid, Minimise, follow plan during PR6 Mitigate and Offset likely adverse effects. This construction. plan to cover the construction and operational phases and to include consideration of all species and habitats applicable to the project. 6.3 Following construction, re-grade and re-vegetate Best international End of construction Reduced adverse effects on flora and disturbed areas with native grass and shrub practices. fauna species. PR6 6.4 Avoid development within sites protected for Best international Prior to construction Reduced adverse effects on flora and their biodiversity under international or practices. fauna Kazakhstan law (habitats and/or species) PR6 6.5 Provide sufficient regulation of water flows to Best international To be planned prior No net loss or a net gain of biodiversity ensure hydrological balance within protected practices. to construction and biodiversity areas to maintain site integrity. implemented during PR6 Consider: construction - utilising less sensitive site locations; or, - implementing more “environmentally friendly” technologies or systems (such as using air-cooled condensers for cooling, where required, rather than surface water withdrawals). 6.6 Undertake study of implications of the HPP on Best international Prior to construction Reduced adverse effects on fish and fish passage and establish requirements for practices. other aquatic organisms controls on the timing of operations and/or
ERM 116 KasREFF SER RPER SSH – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, Measure of success completed etc.) inclusion of fish protection and passage facilities. PR6 6.7 Avoid, or mitigate for, the siting of HPP in areas Best international important for nature tourism (including fishing practices. rivers) PR6 8. Performance Requirement 8: Cultural Heritage 8.1 Undertake archaeological desk study and site PR8 Prior to construction Survey report, focussed on area of investigations where necessary to identify the proposed construction. likelihood of presence of artefacts or other items of cultural significance.
8.2 Develop measures to avoid direct impacts on PR8 Prior to construction Protection of cultural heritage protected cultural heritage sites and their Include information on finds in ESHS settings (including UNESCO sites and those on report to Bank. the tentative list); and avoid, or where necessary mitigate for, impacts upon Registered Cultural Heritage Sites, Zones and Settlements, and unregistered or previously undiscovered sites by following a staged approach to cultural heritage studies involving qualified expertise and in consultation with the EBRD. 8.3 Before (and if needed, during) major earthworks, PR8 Throughout Protection of cultural heritage ensure the supervision of an archaeologist from a construction Include information on finds in ESHS competent conservatory institution to prevent report to Bank. destruction or theft of found objects and building remains with scientific or material value. 8.4 Develop a chance find procedure PR8 Prior to construction Protection of cultural heritage 8.5 Develop measures to avoid, or where not PR8 Prior to construction Protection of cultural practices and possible to avoid, mitigate for potential loss or resources
ERM 117 KasREFF SER RPER SSH – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, Measure of success completed etc.) disruption to cultural practices or resources. Include information on finds in ESHS report to Bank. 8.6 Undertake a Landscape and Visual Impact Best international Prior to construction Protection of landscapes Assessment (LVIA) of the project practices. PR8 8.7 Develop a Landscape Protection Plan following Best international Prior to construction Protection of landscapes the LVIA. Follow the Mitigation Hierarchy: to practices. Avoid, Minimise, Mitigate and Offset likely PR8 adverse effects upon the natural features and landscapes that have archaeological, paleontological, historical, architectural, religious, aesthetic or other cultural significance. This plan to cover the construction and operational phases and to consider the inclusion of the following aspects where applicable: - Screening of works and operations; - Sensitive route placement of power transmission lines, access roads and other associated works; - Select construction materials to integrate development into the surrounding landscape; 10. Performance Requirement 10: Information Disclosure and Stakeholder Engagement 10.1 Develop a Stakeholder Engagement Plan, PR10 Prior to construction Review and approval by EBRD including a Grievance Mechanism (SEP) 10.2 Complete EBRD ESIA requirements for Category PR10 Prior to construction Disclosure through suitable means, to be B projects with a disclosure package, to be agreed with EBRD, which could include: agreed with EBRD, comprising of at least the
ERM 118 KasREFF SER RPER SSH – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, Measure of success completed etc.) SEP, this Environmental and Social Action Plan - Flyers to local residents; and a Non-technical summary of the - Posters in local venues/ public halls; environmental and social assessment undertaken. - Information on KazREFF and/or developer’s websites; - Public meetings; and/or, - Other, as specified in SEP. 10.3 Implement the agreed SEP, inform stakeholders PR10 Throughout project Include in ESHS report: of activities and progress, and receive and - details on grievances and resolution; respond to grievances. and, - consultations and other outreach to the community, including authorities
ERM 119 KasREFF SER RPER SSH – June 2014
Prepared For: Consultancy Contract C26157REV/JPNS- 2013-02-01 Kazakhstan Renewable Energy Financing Facility (KazREFF) - Strategic Environmental Review
Renewable Project Environmental Review Report - Biogas
June 2014
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Contents
1.0 INTRODUCTION 1
2.0 RESOURCE AVAILABILITY AND POTENTIAL 2
2.1 RESOURCE AVAILABILITY 2
2.2 RESOURCE POTENTIAL 6
2.3 TRANSMISSION CAPACITY AND CONSTRAINTS 6
2.3.1 Existing Conditions 6
2.3.2 Anticipated Development 9
2.4 EXISTING PROJECTS 10
2.5 KNOWN PROPOSED PROJECTS 10
3.0 AVAILABLE AND PRACTICAL TECHNOLOGIES 11
3.1 COMPONENTS 11
3.1.1 LFG Collection System 12
3.1.2 Gas Cleaning System 14
3.1.3 Power Generation Systems 15
3.1.4 Flare Plants 19
3.2 GRID CONNECTIVITY 20
3.3 SITE DESIGN AND CONFIGURATION 21
3.3.1 Construction 22
3.3.2 Commissioning, Operation, and Maintenance 23
3.3.3 Decommissioning 24
3.4 DEVELOPMENT COSTS 24
3.5 SUPPLY CHAIN IN KAZAKHSTAN 25
4.0 ENVIRONMENTAL AND SOCIAL CONSTRAINTS 26
5.0 KAZREFF PROJECT APPRAISAL - ENVIRONMENTAL AND SOCIAL PERFORMANCE REQUIREMENTS 27
5.1 EBRD REQUIREMENTS 27
5.1.1 Category A 28
5.1.2 Category B 29
5.2 KAZAKHSTAN REQUIREMENTS 29
5.3 KAZREFF APPRAISAL PROCESS 31
5.3.1 Initial Screening 32
5.3.2 Documentation Review and Approval/Feedback 32
6.0 APPENDICES 34
1.0 INTRODUCTION
This Renewable Project Environmental Review (RPER) Report for Biogas in Kazakhstan is one of four separate reports (other RPER reports were prepared for wind, small hydropower, and solar) that have been prepared by Environmental Recourses Management (ERM) for the European Bank for Reconstruction and Development (EBRD). These RPER reports are prepared to support the Kazakhstan Renewable Energy Financing Facility (KazREFF) Strategic Environmental Review (SER) and provide a resource to provide guidance to developers and their consultants, as well as technical evaluators of proposed renewable projects, by identifying areas of good potential and the nature and scale of technologies that can be applied in different parts of Kazakhstan.
It should be noted that for biogas, there are two types of facility that could be used: landfill gas (LFG) and anaerobic digestion of animal manure. The energy from animal manure is not feasible at this stage because Kazakhstan Renewable Energy Market Study (KREMS) indicated the energy was not viable or there was a significant lack of data to assess its viability; therefore, this RPER focuses on electricity generated from LFG.
The source documents which have informed this RPER report are as follows:
• ERM KazREFF Strategic Environmental Review, Final Inception Report, 29 May 2013; • ERM KazREFF Strategic Environmental Review, Draft Scoping Report, 21 May 2013; • Mercados Energy Markets International, Kazakhstan Renewable Energy Market Study (KREMS), Draft Final Report, July 2013 (ÅF-Mercados EMI (2013)); • Black and Veatch, Renewable Energy in Ukraine Technical Report: Biogas, 1 September 2011 (Black and Veatch 2011).
These sources have been supplemented by additional research carried out by ERM and additional sources of data identified in the text.
ERM 1 KasREFF SER RPER Biogas – June 2014
2.0 RESOURCE AVAILABILITY AND POTENTIAL
This section of the report identifies the characteristics of the biogas rich resource areas of the country and the regions of Kazakhstan where biogas facility development is technically feasible. It also assesses the nature and extent of constraints to the development of biogas electricity generating facilities.
2.1 RESOURCE AVAILABILITY
Kazakhstan is the world’s ninth largest country being some 2.7 million km2 in extent. Figure 1 shows the different oblasts of Kazakhstan. The western regions are dominated by extensive lowlands that include Aral and Caspian Seas, while the centre of the country is characterised by rolling hills with peaks up to 1,565 m. The south eastern and south western parts of the country are bordered by mountain ranges. Approximately 10 per cent of the country is occupied by mountains (Figure 2). Kazakhstan has a number of cities with populations exceeding 50,000 people, and thereby likely to have landfills, indicating that potential biogas resources that could be available for exploitation.
Figure 1 Location Map
ERM 2 KasREFF SER RPER Biogas – June 2014
Figure 2 Topography Map
LFG is produced by the natural decomposition of the organic matter contained in municipal landfills and is composed of 40 to 60 per cent methane on a volumetric basis. Gas production at a landfill is primarily dependent on both the depth and the age of waste in place and the amount of precipitation received by the landfill. In general, LFG recovery may be economically feasible at sites that have more than one million tons of waste in place, more than 10 hectares available for gas recovery, waste depth greater than 12 meters, and at least 60 centimetres of precipitation annually.
With the exception of an existing biogas facility located in the Qarasu/Qostanay Region, however, there is no available information regarding the location and size of existing landfills in Kazakhstan. In general, it can be assumed that those of sufficient size are typically located near large population areas.
Figure 3 presents a map showing the potential areas for developing LFG facilities. This map identifies all areas within 50 km of cities supporting populations exceeding 50,000 people. It is assumed that these cities may have associated municipal solid waste landfills capable of supporting a LFG facility.
The urban population of Kazakhstan (10 million people) produces nearly 2 million tons of municipal solid waste per year, out of which 80 per cent is used on land (as fertilizer). Potential for heat and energy production in decentralised integrated rubbish recycling plants is approximately 100-175 MW depending on separation of raw materials by groups. Landfill gas may
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be the most economic means to access this resource. Overall, economic potential for LFG in Kazakhstan is estimated at one TWh per year.
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Figure 3 Biogas Resource Map
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2.2 RESOURCE POTENTIAL
None of the strategic plans for the development of renewable energy identify specific targets for biogas-sourced energy generation. Based on the information in the KREMS study, biogas is expected to be a minor contributor to RES generation in Kazakhstan due to limited information addressing good candidate landfill sites and other technical factors. As a result, there are not specific drivers for biogas projects in particular in Kazakhstan.
Kazakhstan has very large coal, oil, gas and uranium resources that are all being actively exploited. The country is the third largest producer of crude oil in Central Asia, behind Russia and China and has the third largest reserves outside of the OPEC member countries. One result of the abundance of energy resources has been the lack of a driver for developing renewable energy on the basis of a scarcity of indigenous energy resources. Nevertheless, other drivers needed to be (and were) identified such as the need to reduce greenhouse gas emissions, to strengthen local power supply and to act as an economic stimulus1.
2.3 TRANSMISSION CAPACITY AND CONSTRAINTS
To realise the biogas energy potential of Kazakhstan biogas electricity generating facilities will need to be in general proximity to existing transmission lines and the existing electricity grid will need to have adequate capacity to receive the power generated. Fortunately, since these candidate landfills are located near developed areas, this will not be a significant issue. However, in general, sites that are situated a great distance from load centres or major transmission lines face greater development costs and are generally less favourable than sites with better access to these facilities. Larger projects are able to locate farther away from transmission while smaller projects are located closer to transmission, due to economies of scale of larger projects to absorb higher transmission costs2.
2.3.1 EXISTING CONDITIONS
The grid in Kazakhstan is state-owned and operated by the Kazakhstan Electricity Grid Operating Company (KEGOC). There are also 21 regional energy companies (RECs) that distribute electricity on a regional monopoly basis. Due to the size of Kazakhstan the network is characterised by long distance transmission. The Kazakhstan transmission network dates back to the Soviet era and has a history of underinvestment. However at present it has sufficient capacity and no voltage problems. The majority of the
1 Lessons learnt from the UNDP-GEF project “Kazakhstan — Wind Power Market Development Initiative, UNDP Kazakhstan, 2011. 2 Black & Veatch 2011
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population is connected to the grid, less than 5 per cent of the population, located primarily in rural areas, are without electricity. However, in some areas power cuts or discontinuous supply are not uncommon due to grid capacity issues and a lack of local generation facilities. In addition, in some regions the industrial base has expanded and investment in power infrastructure has failed to keep pace. Figure 4 shows the areas of greatest population density and domestic energy demand in Kazakhstan.
Figure 4 Population Map by Oblast
The electricity grid is separated into three regions west, north and south (Figure 5). It has a general north-south split in generation and demand with approximately 80 per cent of the electricity being produced in the north near coal reserves and 70 per cent being used in the same industrialised region (UNDP/GEF 2011). The transmission system operates at 500 kV and 220 kV and consists of 24,101 km of 35 - 1150 kV overhead transmission lines and 74 power substations with an installed capacity of 34,408 MVA (see Figure 6). A 1,100 km 500 kV electricity transmission system has connected the north and south regions since 2009. Due to demand growth in the southern zone the transmission lines connecting north and south are fully loaded, and in the period of peak demand (winter) they are reported to be occasionally overloaded.
The northern electricity grid contains links to Russia and Central Asia and the southern network contains links to Kyrgyzstan and Uzbekistan. The west of the grid is isolated from the remainder of the national electricity system and has interconnections with Russia.
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From 2011 to 2013 power consumption significantly exceeded energy production, which, taken into account transmission losses has highlighted a deficit of approximately 800 MW. This deficit is currently overcome by importing electricity from neighbouring countries. Demand is projected to reach 145 TWh by 2030 from the current level (CAGR of 2.6 per cent) (Åf- Mercados EMI 2013).
Figure 5 Transmission Regions in Kazakhstan
658 209 700 1173 1180 390 3195 480 850 1720 1609 700 160 95 337 1823
348
90 1862 160
160 320 1020 860 1620 1020
Source: Åf-Mercados EMI (2013)
Developing biogas power projects in the south could help solve the problem of the overload of the north-south transmission lines. The northern zone has an excess of generation, but development would still be an advantage in order to reduce the power imports from neighbouring Russia. The western grid operates separately and currently has a load shortage of about 100 MW, which is also covered by power import from Russia.
Demand in southern Kazakhstan is significant due to the higher population. This is also an opportunity for biogas because the greater population density also means there are more candidate landfills for biogas.
Figure 6 Transmission System Map
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In general, the existing transmission system should not be an impediment to biogas power development, although there are areas where accessing transmission would be prohibitively costly. Most of the biogas power projects would be small to moderate in size (2 MW to 10 MW) and while such projects do impact transmission flows, they are dwarfed by the existing hydro and coal plants, which are mostly greater than 400 MW. The existing transmission lines have been planned for these larger projects, so where lines exist, the addition of one or two small projects is not likely to upset the dynamics of the system unless the system is already at its capacity limit. The limits of the system could only be determined by a full system flow analysis for individual projects, but, in general, capacity availability should not be a problem.
2.3.2 ANTICIPATED DEVELOPMENT
The suitability assessment of the transmission grid for development of biogas assumes that there is no investment in the electricity grid of Kazakhstan. However it should be noted that considerable network development both on- going and planned is being undertaken by Government of the RoK and KEGOC.
Projects planned, or currently being implemented, include:
• Modernization of the national electrical network (NEN) to be completed by 2016. The project comprises reconstruction of the majority of substations and construction of some new transmission lines; • Construction of a 500 kV substation "Alma" ( located in the area of Almaty) with connection to the NEN This will
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eliminate the overloading of existing "Almaty" substation and ensure the reliability of power supply to the Almaty region; and • Reconstruction of a 220 kV overhead line central main substation in Astana.
There are also plans for connecting the western grid to the national grid by 2030.
2.4 EXISTING PROJECTS
At this time, only one known biogas facility, a 375-450 kW plant located in the Qarasu/Qostanay Region, has been operating since August 2011, generating about 2 GWh per year.
2.5 KNOWN PROPOSED PROJECTS
There are no known utility-scale biogas facilities proposed currently in Kazakhstan. However, EBRD recently provided financing to build a biogas plant to provide local power for a wastewater treatment facility in Shymkent which is scheduled to come online in late 2013.
EBRD representatives recently met with a group of biogas developers in Astana to discuss KazREFF program and there was considerable interest in developing biogas projects once the feed-in-tariff system is better defined.
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3.0 AVAILABLE AND PRACTICAL TECHNOLOGIES
This section looks at the type of technology that would be employed for biogas power generation in Kazakhstan. It details the key activities and environmental and physical constraints to be taken into consideration for the construction, operation and decommissioning of a potential site. It also discusses the current status of the biogas facility power supply chain in Kazakhstan.
3.1 COMPONENTS
In general, the characteristics of LFG are:
• Produced with solid waste decomposition in anaerobic conditions • Amount & composition dependent on solid waste characteristics • Increase in organics equals an increase in gas generation • Gas production ends with end of decomposition • Typical Composition o Methane: 50 per cent to 60 per cent o Carbon Dioxide: 40 per cent to 50 per cent o Non Methane Organic Compounds: Trace o Heating Value: 500 Btu/scf = 500 X 1054.54 [J] / 0.028317 [Nm3] = 18.62 [MJ/Nm3] o Moisture Content: Saturated
A LFG project is usually located at or near an existing landfill site, which needs to be partially or completely covered in order to capture the biogas. Due to the productivity declines of landfills following being capped, electricity generation or capacity factor of projects decline over time.
A biogas facility using LFG is typically comprised of a LFG collection system to extract trapped gases in the landfill, a gas cleaning system to remove, at a minimum, sediment and moisture from the gas, and a power generation system to combust the gas to generate electricity and heat. There may be an additional boiler to utilize the waste heat from the combustion for steam or hot water applications. Figure 7 depicts a typical modern LFG facility.
The following sections detail the typical biogas facility components required for these projects and the performance and operation of a typical facility. Project costs and component availability in Kazakhstan are also discussed.
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Figure 7 Typical Modern LFG Facility
Source: Green Power EMC (http://www.greenpoweremc.com)
3.1.1 LFG COLLECTION SYSTEM
A LFG collection system consists of multiple vertical extraction wells, horizontal collectors, headers and condensate system.
Vertical extraction wells are most common approach for recovering LFG and install in existing or operational disposal area, as shown in Figure 8. The depth of waste is preferably more than 10 meters. Vertical extraction wells are installed at an interval of about 2.5 wells per hectare.
Figure 8 Vertical Extraction Well
Source: Global Methane Initiative
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Horizontal Collectors are an alternative approach for LFG recovery and are installed in shallow areas and in existing or operational disposal area, as shown in Figure 9. Horizontal collectors are installed at a spacing of about 30 to 100 m and are used in landfills with elevated leachate levels.
Figure 9 Horizontal Collectors
Source: Global Methane Initiative
Headers are the pathway for LFG from wellheads to blowers and can be laid above-grade or underground as shown in Figure 10. The size of headers depends on flow rate and pressure drop. Pipe configuration is often looped to provide alternative flow paths. Headers are sloped to promote condensate drainage. Unusual drops in vacuum normally occur due to condensate blockages inside headers. The condensate system is depicted in Figure 8. Condensate volume depends on LFG temperature and flow. LFG is assumed to be 100 per cent saturated with water and its temperature is typically 32 to 54 degrees centigrade. LFG cools in the LFG collection piping and the moisture condenses out into the piping. Piping is designed to allow condensate to drain and traps allow for drainage by gravity.
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Figure 10 Condensate System
Source: Global Methane Initiative
A blower is necessary to pull the gas from the collection wells into the collection header and convey the gas to downstream treatment and energy recovery systems, as shown in Figure 11. The size, type, and number of blowers needed depend on the gas flow rate and pressure drop to downstream processes.
Figure 11 Blowers
Source: Global Methane Initiative
3.1.2 GAS CLEANING SYSTEM
LFG is dewatered and filtered with condenser/separator in Gas Cleaning System, as shown in Figure 12. LFG is more likely to contain odorous compounds such as terpenes and carbonyls. Raw gas from industrial waste contains the highest levels of arsenic. The total sulphur content of raw landfill gas is about half hydrogen sulphide and half organic sulphides and thiols. Thus, depending on the types of contaminants found in the LFG and the type of energy conversion technology employed, some gas cleaning technologies may be needed at this stage. No separate odour controls are
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used. Hydrogen sulphide (H2S) is an extremely reactive compound that forms an acidic solution with water in the gas processing equipment. The H2S present in digester gas and LFG is the primary contributory factor to shortened usable life of many of the components in the biogas system. In addition, H2S is a dangerous compound that can be lethal at concentrations above 700 ppm.
Figure 12 Gas Cleaning/Cooling System
Source: Waste Management
When left unchecked, these contaminants can increase the maintenance requirements of the equipment fuelled by the gas, reduce equipment life, and prevent the gas from being suitable for pipeline injection. At a minimum, most primary processing systems include de-watering and filtration to remove moisture and particulates. It is common in new projects to remove water vapour or humidity in the LFG by using gas cooling and compression. LFG used for power generation; however, does not need to be cleaned to pipeline quality methane.
3.1.3 POWER GENERATION SYSTEMS
Power production from LFG facilities is limited by the LFG flow rate from the landfill due to the volume of waste in place and is typically less than 10 MW. Technologies used for power generation include microturbines, internal combustion engines (ICE), and gas turbines. These are typically selected based on the quantities of gas collected, emissions considerations, and project economics. ICE and gas turbines are the most common.
Microturbines
Microturbines are attractive for small landfills that produce 400 to 3,000 cubic metres of LFG per day, making on-site generation available to plants that formerly did not have this option. However, their application is limited due to the higher cost per unit of power capacity. Additional, on-site power generation at landfills is a relatively new technology, with the first commercial units installed in 1998. Microturbines are small gas combustion turbines that operate at very high speeds. They are modular packaged units
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consisting of air bearings and a single moving part that incorporates the turbine shaft and generator, and are typically rated at less than 300 kW. For the KazREFF, projects of 30-250 kW are being considered as 300 kW+ systems have only recently become available to the market. Full systems which include an enclosure for noise reduction and protection from weather are also available. The package includes both the microturbine generator and the cooling/heat recovery equipment. Multiple units can be installed in parallel for higher capacity, as shown in Figure 13.
Figure 13 Multiple Microturbine System
Source: Global Methane Initiative
Benefits of microturbines include minimal noise and relatively low emissions compared to reciprocating ICEs and simple cycle gas turbines.
All microturbines operating on gaseous fuels feature lean premixed combustor technology, which is not generally included in all larger turbines, and therefore they have potential for very low emissions. Microturbines are designed to achieve the objective of low emissions at full load; emissions are often higher when operating at part load. Gas cleaning will be required if any fuel contaminant in the LFG exceed manufacturer specifications. The key characteristics of microturbines are summarized as follows:
• Advantages o Low emissions o Multiple fuel capability o Light weight/small size o Fuel pre-treatment not required o Lower maintenance costs • Disadvantages o Inefficient o High installed capital cost $/kW
Internal Combustion Engine (ICE)
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ICEs are by far the most common generating technology choice. A majority of facilities that generate electricity from LFG use this technology. The reasons for such widespread use are relatively low cost, high efficiency, and load profile matching the gas output of many landfills. Figure 14 shows an example of a reciprocating engine used for LFG energy generation.
Figure 14 ICE System
Source: Global Methane Initiative
The equipment typically consists of a skid-mounted package of a reciprocating engine, generator and a control panel. The popularity of engine generators is attributed to availability from multiple suppliers and familiarity of plant maintenance personnel with the engine, which resembles an automobile engine. The engine is typically a spark-ignited natural gas engine modified and de-rated for use with lower heating value gas. Because of its higher efficiency and lower air emissions, the engine generator of choice is typically a turbocharged lean-burn engine with a synchronous alternator. While most turbocharged engines require compressors to boost gas pressure to a sufficient level, the newer turbocharged lean-burn (low emissions) engines and compress the mixture with the turbocharger. Naturally aspirated engines are rarely specified, and are used only for very small units and where air emissions are not a concern.
Because most engine generators that are fuelled with LFG are employed in continuous duty applications, lower speed units are more often selected for long-term use. The primary emissions from these generators are nitrogen oxides (NOx), sulphur oxides (SOx), volatile organic compounds (VOCs), carbon monoxide (CO), carbon dioxide (CO2) and particulate matter (PM). Emissions of SOx are directly related to the sulphide content in LFG.
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Multiple engine generator units are used to match gas production rates. Engine generators are typically housed in a building where they are readily accessible for servicing. Cooling systems typically include heat exchangers to recover the heat from the jacket cooling water.
A 500 kW system typically requires around 5,000 cubic metres of LFG a day, while a 3 MW system would require around 26,000 cubic metres of LFG a day, depending on the gas quality and the heat rate of the installed equipment. The key characteristics of ICEs are summarized as follows:
• Advantages o Proven and reliable o Efficient o High availability > 92 per cent o Do not require LFG pre-treatment • Disadvantages o High O&M costs o High NOx and CO emissions
Gas Turbine
At larger landfill sites with higher levels of LFG production, around 30,000 cubic metres per day or greater, gas turbine generators can be used. These are available in unit sizes from about one to six MW. Gas turbines are fairly tolerant of some contaminants in LFG. LFG contaminants such as ash, alkalis (sodium and potassium), and sulphur result in alkali sulphate deposits, which impede flow, degrade performance, and cause corrosion in the turbine hot section.
A turbine generator unit consists of a gas combustion turbine connected to a generator through speed reducing gearboxes. The unit is typically packaged on skids (modular mounting hardware), with individual weather protective and sound attenuation enclosures, as shown in Figure 15.
Figure 15 Gas Turbine System
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Source: Global Methane Initiative
Performance declines at higher ambient temperatures. Combustion turbines are available to be configured to combust gas of relatively low energy content such as LFG that is not of pipeline quality. In addition to the turbine generator package, another skid-mounted module may be included with support equipment. The emissions from gas turbines are generally higher than for microturbines but lower than reciprocating ICEs. The key characteristics of gas turbines are summarized as follows:
• Advantages o Corrosion resistant o Low O&M costs o Small physical size o Lower NOx emissions • Disadvantages o Inefficient at partial load o High parasitic loads, due to high gas compression requirements o Require LFG pre-treatment
3.1.4 FLARE PLANTS
Flare plants are installed to control LFG emissions during energy recovery system start-up and downtime and to control gas that exceeds the capacity of the energy conversion equipment. Two types of flare are generally used:
• Enclosed flares (aka ground flares) • Open flares (aka candle-stick flares)
These flares are depicted in Figure 16
Flare plant consists of flare, LFG piping, flame arrestor, flow meter, pilot fuel supply, blowers, moisture separator, auto shutoff valves and control panel.
Figure 16 Flare Plants
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Enclosed Flare Open Flare
Source : Global Methane Initiative
Enclosed flares
Enclosed flare systems are generally more expensive than open flares but hide the flame from view. Other specific characteristics are:
• Flare body usually circular : 9 to 12 metres high • LFG combusted close to ground • Typical operating temperature is 760 to 870 degrees C • Typical destruction of 98 to 99 per cent
Open flares
Open flares are less expensive and smaller than enclosed flares and the flame is visible to the outside.
3.2 GRID CONNECTIVITY
Microturbines, ICE, gas turbines, and CHP are induction generations and result in increased harmonic content when converting power to AC. Increasing harmonic content can create stability concerns for an interconnection, especially within weaker power systems (e.g. radial distribution lines). Induction generators also have sub-transient reactance inherent to the machine, which contributes to high fault current at lower voltages. Different padmount transformer configurations can also increase or decrease the amount of fault current onto the system, so it is important to design the system to keep the zero sequence impedance to a minimum, but still have a ground reference (so no overvoltage scenarios occur). Series neutral reactors or resistors can be added to the neutral connections of the collection system to increase the zero sequence impedance, thus decreasing the fault current.
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Biogas plants have a distinct operational advantage, as they can be used as a base load plant, since the fuel source can be controlled and scheduled. This allows for load following and the reduction of voltage imbalances to the system which cause stability issues like flicker.
Biogas projects are typically only up to 5 MW in size and can be interconnected at distribution voltages, but should not exceed the maximum load of a substation. It is usually too costly to facilitate an interconnection at a higher voltage; however, there are no technical constraints to doing so. At distribution voltages, it is more reliable to interconnect directly to a substation, not tap a line, due to the fault contribution to the system. Therefore, a new line needs to be added to connect the project to the nearest substation. For all biogas projects, regardless of size, load flow, short circuit, and stability studies should be completed to ensure that there are no unforeseen issues due to the specific interconnection point.
3.3 SITE DESIGN AND CONFIGURATION
Several factors should be considered when selecting a site and designing its configuration. Chief site considerations include the size and age of the landfill as it relates to the amount of gas generation. In addition, consideration must also be made for space required to construct facilities for capturing and cleaning the LFG, access to the facilities, proximity to transmission lines, proximity to load centers, and capacity of existing transmission lines. In general, significant amounts of land are not required to support biogas plants. Issues such as visual and odor impacts on local community are not likely a concern in these areas because they already are landfills. There are some other significant issues in Kazakhstan, identified in the SER that should be also considered when siting power facilities:
• Flood prone areas – Construction of biogas facilities in areas prone to flooding could result in the damage of equipment and associated infrastructure. In general, construction in flood prone areas should be avoided. If it is not feasible to avoid flood prone areas, special design modifications to protect equipment should be considered.
• Seismicity, mudflows, and landslides - Construction of biogas facilities in areas of high seismicity or in areas prone to mudflows and landslides could result in the damage to equipment and associated infrastructure. In general, construction in high risk areas for these hazards should be avoided.
• Contaminated lands – Construction of biogas facilities on landfills is obviously going to result in exposure to contamination. Use of existing landfills is clearly a beneficial use of degraded areas; however, special consideration must be made to ensure the health of workers
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that could be exposed to contaminants during construction activities, especially during construction of the LFG collection system.
• Land use - Biogas facilities are only feasible on closed and covered landfills. If these covered landfills are being used for other purposes such as recreation or other land uses, placing a biogas facility may not be a compatible use. When siting a biogas facility, the potential for concurrent land uses should be evaluated.
• Proximity to transmission grid and loading – In general, facilities should be located proximate to existing substations with capacity on the transmission grid. Biogas facilities become to become less economical at increasing distances from substations due to the costs associated with extending distribution or transmission lines to the biogas plant.
3.3.1 CONSTRUCTION
Construction of a biogas power site is site specific as it relates to the type, size and location of the proposed facility. In general however the construction of a typical biogas power site will consist of the following phases:
• Mobilisation, including demarcation of the site boundary if practical, erection of temporary fencing or other suitable measures to protect adjacent sensitive habitats, and creation of a construction compound for off-loading materials and components and to accommodate temporary site offices and welfare facilities; • Creation of suitable access to site boundary; • Construction of access roads, securing site (e.g. fences, gates) • Clearing and grubbing of the site, removal of vegetation • Performing site grading and excavation (shallow), • Construction of underground utilities,(water, drainage) • Construction of gas collection facilities (LFG) o Construction of wells o Installation of gas collection system o Installation of lining/cover • Erection of steel and reinforced concrete structures, o Foundations for gas cleaning equipment, mechanical power generation facilities, AD tanks, o Construction of formwork o Pouring, compacting concrete, curing and striping of formwork o Erection of steel members • Installation of mechanical equipment
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o Gas cleaning equipment (foam/sediment, CO2 removal, H2S removal, dewatering, siloxane removal equipment) o Power generation equipment (turbines, ICE, microturbines),
Additional activities may also be necessary at very remote locations or for very large facilities and could include construction of temporary offices, sanitary facilities, or other supporting works.
3.3.2 COMMISSIONING, OPERATION, AND MAINTENANCE
Once construction is complete, the biogas plant is commissioned. Commissioning involves standard tests for the collection systems, the gas cleaning systems, the turbines, flares, and all electrical infrastructure.
Of the RES technologies considered in the SER, biogas is the most labour intensive when considering long-term monitoring and maintenance. For all systems, regular monitoring and maintenance activities of the gas collection system, the gas cleaning/cooling system, and the blowers will be required. In addition, on-going maintenance will be required for all power generation equipment based on the power generation technology applied.
Microturbines
An overhaul (replacement of the main shaft and inspection/replacement of the combustor) is generally done every 20,000 hours. Microturbines are generally operated with frequent start-up cycles, at least one on-off cycle per day; there is some concern about the effects of this type of operation on component durability.
ICE
Engines require periodic inspections and routine service, generally comprising minor adjustments and replacement of engine oil, filter, coolant, and spark plugs every 500 to 2,000 hours of operation. A minor overhaul (rebuilding cylinder head and turbocharger) is generally performed every 8,000 to 10,000 hours of operation.
If siloxanes are present in the biogas and are not removed during the biogas treatment process, then the period for minor overhauls would likely be reduced to about 5,000 hours of operation. Major maintenance activities such as piston and liner replacement, crankshaft inspection, and bearing/seal replacements are generally performed every 30,000 to 72,000 hours of operation depending on the equipment and gas quality.
Gas Turbines
Daily maintenance requirements generally include visual inspection of filters and general equipment conditions. Routine inspections are required every
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4,000 hours to insure that the turbine is free of excessive vibration due to worn bearings, rotors, and damaged blade tips. An overhaul is generally needed every 25,000 to 50,000 hours depending on service and is typically a complete inspection and rebuild of components to restore the gas turbine to nearly original or current (upgraded) performance standards. Alternatively the owner may elect to replace the turbine equipment in whole with new equipment.
3.3.3 DECOMMISSIONING
The projected operational lifetime of a typical biogas plant is 15 years, depending in the size, age, and amount of decaying material in the landfill. After this period the site would be decommissioned. Prior to decommissioning, a decommissioning method statement, detailing or how the site will be restored is usually prepared and approved by the relevant authorities. In general, the above ground structures would be removed manually. Wells would be filled and sealed in place. Footers for equipment off the landfill would be removed and the voids backfilled with appropriate materials to support the land use at that time. Underground cables and deep concrete foundations are usually left in place as removal is likely to cause more disruption than leaving them in-situ. However, if techniques exist at that time to allow sensitive removal then these will be appraised and considered. Surface vegetation or soil make-up is also to be restored. The electrical control building and internal equipment is removed and reused or recycled where possible.
3.4 DEVELOPMENT COSTS
The typical capital costs, optimal capacity, annual O&M costs of the three biogas power systems are presented in Table 1. Extreme examples are not included.
Table 1 Capital and O&M Cost of LFG Electricity Generation Projects
Power system Optimal Typical Capital Typical Annual Project Size Costs (US$/kW O&M Costs (capacity) capacity) (US$/kW capacity)
Microturbine 1 MW 5,500 380
ICE 1 MW 2,300 210
Gas Turbine 3 MW 1,400 130
Source: USEPA
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3.5 SUPPLY CHAIN IN KAZAKHSTAN
At present there is little utility-scale biogas development in Kazakhstan; however, ICE and gas turbines are all potentially available in the country as they are standard equipment. Microturbine generators are relatively new and the number of manufacturers is limited. Manufacture of microturbines is not yet thought to be done in Kazakhstan; however, it is microturbines are available from neighboring Russia, China as well as in Europe and North America. Collection system components are is also fairly standard equipment which is readily available in Kazakhstan. Key components for electronics include inverters and transformers, and cabling. These are all readily available within Kazakhstan. The technology and ability of the workforce to construct is also readily available in Kazakhstan.
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4.0 ENVIRONMENTAL AND SOCIAL CONSTRAINTS
A detailed assessment of environmental and social constraints related to biogas (and the other three RES evaluated) is provided in the SER Report. Environmental and social factors that could significantly impact the effectiveness, economic feasibility, and therefore, the siting of these facilities are addressed in Section 3.3 of this RPER. In addition, there are areas of high environmental and/or social sensitivity, the proximity of which should also be strongly considered. These environmental and/or social high sensitivity areas are discussed in detail in the SER and are summarized in this section.
• Protected/Designated Lands - Potential solar sites in or near other areas afforded legal protection, including National Parks, preserved lands would be discouraged given the relative lack of this habitat and the abundance of un-forested areas throughout the country. When siting facilities within a protected/designated area is unavoidable, additional impact mitigation measures will be required.
• Surface Water Quality - Due to clearing, grading, trenching and foundation construction for the biogas plant components, there is a potential for soil erosion during construction. Due to this potential, if biogas facilities are located within 1km of a surface water feature (e.g., intermittent or perennial stream, lakes, or ponds), a more detailed assessment of environmental effects and additional impact mitigation measures will be required.
• Cultural heritage - Special care should be taken to avoid siting biogas facilities at or within the viewshed of known and tentative UNESCO World Heritage sites due to the global uniqueness of these areas. Special care should also be taken to avoid placing SSH facilities on or near locally-registered cultural heritage sites. Given the low actual elevation of potential biogas facilities, the viewshed for these facilities is somewhat limited. Therefore, a viewshed buffer of 5 km should be placed around known and tentative UNESCO and national heritage features for biogas facility development. When siting facilities within a viewshed buffer is unavoidable, a more detailed assessment of environmental effects and additional impact mitigation measures will be required. Cultural heritage features themselves would be considered exclusion zones.
Cumulative effects - There are no recognized spatial adverse cumulative effects associated with biogas facilities; therefore, a spatial cumulative constraint assessment was not conducted.
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5.0 KAZREFF PROJECT APPRAISAL - ENVIRONMENTAL AND SOCIAL PERFORMANCE REQUIREMENTS
Biogas projects funded under KazREFF will be subject to the following environmental and social requirements, as stipulated by EBRD:
• The EBRD’s Environmental and Social Policy (2008) and its associated Performance Requirements. • Applicable requirements of Kazakhstan, including but not limited to those related with environmental impact assessments, environmental permitting, labour, public consultation, resettlement and compensation, occupational health and safety, community health and safety, and emergency response. • Relevant European Union Directives and requirements • International best practices, including those promulgated by other international financial institutions, the International Labour Organisation, and others.
5.1 EBRD REQUIREMENTS
Projects would need to adhere to the EBRD Environmental and Social Policy and its associated Performance Requirements (PR), which cover the following areas:
• PR 1: Environmental and Social Appraisal and Management • PR 2: Labour and Working Conditions • PR 3: Pollution Prevention and Abatement • PR 4: Community Health & Safety and Security • PR 5: Land Acquisition, Involuntary Resettlement and Economic Displacement • PR 6: Biodiversity Conservation and Sustainable Resource Management • PR 7: Indigenous Peoples • PR 8: Cultural Heritage • PR 9: Financial Intermediaries (FI) • PR 10: Information Disclosure and Stakeholder Engagement
Depending upon the scale of KazREFF project, EBRD would require a series of environmental documents to be produced in order to gain EBRD funding. Projects are screened at an early stage and placed into one of the four following categories, depending on the level and type of environmental and social due diligence that is required:
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• Category A projects are those with potentially significant and diverse environmental and social impacts, requiring detailed impact assessments • Category B projects are those with environmental and social impacts that are site-specific and can be addressed through readily available management and mitigation techniques • Category C projects have minimal environmental or social impacts • FI projects are where the EBRD is investing in a Financial Intermediary, such as a bank or equity fund.
This categorization reflects: (i) reflect the level of potential environmental and social effects and issues associated with the proposed project; and (ii) determine the nature and level of environmental and social investigations, information disclosure and stakeholder engagement required for each project, taking into account the nature, location, sensitivity and scale of the project, and the nature and magnitude of its possible environmental and social effect and issues.
Due to the relatively small scale of the potential KazREFF projects, most would likely fall under Category B, as the potential adverse environmental and/or social effects that they may give rise to are typically site-specific, and/or readily identified and addressed through mitigation measures. However, the siting of biogas power facilities within or near sensitive/protected areas or in situations where impacts could be more severe may result in these being classified as Category A projects. This determination is made by EBRD and KazREFF in the initial project phases.
5.1.1 CATEGORY A
If a project is considered to be a Category A project, it is usual to expect that it would require the development and disclosure of an Environmental and Social Impact Assessment Package including:
• An ESIA; • A Non-Technical Summary (NTS); • An Environmental and Social Action Plan (ESAP); • A Stakeholder Engagement Plan (SEP); • A Land Acquisition Plan (if land acquisition is required); • A Resettlement Action Plan (if population displacement is required).
Disclosure of these documents generally allows for a 120 day public consultation period, after which the documents are finalized, published, and financing may be secured. In general, the timeframe for completing the environmental and social review process for a Category A project typically takes 9 to 12 months to complete.
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5.1.2 CATEGORY B
If categorized as a Category B project, there are less detailed documentation requirements due to the lesser potential for significant environmental and social impact. EBRD typically requires the development and disclosure of:
• A Project Summary Document; • A Project Fact Sheet or Non-Technical Summary (NTS);
For Category B projects, EBRD also typically reviews, but does not require disclosure of:
• An Environmental and Social Action Plan (ESAP); • A Stakeholder Engagement Plan (SEP); • An Environmental and Social Due Diligence (ESDD) document that demonstrates compliance with PR1
Disclosure of these required documents generally allows for a 30 day public consultation period, after which the documents are finalized, published, and financing may be secured. In general, the timeframe for completing the environmental and social review process for a Category B project typically takes 3 to 6 months to complete.
5.2 KAZAKHSTAN REQUIREMENTS
Specific requirements for EIA procedures for all categories of economic activity are established by the document “Instruction on Environmental Impact Assessment at the Development of Prior Planned, Planned, Prior Project, and Project Documentation”. This guide contains:
• A list of activities which require implementation of the EIA procedure in full;
• A list of activities for which the full EIA procedure is proposed to the State Environmental Expertize (SEE) on the basis of preliminary expertise or by applying a set of criteria determined in normative documents; and
• A list of activities with insignificant environmental impact, for which only the preparation of an "Environmental impact statement" is sufficient for submission to the SEE.
Projects in Kazakhstan are classified by the Sanitary and Epidemiological Services (SES) of MOH according to five danger levels with one being the highest as defined by norms and standards in relation to human health and safety. The sensitivities of projects are measured by the SES Danger/Sanitary Categories. The categories are:
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• Danger/Sanitary Categories 1 & 2 projects have levels of severity/danger that trigger a full EIA. • Danger/Sanitary Category 3 projects are considered to have lower levels of severity/danger and as such a lesser assessment is undertaken, although still referred to as an Environmental Assessment. • Danger/Sanitary Category 4 & 5 projects are considered to present considerably lower risks of severity/danger and generally do not warrant an assessment beyond the initial screening.
The SES Danger/Sanitary Categories relate to four categories of RoK EIA (Оценка воздействия на окружающую среду - OVOS). The EIA/OVOS Categories are:
• Category I - Sanitary Class/Danger Categories 1 and 2 plus investigations and extractions of minerals, except for common minerals. Risks are high and approval by MOEP is required. A Category I EIA/OVOS is categorically required obligatory for large scale including road construction project with four lanes or more. • Category II - Sanitary Class/Danger Category 3 plus extractions of ubiquitous minerals, forestry activities and special uses of water. Risks are ranked as Medium High and approval is required from TEPO(s). • Category III - Sanitary Class/Danger Category 4 Risks are ranked as Low and approval is required from TEPO(s). • Category IV - Sanitary Class/Danger Category 5 plus projects involving animals, except recreational fishing and hunting. Risks are ranked as Low and approval is required from local administrations.
SEE reviews are conducted at end of each stage in the process and before proceeding to the next stage. Reviews are conducted first at the Oblast level and then by MEWR and other agencies as appropriate to the nature of the Project and the level of EIA Categorization. Under Kazakhstan regulations, the EIA process has three stages:
• Preliminary EIA (Environmental Impact Assessment - Pre-OVOS)
• Preparation of the EIA (OVOS). EIAs are obligatory for large scale projects.
• Preparation of an "Environmental Protection Section". The Environmental Protection Section is prepared in the detailed design stage in the event that mitigation measures defined in the EIA (OVOS) are required.
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At each stage of the EIA process, the developer is required to prepare an "Environmental Impact Statement", which is a compulsory annex to each EIA document. The "Environmental Impact Statement" must be presented in the package of documents for submission to the SEE for consideration. Reviews are conducted at the end of each stage, first at the Oblast level and the by MEWR and other agencies as appropriate for the project and EIA Category.
Public hearings or public consultations are required at all stages of EIA. The detailed requirements for public participation are reflected in the Environmental Code, Articles 57 and 60-67 and the “Rules of access to environmental information relate dot EIA procedure and decision-making process on intended economic and other activity”. Minutes from these hearings are filed as part of the EIA documentation.
The process provides for a preliminary review period of two weeks and a final review period of up to 90 days after which the EIA authors are required to defend the EIA at a consultation session with all stakeholders in attendance (usually not the general public). Once complete, the EIA is revised; a final document is prepared; and a formal OVOS certificate is issued to the Proponent, but usually only after another 30-day waiting period, allowing for any additional comments. This certificate allows the project to proceed with other approvals that may be required. Based on this information, it may take up to a year to complete the EIA process in Kazakhstan.
Based on additional guidance provided in the RoK EIA regulations, it is likely that biogas projects (and in fact, all RES projects) would be considered Category II and would require Category II EIA/OVOS documentation. However, the siting of biogas facilities within or near sensitive/protected areas may result in these being classified as Category I projects. This determination is made by MoE at the preliminary EIA stage.
The OVOS process was evaluated against the EBRD Environmental and Performance Standards to identify gaps areas that may be not be satisfied by the OVOS process. This gap analysis is provided in Appendix A.
5.3 KAZREFF APPRAISAL PROCESS
All projects considered for financing through KazREFF will under a detailed appraisal process in order to:
• Determine each project’s ability to meet EBRD environmental and social performance requirements; • Determine each project’s ability to meet EBRD RoK EIA regulations • Ensure that projects are technically feasible
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• Identify significant issues and constraints that may negatively impact KazREFF’s ability to finance each project from an environmental and social perspective • Provide simplified guidance and resources to project proponents (and their environmental consultants) in order to more easily comply with EBRD and Kazakh requirements
The appraisal process will be developed and implemented by the Project Implementation Unit.
5.3.1 INITIAL SCREENING
The appraisal process includes an initial screening of the project proposal against the criteria presented in this RPER, the SER report, and consideration of key environmental and social issues. This initial screening is conducted after the project proponent completes the Environmental and Social Issues Checklist – Biogas provided in Appendix B. This checklist includes identification of key environmental and social issues related to biogas (and cumulative impacts) and is reviewed by KazREFF’s environmental and social review team. Based on the review of the checklist, the project’s EBRD category will be determined and specific documentation requirements will be communicated to the project proponent.
Once the EBRD requirements have been identified, KazREFF environmental and social review team will provide support to project proponents to comply with the Kazakh EIA regulations. In general, information gathered through the initial screening process can be useful in developing the preliminary EIS documentation required for the initial stage of the Kazakhstan EIA.
5.3.2 DOCUMENTATION REVIEW AND APPROVAL/FEEDBACK
Based on the initial screening and categorisation, the project proponent will then be expected to complete the preparation of required documentation.
Templates for the typical documents expected to support biogas projects (under Category B) are provided in Appendix C and include templates for the NTS (Appendix C.1), the SEP (Appendix C.2), and the ESAP (Appendix C.3). If a project is determined to be a Category A project, an ESIA would be required. Due to the very specialized nature of an ESIA, an ESIA template has not been provided. However, information in the SER report will be extremely useful to identify information necessary for the preparation of these documents. The information in the SER identifying the environmental baseline, the anticipated effects, and mitigation strategies should also be very useful to inform the Kazakh EIA.
All projects will be expected to comply with EBRD PR1 through 10. Important information for assessing the significant environmental and social
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effects and avoidance, minimization, and/or mitigation of those effects is provided in the SER.
The required documents will be submitted to, and reviewed by, KazREFF environmental and social review team. The KazREFF environmental and social review team will work with the developer to ensure submitted information is sufficient to demonstrate compliance with EBRD’s PRs.
In addition, KazREFF environmental and social review team will review the progress of the Kazakh EIA and can, if requested, provide technical input and guidance on the process and content. KazREFF environmental and social review team will request updates from the project proponent on the progress of the project through the Kazakh EIA stages until final approval is received.
Once the required environmental and social documentation for KazREFF review has been found to be in compliance with the EBRD and the final Kazakh EIA is approved, KazREFF environmental and social review team will reflect that in the Project Screening Report.
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6.0 APPENDICES
A - Gaps between EBRD PR for ESIA and Kazakhstan EIA Requirements
B – Environmental and Social Issues Checklist - Biogas
C – Environmental and Social Templates
C.1 – Non-Technical Summary (NTS)
C.2 – Stakeholder Engagement Plan (SEP)
C.3 – Environmental and Social Action Plan (ESAP) - Biogas
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Kazakhstan Renewable Energy Financing Facility (KazREFF) - Strategic Environmental Review
Appendix A – Gaps between EBRD PR for ESIA and Kazakhstan EIA requirements
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Appendix A: Gaps between EBRD PR for ESIA and Kazakhstan EIA requirements
EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement PR 1: Environmental and All EBRD-financed projects undergo The EIA is obligatory for all sectors of None Social Appraisal and environmental and social appraisal economic and other activities that may Management directly or indirectly impact the environment and public health.
The EIA process is performed on the strength of commitment, integration (magnitude), alternative, adequacy, preservation, compatibility, flexibility, and public participation.
Categorization and EIA magnitude Economic activities subjected to the EIA None procedure are categorized as I, II, III, and IV, The EBRD categorizes proposed projects as “A”, of which categories I and II cause major “B”, and “C”. impacts on the environment. A project is classified as Category A when it could result in potentially significant and diverse According to the requirements, there is the adverse future environmental and/or social list of projects (economic activities) for impacts and issues which, at the time of which the EIA is recommended to be categorization, cannot readily be identified or performed in full (for example, oil industry assessed and which require a formalized and and crude oil refineries, thermal power participatory assessment process carried out by stations, chemical installations, pipelines independent third party specialists in accordance for transport of gas, oil or chemicals, etc.) with the PRs (Appendix 1 to the EBRD ESP). and the list of projects (economic activities) for which the requirements to carry out a A proposed project is classified as Category B comprehensive assessment are imposed by when the potential adverse environmental and / State review authorities on the basis of a or social impacts that it may give rise to are preliminary review or by applying
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement typically site-specific, and/or readily identified thresholds defined by regulations and addressed through mitigation measures. (agriculture, forestry, mining industry, These impacts could be from past, current or power industry, wind farms, etc.). future activities. Due diligence requirements may vary depending on the project and will be agreed with the EBRD on a case-by-case basis, in accordance with PR 1.
A proposed project is classified as Category C when it is likely to result in minimal or no adverse environmental or social impacts and therefore requires no further environmental and social appraisal beyond categorization.
Based on the KazREFF SER, it is anticipated that most funded projects will fall within Categories B or C. EIA stages The EIA process comprises the following None stages: 1) preliminary EIA (stage 1); 2) EIA that is performed for a complete and comprehensive analysis of potential effects of the project or further economic and other activities, substantiation of alternatives, and development of an environmental management plan (programme) (stage 2); 3) “Environmental Protection” section that constitutes part of the design documentation and contains engineering solutions aimed at prevention of adverse
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement impacts on the environment (stage 3).
The EIA format, completeness of studies, scope of used documents, levels and degree of detail of environmental scientific & design surveys depend on the design stage as well as on magnitude and intensity of impacts caused by projected economic and other activities on human health and environment.
EIA is an integral part of pre-design and design documents. Preliminary environmental and social assessment Through Pre-EIA activities, the potential None (Pre EIA) trends of changes in environmental and socioeconomic components as well as Through appraisal activities, the client will impacts on both the society and consider in an integrated manner the potential environment are identified. environmental and social issues and impacts associated with the proposed project. The No need in computations of the pollution appraisal process will be based on recent level for certain environmental information, including an accurate description components (air, soils, water, subsoil and delineation of the client’s business or the resources). project, and social and environmental baseline data at an appropriate level of detail. The Pre-EIA documents are disclosed for public appraisal should also identify applicable laws and by a project initiator. regulations of the jurisdictions in which the project operates that pertain to environmental Pre-design appraisal documents (business- and social matters, including those laws plans, feasibility studies) and main pre- implementing host country obligations under design documents such as “Investment international law (for example, commitments substantiation” and Pre-EIA documents are
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement related to land use planning and protected area submitted to the State Environmental management). Review (SER).
A positive Conclusion issued by the SER in favour of the project initiator, serves as a guide for making decisions to initiate designing of specific facilities and structures in accordance with the most rational option selected in the course of Pre-EIA development. Environmental and Environmental and social impacts and issues will The EIA process comprises an assessment None social appraisal (EIA) be appraised in the context of the project’s area of impacts on: mechanism of influence. Environmental and social issues and impacts will also be analysed for the relevant • atmospheric air stages of the project cycle. These may include • water resources; preconstruction, construction, operations, and • subsoil resources; decommissioning or closure and reinstatement. • industrial and domestic waste; Where relevant, the appraisal will also consider • physical impacts; the role and capacity of third parties, such as • lands and soils; local and national governments, contractors and • flora; suppliers, to the extent that they may influence • fauna; the project, recognizing that the client’s ability to • socioeconomic environment; address these risks and impacts will depend on its • environmental risks from planned control and influence over the third party actions. activities in the region The appraisal will also consider potential trans-
boundary and global issues, such as impacts from A project initiator discloses EIA documents effluents and emissions, increased use or for the public. contamination of international waterways, greenhouse gas emissions, climate change mitigation and adaptation issues, and impacts on endangered species and habitats.
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement PR 2: Labour and At a minimum, the client’s human resources Labor relationship in the Republic of Labor relationship issues Working Conditions policies, procedures and standards shall be Kazakhstan is regulated by the Labor Code are not reflected in typical designed to: establish and maintain a sound and it does not constitute part of the EIA Kazakh EIA documents. This worker-management relationship; promote the process. would be a gap if not fair treatment, non-discrimination and equal addressed in a project- opportunity of workers; promote compliance Issues related to labor and working specific ESMP. with any collective agreements to which the conditions and safety are considered in the client is a party, national labour and employment “Environmental risk assessment in laws, and the fundamental principles and key connection with planned activities in the regulatory standards embodied in the ILO region” section. conventions that are central to this relationship; protect and promote the health of workers, especially by promoting safe and healthy working conditions.
PR 3: Pollution The client will avoid the release of pollutants or, Measures aimed at prevention and None Prevention and when avoidance is not feasible, minimize or abatement of environmental pollution are Abatement control their release. This applies to the release specified in EIA documents (“Atmospheric of pollutants due to routine, non-routine or Air”, “Water Resources”, and “Waste” accidental circumstances with the potential for sections). These measures provides for local, regional, or trans-boundary impacts. In introduction of low-waste and waste-free addition, the client should examine and technologies and special measures on i) incorporate in its operations energy efficiency prevention (abatement) of air emissions; ii) measures and measures to conserve water and adverse impact mitigation; iii) air quality other resources, consistent with the principles of monitoring; iv) amounts and chemical cleaner production. The client will avoid or composition of wastewater discharges; v) minimize the generation of hazardous and non- substantiation of the introduction of water hazardous waste materials and reduce its circulating systems and wastewater reuse harmfulness as far as practicable. systems, recycling of sludge from wastewater treatment facilities; vi) groundwater protection against pollution
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement and depletion; and vii) recommendations related to recycling, treatment and disposal of all types of waste and waste recycling/waste disposal technologies. PR 4: Community Health Requirements relating to: infrastructure and EIA documents comprise a section titled None & Safety and Security equipment safety; hazardous materials safety; “Assessment of environmental risks for the community exposure to disease; emergency environment and community health in preparedness and response; and security connection with planned economic personnel requirements. These requirements are activities”. This section contains i) focused on avoidance or prevention of risks and recommendations on prevention of and impacts rather than their minimization and response to emergencies; ii) consideration mitigation. of emergency probability; sources and kinds of emergencies and frequency of their occurrence as well as forecasts of their impacts on the environment and community. PR 5: Land Acquisition, The following requirements are considered in the Issues related to land acquisition and Kazakhstan EIA regulations Involuntary course of project design: carrying out of involuntary resettlement are regulated by do not contain Resettlement and consultations; grievance mechanism; the Land Code of the Republic of requirements related to Economic Displacement resettlement planning and implementation; Kazakhstan. But the Pre-EIA documents to land acquisition, Resettlement Action Plan; livelihood restoration be submitted to the SER for reviewing involuntary resettlement framework; compensation and benefits for should contain a copy of document for the and economic displaced persons; displacement; physical right of land use in the subject territory. displacement. displacement; economic displacement; and loss of public amenities. PR 6: Biodiversity Through the environmental and social appraisal The EIA process also includes an None Conservation and process, the client will identify and characterize assessment of impacts on vegetation in the Sustainable Resource the potential impacts on biodiversity likely to be project influence area (the presence of Management caused by the project. The extent of due diligence medicinal herbs; rare, endemic and Red should be sufficient to fully characterize the risks Data Book-listed plat species), green space and impacts, consistent with a precautionary condition; forecasted changes of the
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement approach and reflecting the concerns of relevant vegetation cover in the project stakeholders. The client will seek to avoid implementation area and impacts of these adverse impacts on biodiversity. changes on life and health of local communities; recommendations for conservation of vegetation communities, improvement of their condition, flora conservation and revegetation; recommendation for vegetation monitoring, etc.
Furthermore, the EIA documents contain a baseline assessment of aquatic and terrestrial fauna (the presence of rare, endangered and Red Data Book-listed fauna species); measure to conserve and reproduce the integrity of natural communities and species diversity of aquatic and terrestrial fauna; food potential improvement; a wildlife monitoring programme. In addition, the presence of natural territories and landmarks under special protection in the territory of potential construction operations is considered. PR 7: Indigenous In projects where Indigenous Peoples are likely to The Kazakhstan legislation does not specify The Kazakhstan EIA Peoples be affected, the client is required to carry out an requirements related to Indigenous procedure does not assessment of impacts on Indigenous Peoples. Peoples consider issues related to Depending upon the outcome of this, the client is Indigenous People. expected to first avoid adverse effects and where However, this is not this is not feasible, to prepare and Indigenous typically an issue in Peoples’ Development Plan so as to minimize Kazakhstan, where there is
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement and/or mitigate any potential adverse impacts. no indigenous population. The client is also expected to implement a specific grievance mechanism and determine appropriate modalities for compensation and benefit-sharing.
PR 8: Cultural Heritage At an early stage of the environmental and social EIA documents contain a section devoted None appraisal, the client should identify if any cultural to territories, landmarks and sites under heritage is likely to be adversely affected by the special protection. Cultural heritage is project, and assess the likelihood of any chance regulated by the RK Law “On Protection finds. The client will ensure that provisions for and Use of Historical and Cultural Heritage managing chance finds, defined as physical Sites and Objects” dated July 2, 1992. cultural heritage encountered unexpectedly Companies, institutions, organizations, during project implementation, are in place. Such educational institutions, public provisions shall include notification of relevant organizations and individuals will support competent bodies of found objects or sites; an authorized relevant body in alerting project personnel to the possibility of implementation of measures aimed at chance finds being discovered; and fencing-off protection, preservation and use of the area of finds to avoid any further disturbance historical and cultural heritage sites. or destruction.
PR 9: Financial Not applicable Not applicable Not applicable Intermediaries (FI)
PR 10: Information “Information Disclosure and Stakeholder Public opinion is given proper weight in the Kazakhstan requirements Disclosure and Engagement” specifies requirements relating to process of EIA development. Public opinion do not specify a detailed Stakeholder stakeholder identification, development of a consideration format depends on the procedure for stakeholders Engagement Stakeholder Engagement Plan, information significance of planned economic activities identification and disclosure, meaningful consultations, and and the extent of project influence on the engagement or the grievance mechanism. environment and community health; much grievance mechanism depends on stakeholders. The procedure procedure.
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EBRD Performance Issue Related Kazakhstan Gap Requirement/Issue OVOS Requirement and dates of public consultations is regulated by environmental supervisory authorities.
Public opinion is mainly considered through public consultations. The results of public consultations are recorded in the form of a report where all key issues and disagreements between stakeholders and a client are recorded. Stakeholders’ comments and proposals are considered in design documents. Written proposals and comments from stakeholders (as an independent form of public opinion consideration) are collected for individual less significant projects of economic activities. At subsequent stages of project design, the procedure of public opinion consideration can be carried out through collection of written proposals and comments in respect of EIA findings for a certain industrial operation.
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Kazakhstan Renewable Energy Financing Facility (KazREFF) - Strategic Environmental Review
Appendix B – Environmental and Social Issues Checklist – Biogas
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Please read this before completing the questionnaire: 1. This questionnaire is the first stage in the Bank’s environmental and social due diligence process. The more comprehensive the answers given, the less need will there be for the Bank to request further information. Please, therefore, try to answer the questions as fully and openly as possible. 2. The questionnaire makes reference to both “the Project”, the business activity for which EBRD funding is sought, and “the Company”, which is the corporate entity that is ultimately responsible for the Project. The Project may affect the whole Company or may only relate to one element within the Company. The Bank needs to understand both issues related to the Project being financed by the Bank and the impacts and issues associated with the Company as a whole. 3. There are a number of questions where further information is requested if a positive response is given. Additional information can be provided either in the questionnaire’s boxes or in separate documents.
PROJECT NAME:
TYPE: BIOGAS USING LFG (Y/N) BIOGAS USING ANIMAL MANURE (Y/N) PROJECT LOCATION: Map Provided? Yes / No Company Name: Company Address: Country: Town/Location: Business Sector/Activities: Person completing questionnaire:
Name: Title: Date: Telephone: Mobile: E-mail:
Company authorised representative (e.g. Environmental Manager): I certify that, to the best of my knowledge and belief, the information contained in this questionnaire accurately represents current or future operations.
Signature:
Title: Date:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE COMPANY PROFILE
A) Ownership: • Private ownership %: ______• Public ownership %: ______B) Year of foundation: ______
C) Sector of operation and main products: ______
D) Describe the main activities of the Company and its holdings including any biogas or other renewable energy projects (include a description of the corporate structures and controls that are used to manage/oversee individual projects, including this one):
PROJECT DESCRIPTION
A) Technical information: Start of construction (planned date) Start of operation (planned date) Installed capacity (MW) Annual net generation (MWh) Biogas fuel sources to be used? Method of biogas generation (LFG – microturbines, internal combustion engines or single-cycle gas turbines; Animal manure – anaerobic digester coupled with internal combustion engine, power only or combined heat and power (CHP))? Are data on biogas fuel availability accessible (yes/no) Measuring period for biogas fuel availability (start date / end date) Distance to interconnection grid (km): Voltage level of interconnection grid (kV): Voltage level of overhead line to interconnection point (kV):
B) Status of project development:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE
yes no The project is still in its conceptual phase (we have only a project idea)? Technical design has started? Technical design is completed? Quotations / proposals from equipment suppliers have been received?
C) Summary of information on Environmental Impact Assessment: Is Environmental Impact Assessment (EIA) required? (yes/no) Has EIA been completed? (yes/no) If EIA is available, has it observed any adverse environmental impacts? If yes, describe them and any associated mitigation measures in Section 1b. If EIA is required but not available, when will it be completed?
D) Siting, design and key environmental and social considerations:
1. Describe the Project and provide a map showing its components, including all biogas facility infrastructure, roads, transmission lines, grid connections and other required facilities and the approximate layout. 2. How were environmental and social issues incorporated into the siting and design optimisation process (see also questions under PR1 and PR6 below)? 2.1 What studies have been completed into air quality and emissions control? 2.2 What studies have been completed regarding water use (including water-use minimisation and re-use)? 2.3 What logistics, traffic and transport studies have been completed (including consideration of transport of animal manure, if applicable)? 2.4 What studies have been completed relating to potential impacts on local communities and other land-users? 3. Biogas resource issues – please describe: 3.1 Understanding of the operational regime for each facility and for any operations in tandem (if applicable); and, 3.2 Biogas resource measurements and sourcing information. 4. What meteorological data and monitoring information is available?
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE 5. How have climate-change related variables been accommodated? PR1 - Environmental and Social Appraisal & Management Environmental and Social Appraisal 1.a Has the Company made an assessment of the Yes: No: environmental and social impacts of its operations? If yes, please provide a summary of that assessment: 1.b Has an Environmental and Social Impact Assessment Yes: No: (ESIA) been completed for this Project? If yes, please summarise the conclusions of the ESIA, including required/recommended mitigation, and send a copy/summary: 1.c Have relevant discussions been held with Yes: No: environmental regulators on the ESIA for the Project? If yes, please summarise: 1.d Is there an Environmental and Social Action Plan (ESAP) Yes: No: for the Project construction, operation and If yes, please summarise: decommissioning? 1.e Have any site investigations been performed to check Yes: No: the suitability of the site and characterise If yes, please provide a list of the studies: environmental and social baseline conditions, such as soil, water quality and groundwater testing, slope stability, survey for flora and fauna including bat, bird and water species, or the situation of nearby communities? 1.f What are the relevant Company’s Corporate Social Responsibility Standards? 1.g What processes are in place to manage environmental issues (such as the presence of sensitive species)? 1.h Will / does the Project involve significant excavations, Yes: No: demolitions, movement of earth, flooding or other If yes, please provide details: changes in the physical environment? ERM 49 KasREFF SER RPER Biogas – June 2014
ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE 1.i What soil erosion/sedimentation mitigation/control procedures will be in place for the construction and operational phases of the Project? Environmental Management 1.j Who is responsible for environmental management at Name/title: the Company? Phone/mobile: Email: Who is responsible for social management / community Name/title: relations at the Company? Phone/mobile: Email: Who is, or will be, responsible for environmental Name/title: management for the Project? Will that person be on- Phone/mobile: site during construction and operation? Email: Who is, or will be, responsible for social management / Name/title: community relations for the Project? Will that person Phone/mobile: be on-site during construction and operation? Email: 1.k Does the Company have an Environmental and Social Yes: No: Management System (ESMS)? If yes, is the ESMS compliant with any internationally Yes: No: recognised systems such as ISO 14,001, OHSAS 18,001, SA 8000 or EMAS? 1.l Does the Company periodically prepare a summary Yes: No: report on environmental performance (or If yes, please provide a copy of the most recent report(s) sustainability) for shareholders, stakeholders, or others? How often? 1.m Does the Company routinely provide environmental Yes: No: ERM 50 KasREFF SER RPER Biogas – June 2014
ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE training for Company personnel? If yes, please describe the training provided: Will the Company train workers for the Project? For Yes: No: construction and/or operation? If yes, which workers will be trained? What kind of training? Contractor management 1.n Will the Company use contractors during the Yes No construction and/or operational phases of the Project? If yes, please provide details: 1.o Are prospective contractors required to submit Yes No environmental, health and safety, and/or labour information with bid documents (that is, do solicitations for proposals require such information)? 1.p Is a contractor’s past EHS performance considered Yes No during evaluation of bids? If yes, please describe how (including whether it is used as a pass/fail factor or as part of the overall score: 1.q Does the Company monitor performance of its Yes: No: contractors regarding environmental, health and safety, If yes, how often? How does the Company deal with poor and labour/human resources? performance? 1.r How will the contractors be managed to ensure they have processes in place to anticipate and respond to emerging risks and opportunities, associated with the Project? PR 2 – Labour and Working Conditions 2.a Who is responsible for Human Resources (HR) Name/title management at the Company? Phone/mobile: Email: 2.b Does the Company have written HR policies setting out Yes: No: its approach to managing its workforce?
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE 2.c Are all workers provided with written information Yes: No: about their terms and conditions of employment? 2.d Has the Company ever been found in violation of any Yes: No: country’s labour and/or social security laws? If yes, please describe the circumstances Have these resulted in any penalties, fines, major Yes: No: recommendations or corrective action plans? If yes, please describe: 2.e Are employees free to form, or join, a workers’ Yes: No: organisation (e.g. a trade union) of their choosing? What percentage of the workforce belongs to such an organisation? 2.f Is the Company covered by a collective bargaining Yes: No: agreement? 2.g How does the Company interact with workers’ organisations and provide information to them? 2.h Does the Company have a grievance mechanism which Yes: No: allows employees to raise workplace concerns? If yes, please describe: How many grievances were received from employees Number: during the previous year? Please summarise the issues raised in grievances and how the company has addressed them: 2.i Have there been any strikes or other collective disputes Yes: No: related to labour and working conditions at the If yes, please describe the nature of the dispute and how it was Company in the past three years? resolved: Have there been any court cases related to labour Yes: No: issues? If yes, please summarise contested issues and outcome: Have there been any other significant labour issues Yes: No: raised by the media or by non-governmental
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE organisations? If yes, please describe: 2.j Are there policies or terms and conditions covering Yes: No: employment of young persons under age 18? If yes, please describe What is the minimum legal working age? How does the Company verify the age of employees? Does the Company apply any restrictions to the tasks Yes: No: that can be done by younger workers? If yes, please describe: 2.k Are employees free to leave the premises when they Yes: No: are not required to work or with appropriate due cause? Does the Company retain any identity documentation Yes: No: from the employees? If yes, please explain which documents and why: Are employees free to resign from their jobs? Yes: No: If yes, please describe the notice and other procedural requirements? 2.l Does the Company have a policy for setting wages? Yes: No: How do the Company’s wage levels compare to comparable employers in your sector? 2.m Does the Company anticipate any redundancies or Yes: No: retrenchment in the next three years? If yes, please describe and explain the reason(s): 2.n Does the Company have policies or terms and Yes: No: conditions covering non-discrimination and equal If yes, please describe: opportunities in employment? 2.o Are any criteria other than compliance with job Yes: No: requirements (e.g., gender, ethnicity, nationality, If yes, please specify those criteria: religion, political or trade union affiliation) applied for recruitment / promotion / access to training / benefits?
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE 2.p How many workers does the Company employ? Please provide numbers for men and women separately. How many are...: Direct: Seasonal: Full-time: Part-time: How many sub-contractors does the Company employ and what is the role of these sub-contractors? 2.q Will there be employment opportunities for local Yes: No: stakeholders? If yes, please describe these opportunities: How many non-skilled workers will be employed for the Construction: Operation: Project during construction and then operation? How many non-skilled workers are expected to be Near-by areas: Within the Country: recruited from nearby areas? From the country? What proportion of managers and skilled workers are Near-by areas: Within the Country: expected to be recruited from nearby areas? From the country? Occupational Health and Safety 2.r Who is responsible for health & safety management at Name/title: the Company and/or Project? Phone/mobile: Email: Is there an emergency response plan for dealing with Yes: No: natural disasters, such as earthquakes? (This is also relevant to PR-4 Community Health, Safety and If yes, please describe and provide a copy: Security) Is there sufficient information to confirm that Yes: No: construction will not result in land slips or other
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE environmentally damaging incidents? (This is also If yes, please describe: relevant to PR-4 Community Health, Safety and Security) 2.s Does the Company have a Health & Safety Yes: No: Management System? Is the system compliant with an international health & Yes: No: safety standard such as OHSAS18001? 2.t Is the Company compliant with national requirements Yes: No: for health & safety? 2.u Is there a current Health & Safety Action Plan for the Yes: No: Company? If yes, please provide a copy of the latest update. Do project-specific health and safety plans (typically) go Yes: No: beyond the requirements of host countries? If yes, please summarise (typical) differences: 2.v Does the Company keep any statistics on Yes: No: • Fatalities; If yes, please provide health and safety statistics for the last three • Lost time accidents; years of operations. • Lost workdays resulting from incidents; and/or • Total staff hours worked? 2.w Have any Company operations been cited for violations Yes: No: of national or other health and safety standards and If yes, please summarise the circumstances and the outcome procedures in the last 3 years? 2.x Is there (or will there be) a Health and Safety Plan for Yes: No: this Project? If yes, please describe what it covers (or will cover)?
Will workers be required to undergo health and safety Yes: No: training? If yes, please indicate how often and what type(s) of training 2.y How does the Company ensure that workers employed
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE by its contractors, sub-contractors or labour agents are protected by the same labour and health and safety standards as those that apply to the Company’s own employees? PR 3 – Pollution Prevention and Abatement Environmental Compliance 3.a In the last 3 years, has the Company been cited for any Yes: No: violations of environmental permits or regulations? If yes, please describe circumstances and outcomes: 3.b Has the Company applied for, and/or received, the Yes: No: required environmental permits and licences to Please list required permits and licenses, and their status (issued, construct the Project? To operate? applied for, etc.) Construction: Operation: 3.c Which agencies and authorities will be primarily responsible for overseeing environmental performance of the Project? Air Emissions 3.d Does the Company produce air emissions? Yes: No: If yes, please describe the main sources, types and quantities of air emissions produced by the company: 3.e Please describe any measures taken to reduce emissions and prevent air pollution. 3.f Please provide monitoring data for total air emissions. Water Use 3.g What will be the main sources of water for the Project during construction and operation? How much water will the Company use at each phase of the Project?
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE Have permits been issued? Yes: No: Will any water require treatment prior to use? Yes: No: If yes, please describe use, amount to be treated and treatment method: Wastewater Discharges 3.h What are the sources, types and quantities of effluent discharges that will produced by the Company during the Project? 3.i How much wastewater will be generated during Construction: Operation: construction and operation? How will wastewater be managed and discharged? Is any wastewater treatment required prior to Yes: No: discharge? If yes, please describe: Solid Waste Management 3.j What are the types and quantities of solid wastes produced by the Company? How are these wastes disposed of? 3.k Are any hazardous wastes produced and how are these Yes: No: stored and disposed of? If yes, please describe: 3.l Does the Company implement any measures to reduce Yes: No: / reuse / recycle any solid wastes at its facilities? If yes, please summarise: Are contractors required to implement these Yes: No: measures?
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE Hazardous Material Management 3.m What hazardous materials will used by the Company in the Project (such as flammable, explosive, reactive, radioactive and toxic substances) and in what quantities? What measures and procedures are in place for the handling and storage of such materials? 3.n Has the Company suffered any environmental incidents Yes: No: or accidents (such as spills, tank ruptures, explosions, If yes, please describe: etc.) during the previous three years at any of its facilities? 3.o Does the Company prepare Environmental Incident Yes: No: Reports, or similar, when an environmental accident or If yes, please describe the reporting system and indicate the relevant incident occurs? authorities you report to: 3.p Will fuel or other hazardous materials be stored and/or Yes No used for this Project? If yes, what materials will be used/stored? How much of each? How will they be used/stored? PR 4 - Community Health, Safety & Security 4.a How far are the nearest villages/towns/cities from the Please describe and include a map: Project site? How far from the Project site are the nearest occupied
houses and/or workplaces? 4.b Will the Company’s activities pose any material risks to, Yes: No: or have any significant impacts on, the health and If yes, please describe: safety of local communities or people? Has a public health assessment been undertaken? Yes: No:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE If yes, please describe:
4.c Has the Company developed measures to prevent Yes: No: and/or mitigate any such impacts? If yes, please describe:
4.d Has the Company consulted with locally affected Yes: No: community(ies) and stakeholders to discuss the Project If yes, please describe: and measures to be taken to reduce impacts, in order to understand any concerns and address issues associated with potential public health effects? How have impacts of the project on affected communities (if any) been identified and addressed? 4.e Will there be security guards to control entry to the Yes: No: Project site during construction and/or operation? If yes, will they be armed? How will they be trained? Will security be outsourced to a separate company? Yes: No: If yes, what criteria did the Company use to select the security contractor?
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE PR 5 - Land Acquisition, Involuntary Resettlement and Economic Displacement 5.a Does the Company have a person in charge of land Yes: No: acquisition and/or expropriation? Name: Title: Phone/mobile: Email: 5.b Have any structures or land already been acquired by Yes: No: the Company in connection to the Project? If yes, please provide details. 5.c How much land will need to be permanently acquired by the Company for the Project (including power- generating infrastructure, control centre, roads, transmission lines and other related facilities)? How much land will have to be temporarily occupied (e.g. for storage, access to construction sites, accommodation of workers)? 5.d Has the Company already identified owners and users Yes: No: of affected land and structures (for example, from Land If yes, please provide details: Books, Cadastre or through a field survey)? Have any negotiations with land/structure Yes: No: owners/users or any expropriation procedure been If yes, please provide details: initiated (including request for public interest)? What is the land currently being used for? Will land that is not needed by the Company continue Yes: No: to be used by others (such as land between buildings/generating infrastructure)?
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE 5.e Will any people need to be relocated to new houses, Yes: No: new farm land and/or lose access to other valuable If yes, please provide details. assets? 5.f Will the Company acquire land and/or pay for Yes: No: temporarily using it? If yes, how much land will be acquired and/or require payments for use? How will the amount to be paid for purchase or usage be determined? How will the Company proceed if agreement cannot be reached with owner(s)? Is there a written land acquisition plan for the Project? Yes: No: If yes, please provide details: 5.g Will any businesses / economic activities, both formal Yes: No: and informal, in the area be affected by construction If yes, please provide details: activities (e.g. tourism activities)? Does the Company have plans to compensate affected Yes: No: people for loss of business or economic activity? If yes, please provide details: 5.h Is there any resettlement required for this project? Yes No If yes, please provide details: If so, is there a Resettlement Action Plan? Yes No If yes, please provide details: PR 6 – Biodiversity Conservation & Sustainable Management of Living Resources 6.a How far is the Project from the nearest protected or Please provide a list with distances and provide a map showing the designated areas, or areas important for local Project and nearest protected/important areas. biodiversity, including Natura 2000 sites, national parks, Ramsar Sites (wetlands), etc.? 6.b Does the site provide habitat for any protected or Yes: No:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE sensitive species of plants or animals? If yes, please provide details: 6.c What habitat mapping or species surveys have been completed? 6.d Which habitat areas/species would be impacted by ancillary works, transmission lines, construction access roads, other construction activities etc? 6.e Is there any other baseline environmental data on Yes: No: wildlife of the area not already covered above or in the If yes, please provide further details: Project Description section? 6.f Is there any further information on potential impacts to Yes: No: species or habitats that have not been covered above If yes, please provide further details: or in the Project Description section? PR 7 – Indigenous Peoples Are there any indigenous peoples likely to be impacted by the project? Yes: No: If yes, please provide details: PR 8 – Cultural Heritage 8.a Is the Project located in or near a cultural heritage site Yes: No: recognised by the country in which the project is If yes, please provide details: located, or where artefacts have been found in the past (including UNESCO World Heritage Sites and those on the tentative list, Registered cultural heritage sites, zones and settlements)? 8.b Is the Project located on or near to a place of worship, Yes: No: cemetery or other place of importance and value to a If yes, please provide details: community? 8.c Has the Company consulted with the national, regional, Yes: No:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE and/or local agency(ies) responsible for protecting If yes, please provide details: cultural resources? 8.d Has the risk to cultural heritage sites and areas of Yes: No: archaeological interest been assessed and managed? If yes, please describe: PR 9 – Financial Intermediaries Not relevant for KazREFF PR 10 – Information Disclosure & Stakeholder Engagement 10.a Who will be affected by the Project, including the workforce and local communities? How and to what extent? 10.b Does the Company have a person in charge of Yes: No: communications with local communities? Name: Title: Phone/mobile: Email: 10.c Has the Company established a mechanism through Yes: No: which members of the public can raise concerns or If yes, please provide details: grievances concerning the Company’s environmental and social practices? 10.d Has the Company established a regular means for Yes: No: communicating with affected community(ies)/people If yes, please describe: (e.g. newsletter, email, helpline, open day)? 10.e Is the Company aware of any issues, concerns or Yes: No: positive feedback brought to the Company’s attention If yes, please describe: by members of the community, non-governmental organisations (NGOs), or the media? 10.f Has the company undertaken any consultations with Yes: No:
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ENVIRONMENTAL AND SOCIAL DUE DILIGENCE QUESTIONNAIRE stakeholders – including national, regional, and local If yes, please describe: authorities, NGOs, businesses, citizens? 10.g Does the Company have plans to implement Yes: No: community development activities (e.g. is there a If yes, please describe: corporate social responsibility plan)?
(end of questionnaire)
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Kazakhstan Renewable Energy Financing Facility (KazREFF) - Strategic Environmental Review
Appendix C – Environmental and Social Templates
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Kazakhstan Renewable Energy Financing Facility (KazREFF)
TEMPLATE - PROJECT NAME
DATE
Non Technical Summary of Environmental and Social Considerations
Prepared for:
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CONTENTS
1 Introduction 68 2 Description of the Proposed Development 69 3 Environmental, Health, Safety and Social Review 69
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7.0 Introduction
Add summary of company proposing development – i.e private / public owned, company structure and operations Add summary of project proposals – i.e type of power plant, size and location Add summary of environmental studies undertaken to date – i.e an ESIA?, specialist surveys? (Company name XXX) has approached the European Bank for Reconstruction and Development (EBRD) for financing. The project is thus subject to EBRD’s 2008 Environmental and Social Policy and has been determined as a Category XXX project (add details of whether it is a category A or B project). EBRD has conducted an environmental and social due diligence assessment of the project and supported the development of applicable environmental and social documentation, namely a Stakeholder Engagement Plan, an Environmental and Social Action Plan, and this Non Technical Summary (also add reference to other relevant documents if appropriate eg an ESIA, specialist studies). This document provides in a non-technical manner an overview of the proposed development plans. The document also provides a summary of potential environmental and social impacts and other environmental and social issues relevant to the proposed activities. Appropriate measures to mitigate key adverse environmental and social effects that may arise during project construction and operation are also provided. This NTS document and other materials will be placed in the locations shown below on (add disclosure date XXX). During a 60 / 120 (delete as appropriate) -day period beginning on (add disclosure date XXX), anyone can provide comments and recommendations on the environmental, social and other aspects of the project. Comments can be made at public consultations to be held at the locations shown below, and may be submitted to the address below. Environmental and social documents will be available for review during normal business hours at the following location: XXXX (add details)
Meetings at which anyone can make comments will be held as follows: XXXX (add details) The dates and times of public meetings will be announced at least three weeks before the meeting(s), and advertised in local mass media. For further information on this project, or to provide comments on the project or the environmental and social documentation, please contact: Comments may be submitted to: Name Contact information Address: Complete all contact Phone:
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details Email:
8.0 Description of the Proposed Development
Add project description – • prospective annual electricity generation, • equipment to be installed, • permitting requirements, • Location, size, (including location map(s)
9.0 Environmental, Health, Safety and Social Review
Key Environmental and Social Elements Several documents collectively make up the environmental and social documentation for the project. The Non Technical Summary is described above, while the other documents are described here. Environmental and Social Action Plan (ESAP) As part of the environmental and social due diligence evaluation, a wide review was conducted of corporate environmental, health, safety and social management arrangements. From the overall review, an Environmental and Social Action Plan (ESAP) has been developed which lists key actions to ensure areas for improvement can be implemented and include mitigation measures discussed above. This ESAP is being disclosed for public comment; key mitigation measures are described below. Stakeholder Engagement Plan (SEP) (Insert company name XXX) has prepared a Stakeholder Engagement Plan (SEP) for the Project. The SEP will guide (insert company name XXX) in communicating with people, institutions and any other stakeholders who may be affected by or interested in the implementation of Project. (Insert company name XXX) has assigned a social liaison officer, who will be responsible for keeping open dialogue with stakeholders groups and local public. This SEP is being disclosed for public comment. At any time before and during construction and operation, any stakeholder will have a chance to raise any concerns, provide comments and feedback about the Project. All such comments and grievances from people will be accepted, processed and answered by (insert company name XXX) in a timely manner.
Key Features Key environmental features and sensitive locations from a social perspective in relation to the site include:
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XXX – add details
Potential Impacts and Mitigation Measures The EBRD’s environmental and social diligence evaluation determined that the project could have negative impacts on environmental resources and on people if they are not controlled carefully. Therefore, the EBRD will require (insert company name XXX) to implement many actions (“mitigation measures”) to prevent, reduce, or mitigate impacts on people and the environment. A summary of key impacts and mitigation measures have been identified, and they are summarised in Appendix A.
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Overview of Potential Impacts and Mitigation
Resource Potential Impact / Issue of Concern Mitigation
For example … Climate and Air Quality
Geology, Geohazards and Soils
Surface Water & Groundwater
Water Supply
Ecosystems and Flora & Fauna Noise
Waste Management
Cultural Heritage Tourism
Visual Landscape
Socio-economics
Traffic Management
Occupational Health & Safety
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Public Health & Safety Others…
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Contents
Kazakhstan Renewable Energy Financing Facility (KazREFF)
TEMPLATE - PROJECT NAME
DATE
Stakeholder Engagement Plan
Prepared for:
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CONTENTS 1 Introduction 75 1.1 Background 75 1.2 Description of the Proposed Development 75 1.3 Overview of XXX (add company name) 75 1.4 Objectives of the Stakeholder Engagement Plan (SEP) 75 1.5 Structure of SEP 76 2 Regulatory Context 77 2.1 Kazakhstan requirements for stakeholder engagement/ public consultation 77 2.2 EBRD requirements for stakeholder engagement and public consultation 77 3 Summary of previous stakeholder engagement 79 3.1 EBRD previous stakeholder engagement and consultations in Kazakhstan 79 3.2 KazREFF SER Consultations 79 3.3 Public disclosure and consultations during project 80 3.4 Other consultations during the project 80 4 Stakeholder Identification and Communication Methods 81 5 Disclosure of Information and Stakeholder Engagement Programme 83 5.1 Disclosure of general information 83 5.2 Disclosure of information relevant to Project 83 5.3 Stakeholder engagement programme 83 6 Timetable 84 7 Public Grievance Mechanism 85 8 Roles and Responsibilities 86
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10.0 Introduction
10.1 BACKGROUND Add summary of company proposing development – i.e private / public owned, company structure and operations Add summary of project proposals – i.e type of power plant, size and location Add summary of environmental studies undertaken to date – i.e an ESIA?, specialist surveys? (Company name XXX) has approached the European Bank for Reconstruction and Development (EBRD) for financing. The project is thus subject to EBRD’s 2008 Environmental and Social Policy and has been determined as a Category XXX project (add details of whether it is a category A or B project). EBRD has conducted an environmental and social due diligence assessment of the project and supported the development of applicable environmental and social documentation, namely a Stakeholder Engagement Plan, an Environmental and Social Action Plan, and a Non Technical Summary of the environmental and social considerations (also add reference to other relevant documents if appropriate eg an ESIA, specialist studies). To meet EBRD requirements for stakeholder engagement and public consultation and disclosure (EBRD Performance Requirement PR10), a stakeholder and public engagement process with development of a Stakeholder Engagement Plan (SEP) will also be directly applied to this project. These details are laid out in this document, the SEP. EBRD considers stakeholder engagement as an essential part of good business practices and corporate citizenship, and a way of improving the quality of projects. In particular, effective community engagement is central to the successful management of risks and impacts on communities affected by projects, as well as to achieving enhanced community benefits.
10.2 DESCRIPTION OF THE PROPOSED DEVELOPMENT Add project description – • prospective annual electricity generation, • equipment to be installed, • permitting requirements, • Location, size, (including location map(s)
10.3 OVERVIEW OF XXX (ADD COMPANY NAME) Add summary of company proposing development – i.e private / public owned, company structure and operations
10.4 OBJECTIVES OF THE STAKEHOLDER ENGAGEMENT PLAN (SEP) This SEP has been developed with the aim of explaining how company name XXX will communicate with people and institutions who may be affected by or interested in the Project, at various stages of project preparation and implementation. The plan includes a ERM 75 KasREFF SER RPER Biogas – June 2014
grievance mechanism for stakeholders to raise any concerns related to the project for company name XXX attention. 10.5 STRUCTURE OF SEP The remainder of this SEP is organised as follows: • Chapter 2 briefly describes applicable regulations and requirements for stakeholder engagement and public consultations. • Chapter 3 summarises previous and on-going stakeholder engagement and public consultation activities. • Chapter 4 identifies stakeholders and describes communication methods with them. • Chapter 5 describes stakeholder engagement program and disclosure of information. • Chapter 6 describes roles and responsibilities for handling the consultation and information disclosure process. • Chapter 7 describes a grievance mechanism by which feedback, comments, concerns and complaints may be communicated to company name XXX and how these grievances and comments will be handled.
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11.0 Regulatory Context
11.1 KAZAKHSTAN REQUIREMENTS FOR STAKEHOLDER ENGAGEMENT/ PUBLIC CONSULTATION Kazakhstan is a signatory for Aarhus Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters (UNECE)3. The convention is designed to improve the way ordinary people engage with government and decision-makers on environmental matters. Consequently, citizens of Kazakhstan are entitled to be informed about all environment related issues pertaining to the project and it is the responsibility of public authorities, local authorities, or government departments to reveal such environmental information. National legislation also foresees broad public involvement in decision-making process. Further details to be added….
11.2 EBRD REQUIREMENTS FOR STAKEHOLDER ENGAGEMENT AND PUBLIC CONSULTATION Since EBRD may be involved in funding the Project, the Project must meet the best international practices and requirements for stakeholder engagement and public consultations as specified in the EBRD Environmental and Social Policy of 2008.
The principles, requirements, methodological and procedural aspects of stakeholder engagement for EBRD Category A and B projects are described in detail in PR10 “Information Disclosure and Stakeholder Engagement 4 . PR10 outlines a systematic approach to stakeholder engagement that will help clients build and maintain over time a constructive relationship with their stakeholders, including the locally affected communities.
As required, the following important stages shall be implemented for the Project engagement and consultation process: - Identification of project stakeholder groups. Identification of stakeholders, including members of the public who could be affected by the Project construction and operation. - Stakeholder engagement process and information disclosure. During this step, company name XXX is to ensure that identified stakeholders are appropriately engaged on environmental and social issues that could potentially affect them through a process of information disclosure and meaningful consultation. - Meaningful consultation. The consultation process will be based on the disclosure of information relevant to the Project activities and operations. The consultation process
3 UNECE Aarhus Convention on access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters
4 EBRD Environmental and Social Policy 2008 (http://www.ebrd.com/downloads/about/sustainability/2008policy.pdf)
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will be undertaken in a manner that is inclusive and culturally appropriate for all stakeholders, including effected communities and vulnerable groups. - Grievance mechanism. Maintaining a grievance process by which the general public and other stakeholders can raise concerns, and which will be handled in a prompt and consistent manner.
The stakeholder engagement process and SEP preparation was also guided by the IFC Good Practice Handbook5 that defines the best practice approach to stakeholder engagement.
5 http://www.ifc.org/ifcext/enviro.nsf/AttachmentsByTitle/p_StakeholderEngagement_Full/$FILE/IFC_StakeholderEngagement.pdf
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12.0 Summary of previous stakeholder engagement
12.1 EBRD PREVIOUS STAKEHOLDER ENGAGEMENT AND CONSULTATIONS IN KAZAKHSTAN The European Bank for Reconstruction and Development (”EBRD” or the “Bank”) has made RES a key priority for investment in its countries of operation and has reviewed a number of early stage RES projects in Kazakhstan. The Bank has gained initial approval from the Clean Technology Fund (CTF) for concessional finance of up to $110 million to help create markets for power from RES in Kazakhstan. The Bank is now in the process of establishing dedicated financing facilities to enable it to provide finance to both larger and smaller RES projects in Kazakhstan (up to €10 million per project). This will be supported by funds from the CTF. The Bank has been active since 2008 in assisting the Government of Kazakhstan (the “Government”) through a technical cooperation programme in supporting the preparation of legislation to support RES development which has involved extensive stakeholder dialogue with the Ministry of Industry and New Technologies (MINT). In 2012, during the early stages of renewable energy programme development for Kazakhstan, the EBRD launched the assignment Kazakhstan Renewable Energy Development Framework and Regulatory Support (TCS number 34068). This assignment was to provide technical assistance in renewable energy regulatory support and institution building to the Kazakhstan Ministry of Industry and New Technologies (MINT; subsequently renamed the Ministry of Environment and Water Resources, or MEWR). Included in that assignment was a Renewable Energy Market Study, which included extensive stakeholder dialogue to establish the appropriate structure for renewable energy regulation in Kazakhstan. A number of key stakeholders and interested parties were identified at that stage, including local authorities and regulators at different levels, potential donor agencies, scientific and research institutes, and private developers. All targeted groups were contacted, and a series of individual meetings and workshops were organized and undertaken.
12.2 KAZREFF SER CONSULTATIONS
The Kazakhstan Renewable Energy Financing (KazREFF) undertook a large stakeholder engagement exercise alongside the Strategic Environmental Review (SER) of the potential effects of implementing renewable energy projects funded under KazREFF. The SER consultations were undertaken in three stages:
• Stage 1 (between April and July 2013). In Stage 1, the information about the KazREFF SER and SER Scoping Report was disclosed to with 30 representatives of various stakeholder groups; 13 of whom were individually interviewed. Representative stakholders included representatives of local authorities, manufacturers, developers and consultants involved in the development and implementation of renewable energy projects in Kazakhstan. The initial list of stakeholders resulting from stakeholder identification and analysis was expanded and amended where necessary.
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• Stage 2 (between July 2013 and September 2013). In Stage 2, the SER Environmental Scoping Report was published on the KazREFF SER website at http://www.kazreff- ser.com. EBRD conducted half-day scoping meetings on 16 and 18 July 2013 in Astana and Almaty, respectively, to encourage broad stakeholder participation in the development of the SER. Outreach activities, including mailing, emailing and telephoning contacts, were undertaken with 86 organizations representing a variety of stakeholders in the Astana and Almaty areas including government, developers, non- governmental organizations (NGOs), consultants, and advisory bodies. Eighteen organizations representing a variety of stakeholders participated in the meetings. • Stage 3 (June 2014 through October 2014). In Stage 3, the Draft SER report was disclosed and initiated formal 120-day public consultation period, where all stakeholders had an opportunity to provide comment on the disclosed Draft SER report. During this timeframe, two workshops were held to both inform and educate stakeholders about the SER and the KazREFF.
12.3 PUBLIC DISCLOSURE AND CONSULTATIONS DURING PROJECT Add details of any public disclosure / consultation undertaken to date as part of this project.
12.4 OTHER CONSULTATIONS DURING THE PROJECT Add details of any other consultation that may have occurred as part of the project, for example with authorities to obtain necessary permits.
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13.0 Stakeholder Identification and Communication Methods
In order to define a communication process in line with EBRD PR10, company name XXX has identified several stakeholder groups that may be interested and/or affected by the Project development and implementation. The stakeholders identified include: • Internal stakeholders, such as company name XXX employees and construction contractors’ workers
• External stakeholders, such as o governmental authorities, o non-governmental organisations and o local residents.
Others who wish to be included in the list can contact company name XXX and be put on the mailing list for information on reporting, meetings, or other consultation opportunities.
Table 1 describes the stakeholder engagement programme and communication process by providing contact details of certain stakeholders, and identifying communication methods and specific media that will be used to notify stakeholders of information. Any suggestions for improvement of proposed communication methods or media are welcomed and can be submitted via the contact information at the end of this document.
Table 1. Stakeholder engagement programme for the Project Stakeholder group Description Communication method / Proposed Media channel and contact information (where applicable) Internal Stakeholders Employees XXX For example… Company website?? - Internal newsletters www.kazreff.com ?? - Emails - Grievance procedure - Bulletin boards - Union meetings - Inserts with payslips Temporary Construction XXX For example… XXX Workers, subcontractors - Internal newsletters - Emails - Grievance procedure - Bulletin boards - Union meetings - Inserts with payslips
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Table 1. Stakeholder engagement programme for the Project Stakeholder group Description Communication method / Proposed Media channel and contact information (where applicable) Unions: XXX For example… XXX • XXX - Official correspondence. - Union newsletter. - Information on request to union representatives. External Stakeholders Population in XXX XXX XXX Newspapers: XXX Radio: XXX Company website?? www.kazreff.com ?? Local authorities and public enterprises: For example… XXX For example… XXX Water Company - Communication via official letters and meetings Public Health Institute XXX For example… XXX - Ongoing working linkages with the Institute County / city XXX For example… XXX administration - Ongoing working linkages with the authorities - Official correspondence - Meetings State level authorities: - Ukrainian Water XXX For example… XXX Authority - Official correspondence - Ministries - Meetings • XXX
Other relevant external stakeholders For example… XXX - Meetings (invitation to public Company website?? Local Tourist Board consultation meetings) www.kazreff.com ?? Others..
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14.0 Disclosure of Information and Stakeholder Engagement Programme
14.1 DISCLOSURE OF GENERAL INFORMATION Provide details of general information disclosure – website, company reports etc.
14.2 DISCLOSURE OF INFORMATION RELEVANT TO PROJECT To meet the environmental and social requirements and performance standards of EBRD and EU, company name XXX will develop, disclose to the public and then implement an Environmental and Social Action Plan (ESAP), which will identify mitigation measures to minimise, reduce, eliminate or control potential adverse impacts on environment and people.
The final version of ESAP will be published on company name XXX official website (or KazREFF website?) and printed copies will be available on request from XXX (contact information available in the table above).
The local population will receive timely information (through the local media listed in the table above and announcements regarding grievance management in relation to construction activities, safety measures in the vicinity of the construction site, traffic management, employment opportunities and opportunities for service provision (catering, accommodation of workers, laundry services, etc.) and any other information identified through the development of the ESAP.
Annual project progress reports, including environmental and social impacts, health and safety performance and implementation of the external grievance mechanism will also be disclosed on company name XXX official website (or KazREFF website?) and will be available on request XXX (contact information available in the table above).
14.3 STAKEHOLDER ENGAGEMENT PROGRAMME Consultations and disclosure of information for local public
Public consultations will be held after a draft Environmental and Social Action Plan has been developed. Add details of proposed consultation. For example - who will manage it, when will it take place, and with whom?
Other stakeholder engagement activities Add details of proposed consultation. For example - who will manage it, when will it take place, and with whom?
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15.0 Timetable
Stakeholder(s) and engagement Issues / documents Possible dates activity(ies) During the development of ESAP and NTS XXX XXX XXX XXX XXX XXX When the ESAP/SEP/NTS are completed All stakeholders Publish ESAP, SEP and NTS (in XXX English and Ukrainian) and inform all stakeholders through local media. Include responses to comments, suggestions which were not incorporated in the documents. Before construction Contractors / temporary workers Agree construction related XXX grievance management, inform all stakeholders; Code of conduct for temporary workers, trainings Local population Information on safety measures XXX Traffic Management Plan Employment opportunities and opportunities for service provision During construction and operation Public consultation meetings if Implementation of the ESAP, new XXX necessary (determined in cooperation impacts, revision of documents, with EBRD) implementation of SEP, processing and responding to grievances
After construction
Ongoing meetings and cooperation, throughout the life of the project, with the following external stakeholders: • XXX
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16.0 Public Grievance Mechanism
The objective of a grievance procedure is to ensure that all comments and complaints from any project stakeholder, including local/regional authorities, residents of nearby residential areas, company name XXX employees, company name XXX contractors’ staff and other interested parties, are considered and addressed in an appropriate and timely manner. All grievances will be acknowledged and responded to within a reasonable timeframe. company name XXX will accept all comments and complaints associated with the project. A sample of a Comments and Complaints Form is shown in Appendix A. The comments and complaints will be summarised and listed in a Complaints/Comments Log Book, containing the name/group of commenter/complainant, date the comment was received, brief description of issues, information on proposed corrective actions to be implemented (if appropriate) and the date of response sent to the commenter/complainant. Any person or organisation may send comments and/or complaints in person or via post, email, or facsimile using the contact information specified in Section 8.0 below.
All comments and complaints will be responded to either verbally or in writing, in accordance with preferred method of communication specified by the complainant in the Comments and Complaints Form. Comments will be reviewed and taken into account in the project preparation; however they may not receive an individual response unless requested.
All grievances will be registered and acknowledged within 5 days and responded to within 20 working days. Company name XXX will keep a grievance log and report on grievance management, as part of annual project progress reports, available at the company name XXX website and on request at add contact details.
Comments and concerns regarding the project can be submitted in writing in the following ways: • electronic form on company name XXX website or KazREFF website?: add details • email: XXX • by post or hand delivered to (see example grievance form attached): – XXX • by phone: – XXX
Provide contact person and specify contact details Individuals who submit their comments or grievances have the right to request that their name be kept confidential.
During construction, grievances in relation to construction activities will be managed by company name XXX and construction contractor. Local residents will be informed about the
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contractors contact information before construction begins, through the local media (listed in the table above) and announcements in public places. A separate grievance mechanism is available for workers, both employees of company name XXX and the contractors. 17.0 Roles and Responsibilities
Provide contact person and specify contact details will have the overall responsibility for handling the consultation and information disclosure process, including organisation of consultation process, communication with identified stakeholder groups, collecting and processing comments/complaints, and responding to any such comments and complaints. Depending on the nature of a comment/complaint, some comments or complaints will be provided to the appropriate person in the company for a response.
Name of the person and title Affiliation XXX Company: XXX Postal Address: XXX Telephone: XXX E-mail address: XXX Hotline: XXX
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APPENDIX A Comments and Complaints Sample Form FORM FOR COMMENTS, COMPLAINTS AND REPORTS OF INDIVIDUALS Reference No: Full Name
Contact Information By Post: Please provide mailing address: and Preferred method ______of communication ______
Please mark how you wish to be contacted By Telephone: ______(mail, telephone, e-
mail). By E-mail ______
Description of Incident or Grievance: What happened? Where did it happen? Who did it happen to? What is the result of the problem? Source and duration of the problem?
Date of Incident/Grievance
One time incident/grievance (date ______) Happened more than once (how many times? _____) On-going (currently experiencing problem)
What would you like to see happen to resolve the problem?
Signature: ______Date: ______Please return this form to: XXXXXXXX Address ______: Tel.: ______
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or E-mail: ___
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CONTENTS
Kazakhstan Renewable Energy Financing Facility (KazREFF)
PROJECT NAME
Environmental and Social Action Plan - Biogas
DATE
Prepared for:
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CONTENTS
1 PROJECT OVERVIEW 91 1.1 Project approach 91 1.2 Scope of this ESAP 91 1.3 ESAP for biogas projects 93
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PROJECT OVERVIEW
– PROJECT APPROACH To encourage businesses to pursue sustainable energy projects, the European Bank for Reconstruction and Development (EBRD) has launched the Kazakhstan Renewable Energy Financing Facility (KazREFF). KazREFF aims to ‘provide development support and debt finance to renewable energy projects which meet required commercial, technical and environmental standards’. KazREFF not only provides tailor-made financing, but also provides technical assistance for businesses and local authorities based on information gathered and analysed by stakeholders to promote projects that are often challenging to finance and implement. KazREFF is part of the EBRD’s Sustainable Energy Initiative (SEI) which addresses the challenges of climate change and energy efficiency. Since the launch of the SEI in 2006, the EBRD has remained at the forefront in helping countries from Central Europe to Central Asia secure sustainable energy supplies and finance the efficient use of energy that will cut demand and imports, reduce pollution, and mitigate the effects of climate change. In co-operation with the national authorities in Kazakhstan, EBRD commissioned a Strategic Environmental Review (SER) for the KazREFF programme, focusing on renewable energy technologies in optimal areas of Kazakhstan. The renewable energy technologies specifically reviewed in the SER include small hydropower, on-shore wind, solar photovoltaic, and biogas technologies. Four Environmental and Social Action Plan (ESAP) templates have been produced – one for each of the renewable energy technologies – to provide a framework for further development at the inception of a given renewable energy project that is seeking funding from KazREFF. The SER and associated Environmental and Social Action Plans comply with the EBRD’s Environmental and Social Policy and its Public Information Policy.
– SCOPE OF THIS ESAP This ESAP is for the biogas renewable energy scenario; It includes a series of actions to be undertaken in order to manage – that is, to plan and implement specific measures to avoid, reduce, control, or otherwise mitigate – potential environmental, occupational health and safety, and social impacts during construction and operation 6 . This ESAP should be considered as a template which will be reviewed and amended by project proponents who wish to develop specific biogas projects (utilising either landfill gas (LFG) or animal manure) funded by KazREFF in the future; and will be part of the contract between the project developer and EBRD. It is envisaged that EBRD will require performance of the required actions to be regularly reported and that it will periodically monitor implementation of the ESAP. The table below presents the actions required by this ESAP, organised by the EBRD’s Performance Requirements. These actions should be added to as befits the individual project
6 For purposes of this ESAP, “construction” includes all actions in the field to construct the project, including support and ancillary facilities such as construction camps, roads, temporary or permanent buildings, staging areas, etc. “Operation” means routine and non-routine operation and maintenance and support facilities, and “project performance” includes the entire period of construction and operation.
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situation; If there is a good reason to remove an action from the table this can be agreed with the EBRD during the development of the project. The table shows the source and timing of the requirement and the criteria by which performance of the action will be evaluated. Implementation of all the actions will be the responsibility of project developer. When other companies perform work under contract, the developer will be responsible for those contractors’ compliance with the requirements of the ESAP. This is expected to be accomplished by inclusion of appropriate requirements in contracts and subcontracts, and by direct oversight and supervision by the developer as needed. As specified in various required actions, or as otherwise agreed by the parties, once produced, a project-level ESAP may be further revised from time to time during project performance. No changes to the project-level ESAP will allow violations of Kazakhstan law or of EBRD requirements for environmental and social performance. Additionally, it should be fully understood by all parties that this ESAP does not supersede any local or national laws; the developer must comply with all applicable laws and regulations governing the development of the proposed facilities.
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KAZAKHSTAN RENEWABLE ENERGY FINANCING FACILITY (KAZREFF) – ESAP FOR BIOGAS PROJECTS Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility 0 Prepare and submit reports on status of ESAP EBRD PR1 Each six months Submission reports on environmental, implementation and environmental and social during construction, occupational health and safety, and performance, including resolution of grievances. annually thereafter social (ESHS) performance 1. Environmental and social planning and management 1.1 Achieve and maintain environmental and social Best international Ongoing Include in ESHS report the status of management systems equivalent to ISO 14001. management practices. environmental and social management systems PR1 1.2 Achieve and maintain an occupational health Best international Ongoing Include in ESHS report the status of OHS and safety (OHS) management system to OHSAS management practices. management systems 18001 or equivalent for all companies associated PR1 with energy generation, transmission and distribution. 1.3 Appoint responsible manager(s) for Best international Throughout - Appointment of corporate ESHS environmental and occupational health and management practices. construction and manager safety issues. Train foremen and appropriate operation PR1 - Training of foremen and other staff staff on each construction team and ensure operations meet the relevant requirements of this - Ultimate goal: full compliance with ESAP and, as needed, the requirements of ESAP EBRD’s Performance Requirements. - Include in ESHS report updates on appointment(s) and training 1.4 Develop comprehensive waste management Best international Prior to and during - Preparation and implementation of plans for the project. Plans should include (at a management practices. construction waste management plans
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility minimum): PR1 - Include in ESHS report information on plan preparation and waste - Procedures for proper handling of all waste management compliance status generated at the construction or operational site (including hazardous and non-hazardous waste); - Methods to verify proper off-site management of related wastes by contract waste managers; and, - Measures to minimise waste generation and maximise reuse and recycling (for example, options for reusing digestate – generated as part of the biogas (using animal manure) generation process – through reprocessing and using as feriliser). Note that wastes include paper, printer cartridges, lights, and office waste as well as construction and industrial waste 1.5 Establish corporate policy and procedures for Best international Prior to and during ESHS reports to EBRD on: oversight of contractor (if project proponent is management practices. construction - Programme description not also contractor) ESHS performance during PR1 construction, to include (at a minimum): - Highlights of performance (appointments, inspections, etc.) - Inclusion of appropriate ESAP and other legal requirements in contracts, including - Training requirement for staff/management training; - Contractor summaries (both at - Assignment of clear responsibilities within contractor level and compiled project developer for contractor oversight of the level) in terms of environmental and
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility projects; OHS performance summaries - Regular inspections of sites and contractors’ construction camps; - Contractor reports on performance sufficient to allow inclusion of data in ESHS reports to the Bank, and to allow developer to determine if corrective actions are needed; and, - Verification of training and professional credentials for contractor environmental and OHS managers and staff. 1.6 Obtain all required permits for the projects and Local regulatory Prior to construction - Identify permits required and comply with permit requirements. requirements and during received in ESHS reports; and, operation, as PR1 - Report on compliance in ESHS applicable reports 1.7 Monitor performance of project during operation PR1 During operation Submission of monitoring reports against the environmental and social standards demonstrating that predicted and objectives set and submit regular reports to environmental and social effects are being satisfactory mitigated for. EBRD at agreed timescales and for an agreed period (likely to be a number of years). 2. Performance Requirement 2: Labour and Working Conditions 2.1 Evaluate HR management system and PR2 Prior to construction - Until complete, include in ESHS procedures against EBRD requirements and report status of required and Kazakhstan law, including specifically completed updates to HR systems; provisions covering: - Report annually on key worker data,
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility - terms of employment and dismissal; including dismissals and new hires, status of medical checks, etc.; and, - grievance mechanism; - Include in ESHS report data on - discrimination, harassment, violations and numbers of workers in various human rights; categories (management, skilled, - proscription of forced and child labour; unskilled, etc.), and breakdown by gender. - mandatory medical checks for new hires; and, - social leave/benefits. Update system/policies as necessary to ensure compliance. 2.2 As part of policy development under item 1.5 PR2 Prior to contracting - Preparation and implementation of above, develop and implement a contractor plan; and, management plan for the project, and procedures - Report on contractors’ compliance ensuring contractor’s compliance with EBRD PR and oversight results. 2 and Kazakhstan labour law. 2.3 Support local labour force by: Best international Throughout - No complaints from labour force; practices. construction and, - Providing realistic information on employment opportunities, with transparent PR2 - Include data on use of local labour in hiring practices; ESHS reports. - Advertise for all positions; - Employing local labour where possible; - Pay wages at least average for the area for comparable positions; and, - Construction camps must comply with ERM 96 KasREFF SER RPER Biogas – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility Kazakhstan law and provide adequate heating, showering and cooking facilities. 2.4 Develop and implement an OHS plan to guide Best international Plan in place prior - Preparation and implementation of all project-related activities on the project sites practices. to construction (for OHS plans for projects; during construction and then throughout contractors, prior to PR2 - Review and approval of contractor operation. Also require contractor site operations). OHS plans; and, plan/compliance. Requirements to include (but Throughout not be limited to): - Include in ESHS reports to Bank data construction and on performance by developer and - Job- and task-specific hazard analysis and operation. contractors (hours worked, accidents, controls for developer and contractor’s lost time, etc.). activities; - Provision of PPE, requirements for use of PPE, and enforcement of PPE use; - Safety training for all personnel, covering hazards for their jobs; - Review and approval of contractors OHS plans, to meet same standards as developer’s plan; - Oversight of contractor OHS implementation, including mandatory reporting; and, - Recording incident statistics, including total work hours.
2.5 Location and life activities of construction camps Best international At all times Compliance shall meet the requirements of Kazakhstan law practices. construction camps Include data on incidents in ESHS and EBRD PR2. PR2 are occupied reports
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility 3. Performance Requirement 3: Pollution Prevention and Abatement 3.1 Implement mitigation measures and best Best international Throughout Minimal air pollution (including dust management practices to prevent / reduce / practices. construction and generation) control air pollution from construction and operation PR3 operational biogas generation process. During construction: - Controls on vehicle emissions during construction (material deliveries and on-site plant movements); - Control dust emissions in dry periods by considerate siting and access routes, and where necessary using water or other dust suppression methods on roads and construction areas that may generate dust; - Ensure efficient usage of delivery vehicles; including use of alternative and/or more efficient delivery methods (including for example rail, boat) during construction to optimise the emissions to atmosphere per payload; - Ensure all vehicles carrying spoil and all stockpiles are covered; - Switch vehicles and equipment off when not in use; and, - Keep all motorised equipment and vehicles well-maintained to reduce emissions.
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility Emissions controls during operation of biogas plants should ensure compliance with Kazakhstan and EU standards, including consideration of: - Gas cleaning (to remove contaminants in source gas); - Monitoring and control of emissions of nitrogen oxides (NOx), sulfur oxides (SOx), volatile organic compounds (VOCs), carbon monoxide (CO), carbon dioxide (CO2) and particulate matter (PM); - Continuous Emissions Monitoring (CEM) equipment; and, - Controls on odour emissions (although these may be less than previous odour levels for existing LFG / livestock farms). 3.2 Develop water resource plan to minimise the Best international Prior to construction Minimise water resource use volumes of water used and consider appropriate practices. techniques to operate the biogas generation PR3 without causing detriment to other users of water resources. 3.3 Develop erosion, sediment and water quality Best international Prior to construction Mitigated adverse impacts on water control plan for all areas where the ground will practices. quality be disturbed during construction or that have a PR3 Report on impacts in ESHS reports. pathway to the site area and for areas where fuel storage during operation could result in
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility pollution to watercourses. Plan should (at a minimum): - Specify use of good housekeeping practices and best management practices to minimise surface water and stormwater runoff to watercourses and aquatic habitat (especially in critical areas or time periods for aquatic life). For example, siltation dispersal, such as settling ponds, using silt curtains along any nearby waterways, straw bales, check-dams, and seeding; - Keep hard-standing areas and road surfaces clean from mud and oil build up; - During construction, keep stockpiles covered and minimise bare ground near rivers; - Store hazardous and potentially polluting materials (including animal manure (potential biogas fuel) which is mobile and could cause pollution of surface water) in bunded, secure, areas away from watercourse and pathways to watercourses (e.g. drains, ditches); - Use kerbed/ bunded areas to prevent run off to river; - Sediment and silt collected in any device or structure (such as sediments and moisture removed prior to combustion of LFG) should ERM 100 KasREFF SER RPER Biogas – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility be stored in secure covered areas and regularly disposed (where reuse or recycling is not possible); - Inspections of vehicles and equipment for leaks before use near or in water; and, - Particular attention should be given to avoiding steep slopes and implementing erosion control measures, and promptly re- vegetating cleared land with appropriate native species. 3.4 Implement measures to prevent / reduce / Best international Throughout Mitigation in place for potential adverse control ground contamination as a result of spills practices. construction and impacts of ground contamination. of fuel, lubricants and other chemicals. operation PR3 - Store fuels and oils in bunded containers with 110% capacity; - Ensure drip-trays are in place where fuels or oils are stored or used; - Identify a designated bunded refuelling location; - Educate drivers and equipment operators in proper fuel management, including clean-up of spills; and, - Make spill kits available, and use if necessary to clean up oil spills etc before contaminants can enter the ground or watercourses.
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility 3.5 Ensure appropriate containment and disposal of Best international Throughout Reduction in the risk of water / land construction and operational wastewater, practices. construction and pollution and impacts on ecology including sanitary water, waste-water from fuel operation PR3 digestion process and contaminated storm water. All sanitary and storm water to be collected and (if not able to reuse) delivered to a nearby waste water treatment works. 3.6 Developer to ensure that the project team has a Best international Throughout Potential major incidents identified and high level of preparedness for emergencies (such practices. construction and avoided through emergency planning; if as earthquakes and major dam failures where operation major incidents occur, these are handled PR3 PR4 applicable) and that an appropriate emergency according to the planned procedures. plans is in place and understood by developer and contractor staff. Include the local community in the emergency plan. 3.7 Develop plans to reduce project-related Best international Planning prior to GHG emissions minimised greenhouse gas (GHG) emissions practices. construction and GHG emissions reported to EBRD in implementation - Establish baseline GHG emissions; PR3 ESHA report. throughout - Estimate construction and operation GHG construction and emissions and take steps to reduce these operation during project design; and, - Record actual GHG emissions during construction and operation. 3.8 Develop reinstatement plans for working areas Best international Planning prior to Working areas reinstated with native including for the re-vegetation of areas cleared practices. construction and vegetation where appropriate and as prior to, or during, construction. implementation soon as practicable following PR3 following construction (it is recognised that could
take a number of months or in some
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility construction. cases years). 3.9 Develop soil protection plan to include: Best international Prior to construction Mitigated for potential adverse impacts practices. upon soils. - Site selection and facilities arrangement (including transmission lines, access roads, PR3 PR4 etc); - Measures to minimise compaction and other alteration of soil composition across working area; and, - Soil erosion across the working area. 4. Performance Requirement 4: Community Health & Safety and Security 4.1 Develop and implement – and require PR4 Throughout - Public notices contractors to implement – procedures to protect construction and - Security training public health and safety, to include (but not be operation limited to): - Include in ESHA report to Bank data on notices, training, etc. - Suitable buffer areas around sites to minimise risk to public health and nuisance; - Control of odour and airborne materials that could be detrimental to health (such as dust or particulate matter); - Traffic management plan for all drivers and equipment operators (see 4.2 below); - Public notice of construction operations near areas open to the public; - Methods to identify and prevent spread of those communicable diseases that can be ERM 103 KasREFF SER RPER Biogas – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility transmitted by the project components or its workforce (including contractors); - Methods to prevent and minimise exacerbating impacts caused by natural hazards (such as landslides or floods); - Security as needed to prevent unauthorised access to project locations, with appropriate training for guards to be guided by the principles of proportionality, good international practice and Kazakhstan law; and, - Hazard notices/signs/barriers to discourage/prevent access to energised components or other dangerous areas. 4.2 Develop and implement a Traffic Management - Best international Throughout Traffic management plan Plan. practices construction and Include in ESHS reports data on all operation - Careful consideration and consultation - PR4 accidents should be given to the agreement of delivery routes to the site area (if appropriate, consideration should be given to delivery methods alternative to road – for example by nearby waterways); - Design routes so as to avoid unnecessary conflict with other road users, schools, hospitals, and other areas where there may be heavy pedestrian or child use; - Notify communities and place signs on ERM 104 KasREFF SER RPER Biogas – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility public roads; - Place warning signs along the perimeter of construction areas; - Confine construction activities to daylight hours; - Establish and enforce strict delivery times; - Establish and enforce speed limits on- and off-site; - Provide training to all drivers, enforce compliance with traffic plan; and, - Identify and implement measures to reduce construction traffic where possible, for example through car sharing and use of bicycles etc. 4.3 Develop a noise monitoring and mitigation PR2, PR4 Establish baseline Robust baseline programme that will establish a pre-construction prior to construction Minimal off-site disturbance baseline and ensure construction and operational Monitor noise noise is within Kazakhstan law and to minimise Early awareness of potential noise periodically off-site disturbance to local population. impacts, allowing mitigation to be put in throughout place as required Avoidance and mitigation measures for noise, construction should include consideration of: - Proper siting of development (where siting is to be on a new area, and not on existing landfill/animal manure storage areas) and access routes to avoid close proximity to sensitive noise receptors (e.g. residences, ERM 105 KasREFF SER RPER Biogas – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility hospitals and schools); - Controls on construction and operation hours; - Controls on type of construction and operation plant/vehicles/equipment; - Controls on type of delivery vehicles used, routes used for deliveries and timing of deliveries; and, - Noise screening of works during construction and operation. 4.4 Establish and enforce clear rules for workers Best international At all times when Include in ESHS report information on (including contractor employees) in construction practices construction camps complaints and incidents involving camps to prevent off-site disturbance incidents are occupied workers, and contractor/developer involving local residents. responses 5. Performance Requirement 5: Land Acquisition, Involuntary Resettlement and Economic Displacement 5.1 Avoid siting projects and ancillary works where PR5 PR4 Prior to construction Project siting in area of least disturbance they will cause disruption or displacement to to communities Best international established communities, farms and homes, or practices users of grazing land where possible through thorough consideration of alternatives. 5.2 If displacement is unavoidable, plan to improve PR5 PR4 Prior to construction Sustainable improvements to socio- or, at a minimum, restore the livelihoods and economic status of any displaced persons Best international standards of living of any displaced persons to practices pre-project levels. Displaced persons could include those who have legally recognisable rights or claims to the land, those with
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility customary clams to the land, those with no legally recognisable rights or clams to the land, seasonal resource users such as herders/fishing families, hunter and gathers who may have interdependent economic relations with communities located within the project area. 5.3 Attempt to reach negotiated settlements with all PR5 Prior to construction Amicable agreements avoiding the need affected individuals / households for involuntary resettlement 5.4 If required, compensation to be provided at just PR5 Prior to construction Amicable agreements. replacement value, as determined by court Include information on certified valuators. This will take the form of acquisition/resettlement/ compensation replacement by a similar property or cash actions in ESHS report to Bank. compensation. 6. Performance Requirement 6: Biodiversity, Conservation and Sustainable Resource Management 6.1 Undertake pre-construction ecological surveys Best international Prior to construction Survey reports, focussed on area of and associated assessments of the project practices. proposed construction footprints (including ancillary works such as PR6 improvements to transmission lines and access roads) and surrounding areas to establish a robust baseline. Surveys and assessments should be included for terrestrial ecosystems and aquatic ecosystems as befits the specific project and situation. However, it is envisaged that for biogas development surveys will particularly be needed for the following:
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility - Terrestrial flora (including protected habitats); - Birds (in particular implications of land take on potential nesting and foraging habitats); - Wide-ranging mammals (including, bats, otter, brown bear, bison, lynx and wildcat); and, - Where appropriate, other terrestrial fauna (such as reptiles and invertebrates). 6.2 Develop an Ecosystem Protection Plan following Best international Develop plan prior Production of an Ecosystem Protection the ecological surveys. practices. to construction and Plan follow plan during Follow the Biodiversity Mitigation Hierarchy: to PR6 construction. Avoid, Minimise, Mitigate and Offset likely adverse effects. This plan to cover the construction and operational phases and to include consideration of all species and habitats applicable to the project, including provisions to: - Avoid, or mitigate for, siting of biogas plant and associated transmission lines in areas recognised as important for bird nesting or foraging; - Avoid, or mitigate for, siting biogas plant or associated structures in areas recognised as important for bat roosting and/or foraging; - Mitigation for potential light disturbance to ERM 108 KasREFF SER RPER Biogas – June 2014
Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility bats and other nocturnal species; - Identify and avoid or mitigate for project impacts upon species utilising key crossing points (crossing roads, transmission lines, etc). Mitigation may include, for example, such inclusions as aerial bat crossings, mammal underpasses, speed restricted crossing points and fencing, and / or restrictions upon vehicle movements during key migratory periods or times of day. 6.3 Following construction, re-grade and re-vegetate Best international End of construction Reduced adverse effects on flora and disturbed area with native species. practices. fauna PR6 6.4 Avoid development within sites protected for Best international Prior to construction Reduced adverse effects on flora and their biodiversity under international or practices. fauna Kazakhstan law (habitats and/or species). PR6 6.5 Avoid, or mitigate for, siting of development or Best international Prior to construction Reduced adverse effects on nature ancillary works (including transmission lines, practices. tourism access roads, etc) in areas important for nature PR6 tourism. 8. Performance Requirement 8: Cultural Heritage 8.1 Undertake archaeological desk study and site PR8 Prior to construction Survey report, focussed on area of investigations where necessary to identify the proposed construction. likelihood of presence of artefacts or other items of cultural significance (for biogas projects this is most likely to apply to ancillary works areas
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility rather than generation plant locations).
8.2 Develop measures to avoid direct impacts on PR8 Prior to construction Protection of cultural heritage protected cultural heritage sites and their Include information on finds in ESHS settings (including UNESCO sites and those on report to Bank. the tentative list); and avoid, or where necessary mitigate for, impacts upon Registered Cultural Heritage Sites, Zones and Settlements, and unregistered or previously undiscovered sites by following a staged approach to cultural heritage studies involving qualified expertise and in consultation with the EBRD. 8.3 Before (and if needed, during) major earthworks, PR8 Throughout Protection of cultural heritage ensure the supervision of an archaeologist from a construction Include information on finds in ESHS competent conservatory institution to prevent report to Bank. destruction or theft of found objects and building remains with scientific or material value. 8.4 Develop a chance find procedure PR8 Prior to construction Protection of cultural heritage 8.5 Develop measures to avoid, or where not PR8 Prior to construction Protection of cultural practices and possible to avoid, mitigate for potential loss or resources disruption to cultural practices or resources. Include information on finds in ESHS report to Bank. 8.6 Undertake a Landscape and Visual Impact Best international Prior to construction Protection of landscapes Assessment (LVIA) of the project, including practices.
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility consideration of the potential visual impacts of PR8 the biogas plant and associated ancillary works from all relevant viewing angles when considering locations. 8.7 Develop a Landscape Protection Plan following Best international Prior to construction Protection of landscapes the LVIA. Follow the Mitigation Hierarchy: to practices. Avoid, Minimise, Mitigate and Offset likely PR8 adverse effects upon the natural features and landscapes that have archaeological, paleontological, historical, architectural, religious, aesthetic or other cultural significance. This plan to cover the construction and operational phases and to consider the inclusion of the following aspects where applicable: - Screening of works and operations (for example by using natural features such as tree lines, or by careful placement of earthworks); - Sensitive placement and route placement of power transmission lines, access roads and other associated work; and, - Routing of roads and transmission lines along existing cuttings or linear features to reduce on setting. 10. Performance Requirement 10: Information Disclosure and Stakeholder Engagement 10.1 Develop a Stakeholder Engagement Plan, PR10 Prior to construction Review and approval by EBRD
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Source of Requirement Date to be No. Issue/Action (EBRD PR #, EU, BAT, completed / Measure of success etc.) responsibility including a Grievance Mechanism (SEP) 10.2 Complete EBRD ESIA requirements for Category PR10 Prior to construction Disclosure through suitable means, to be B projects with a disclosure package, to be agreed with EBRD, which could include: agreed with EBRD, comprising of at least the - Flyers to local residents; SEP, this Environmental and Social Action Plan and a Non-technical summary of the - Posters in local venues/ public halls; environmental and social assessment - Information on KazREFF and/or undertaken. developer’s websites; - Public meetings; and/or, - Other, as specified in SEP. 10.3 Implement the agreed SEP, inform stakeholders PR10 Throughout project Include in ESHS report: of activities and progress, and receive and - details on grievances and resolution; respond to grievances. and, - consultations and other outreach to the community, including authorities
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