Rajgród Fw6 Wind Farm Poland

Non-Technical Executive Summary

RAJGRÓD FW6 WIND FARM POLAND

March 2013

Introduction and general project presentation

Grupa PEP – Farma Wiatrowa 6 Sp. z o.o. (developer) is developing a wind farm in the commune of Rajgród (gmina), Grajewo county (powiat), Podlaskie voivodeship (województwo), north-eastern Poland.

The subject wind farm configuration includes:

 11 wind turbine generators (WTGs), type Siemens SWT-2.3-108,

 main electrical substation (MES Rajgród);

 underground infrastructure of power transmission and control cables;

 access roads to individual WTGs and assembly and service yards;

 power transmission line from MES Rajgród to the switching station 110 kV/15 kV Grajewo 1.

Total installed capacity of the wind farm will be 25.3 MW.

The WTGs are to be located in one group, between the villages of Bukowo and Kołaki in the west, Karwowo and Skrodzkie in the north, Kosiły and Łazarze in the east and Turczyn and Danowo in the south.

The project is classified, both from the point of view of European Union and Polish legislation (Executive Order from November 9, 2010 on investments potentially significantly impacting the environment), as the one which may be required to undergo Environmental Impact Assessment process as an investment which could have a potentially significant impact on the environment. The local authorities taking into account the environmental regulations decided that development of an environmental impact assessment report is obligatory for the investment.

This non-technical summary presents information enclosed in the environmental impact assessment reports (EIA) prepared for the project execution and other environmental documentations prepared for the needs of the planned wind farm.

Based on the environmental impact assessment reports and analysis of available information, the project is not likely to generate significant adverse social impacts or need for involuntary resettlement or economic displacement. No regulatory non-compliance issues were identified in this audit. WTGs description

According to the environmental impact assessment reports prepared for the development, development of 15 wind turbine generators VESTAS V90-3.0 MW was initially analyzed.

In the final planned scenario the number of WTGs was reduced to 13, the locations were also modified. The changes were determined by the need of minimization of the impact on the environment, and resulted from environmental impact assessment analyses and the pre- investment birds monitoring. Eventually, the number of WTGs has been reduced to 11 due

to the conditions of connections to power grid. The developer also decided to change the initially considered WTG model and to install Siemens SWT-2.3-108 wind turbines of a total power capacity of 25.3 MW. It is planned to construct 115 m high hubs with rotors of 108 m in diameter.

A typical wind turbine generator consists of a tower and a gondola comprising a rotor and measurement apparatus. The rotor is composed of the blades, attached to each other by a bearing. The blades are moved by the wind and transmit this force to the bearing, which is connected to a multiplier that increases the axle speed. The mechanical energy is transferred from the multiplier to an electricity generator, which transforms it into electricity for subsequent injection into the grid.

Access to the WTGs will be provided by a network of access roads. Total length of newly constructed roads will amount approximately 3.5 km. Total area developed as part of the project including areas of the newly constructed roads, technical yards and foundations in the vicinity of WTGs and the main electrical substation will amount to approximately 4.7 ha.

The individual WTGs will generate electricity of a 0.69 kV voltage, which after transformation in the individual, on-site, container substations will be transferred to the MES via an underground connection of approximately 3.5 km length and will not pass any sensitive environmental areas, according to the environmental impact assessment report.

The construction works have not started yet, however, the project already passed the EIA procedure and was granted environmental decision. As reported by the developer, the Building Permit for the wind farm project has been granted as of March 18, but is currently being amended due to the decision to develop 11 WTGs instead of initially-planned 13 WTGs.

Project Location

The Rajgród wind farm is to be developed in the commune of Rajgród (in the villages of Turczyn, Bukowo, Kołaki, Łazarze, Kosiły, Karwowo, Skrodzkie i Wólka Piotrowska), Grajewo county, Podlaskie voivodeship. According to the available sources, the Rajgród commune occupies an area of approximately 207 km2, of which 58% is occupied by agricultural land and 29% by forests. As of 2004, the population of the commune counted approximately 5 615.

The wind farm is to comprise one site located ca. 8-10 km south-west from the Rajgród town. The site, of an approximate area of 10 km2 which will house 11 WTGs of a maximum capacity of 2.3 MW each, can be described as an irregular path of land stretching out between the villages of Bukowo in the west and Kosiły in the east. The westernmost WTG is located in a distance of approximately 6 km to the south-west of Rajgród.

Based on the site visit observations and review of aerial photos available e.g. at http://geoserwis.gdos.gov.pl/mapy/, the wind farm development area has a rural character. The terrain in this area is flat, with numerous small hilly postglacial forms and closed depressions. The terrain elevation varies between 120 m asl in its eastern corner to 137 m asl in the western part. The majority of the area of the planned wind farm location is

occupied by arable fields. Local woodlots and bushes with single trees and occasional bushes make the prevailing vegetation in the area. There is a network of local dirt roads along the routes of the planned cable power lines. There is a national road no. 61 (Warszawa-Augustów) which runs in a distance of ca. 2-3 km south and south-east from of the wind farm development.

Based on visual observations, the local road network provides easy access to the construction sites with no evident obstacles that could affect transport of an oversize cargo during the construction phase. In particular no trees or historical monuments were identified as such possible obstacles.

The planned wind farm development site is not located within the borders of protected areas. There are, however, environmentally sensitive areas and protected areas located in the site’s surroundings. The nearest protected areas identified by the EIA reports are:

 Biebrzański Park Narodowy (Biebrza National Park), approximately 8 km south-east from the nearest planned wind farm development,

 Nature reserves: “Czapliniec-Bełda” (approximately 2,5 km east from the planned wind farm development), “Ostoja Bobrów Bartosze” (approximately 20 km north-west from the planned wind farm development), Zdedy” (approximately 26 km west from the planned wind farm development), “Jezioro Kolno” (approximately 26,2 km north- east from the planned wind farm development), “Ławski Las I” (approximately 27,6 km south-west from the planned wind farm development), “Ławski Las II” (approximately 28,8 km south-west from the planned wind farm development);

 Landscape Protected Areas: “OCHK Pojezierza Rajgrodzkie” (approximately 1 km north-east and east from the planned wind farm development), “OCHK Jezior Rajgrodzkich” (approximately 3,5 km north from the planned wind farm development), “OCHK Pojezierza Ełckiego” (approximately 4 km west from the planned wind farm development), “OCHK Jeziora Rajgrodzkie” (approximately 6 km east from the planned wind farm development), “OCHK Dolina Biebrzy”(approximately 12,9 km east from the planned wind farm development), “OCHK Wzgórz Dybowskich” (approximately 13,3 km east from the planned wind farm development), “OCHK Doliny Legi” (approximately 17,2 km north-west from the planned wind farm development), “OCHK Jezior Orzyskich” (approximately 20 km west from the planned wind farm development), “OCHK Puszcza i Jeziora Augustowskie” (approximately 22 km north-east from the planned wind farm development), “OCHK Puszczy i Jezior Piskich” (approximately 25,4 km west from the planned wind farm development) and “OCHK Dolina Rospudy” (approximately 27 km north-east from the planned wind farm development).

 Natura 2000 Special Protection Areas: PLB200006 “Ostoja Biebrzańska” (approximately 2 km south-east from the planned wind farm development), Area PLB200002 “Puszcza Augustowska” (approximately 23,4 km north-east from the planned wind farm development) and PLB280014 “Ostoja Poligon Orzysz” (approximately 25 km west from the planned wind farm development).

 Natura 2000 Sites of Community Importance: PLH200008 “Dolina Biebrzy” (approximately 7,9 km south-east from the planned wind farm development),

PLH200005 “Puszcza Augustowska” (approximately 25 km north-east from the planned wind farm development), PLH280034 “Jezioro Woszczelskie” (approximately 25 km north-east from the planned wind farm development) and PLH280041 “Murawy na Pojezierzu Ełckim” (approximately 26,2 km north-east from the planned wind farm development).

 Ecological sites: – the nearest one is “Ślepe Jezioro Okoniówek” in a distance of approximately 3,5 km north-east from the planned wind farm development.

 Natural monuments – the nearest ones are located in the Biebrza National Park, approximately 8 km away from the wind farm development.

As established during the meeting with Rajgród authorities representative, there are no existing wind farms or single WTGs at the territory of the commune and no such development, except for the subject one, is planned. For the purposes of the environmental assessment all communes bordering with Rajgród were contacted, i.e.: Bargłów Kościelny, Goniądz, Grajewo, Kalinowo and Prostki. All commune offices were contacted via telephone and the representatives of local authorities, responsible for environment protection and development investment were interviewed. The interviews were focused on obtaining general information regarding any wind farm investments (existing or being developed) within the borders of the subject commune.

Based on the interviews, there are no existing wind farms or wind farms currently under development in the neighboring communes, except for Grajewo commune and Prostki commune. In Prostki commune, one wind turbine was reported to be already present (WTG of a capacity of 0.6 MW) but there no plans for further investments of such type in the area of the commune (potentially, 3 wind farms will be constructed). In the Grajewo commune, there is a study of spatial development of the commune and it includes possible location of potential wind farm investment in the area. There are plans for 25 WTGs of a capacity of 3 MW each to be developed in the commune. Currently the investment is at a preliminary stage – there is a local spatial development plan (issued in September 2012) and the investor has applied for the decision on environmental conditions of approval of an undertaking for the investment. No wind farm projects were reported to be planned at the time of the interviews (March 15-19, 2013) in the other surrounding communes, including: Bargłów Kościelny, Goniądz and Kalinowo.

Rationale for this Project In line with European Climate Change Program, many European countries, including Poland, have adopted national programmers aimed at reducing emissions. These cover various policies, adopted at the European level as well as national levels, includes among others:  Planned increase in use of renewable energy (wind, solar, biomass)  Improvements in energy efficiency in e.g. buildings, industry, household appliances; The main regulations of EU countries to reduce emissions is the Emission Trading Scheme of carbon dioxide and legislation tackling with emissions of fluorinated greenhouse gases.

The development of wind energy is one of the measures to be implemented, and leads to the limitations of air emissions and an increase of production of energy from renewable

resources. The main benefit is that wind turbines convert the wind’s kinetic energy to electricity, while producing none of the emissions to the air. Conventional energy sources, mainly based on various types of coal incineration, when producing energy generate emissions of greenhouse gases, SO2, dust and others.

The wind energy is considered to be one of the cleanest ones, in fact, during the exploitation phase of the turbines no pollutants are emitted to the atmosphere.

According to the EIA report, the expected annual energy production will amount approximately 73 400 MWh. Therefore the environmental benefit of the project will be to reduce greenhouse gases emission in an amount of 46 829tons (calculated based on an emission factor, representative for projects supplying additional electricity to the grid, as of 0.638 tCO2/MWh, produced for Poland in 2012) per year. The development will also help the country to meet the national plan to achieve 15% share of renewable energy use in total energy consumption by 2015.

Apart from saving the greenhouse gases emission, the project will also result with significant “avoidance” of post-combustion emissions. As an example, the equivalent production of electricity by the largest Polish hard-coal power plant in Kozienice would result with the following emissions (estimations based on Elektrownia Kozienice emission factors for 2011)

 PM: approx. 6 tons/year;

 SO2: approx. 193 tons/year;

 NOx: approx. 126 tons/year.

Exploitation of the subject wind farm can be therefore considered a measure to avoid the emissions to the atmosphere of the comparable amounts of pollutants.

The issues of social advantages of the project were widely discussed with the representative of the Rajgród commune. The following direct advantages were agreed with the representative during the discussion:

 the project will increase income of the commune by taxes paid by the operator for commercial activities in the area;

 the project will increase income of the owners of the land occupied by the wind farm and its infrastructure;

 the project helps the local authorities to promote pro-ecological behavior of the local citizens.

Legislative Context and Public Consultations The procedure regarding the wind farm location had been commenced by elaboration of local spatial planning documents including: elaboration of amendments of the the commune frame development plan (studium kierunków i uwarunkowań zagospodarowania przestrzennego) and development of the Local Zoning Plan (miejscowy plan zagospodarowania przestrzennego). The procedure was conducted by the authorities, following the rules of the Act on Spatial Planning and Development of March 27, 2003 (with

further amendments). Local Zoning Plan was issued with a Resolution No. VI/40/11 issued on May 20, 2011 by the Commune Council of Rajgród.

According to environmental regulations: Regulation on disclosure on environmental information, public participation in environment protection and on environmental impact assessments, an Environmental Impact Assessment (EIA) procedure must be performed for projects which can always significantly impact the environment (group I projects) or particular ones which can potentially impact the environment (group II projects), or may impact an area of ‘Natura 2000’ protected land. An EIA is carried out to obtain a decision on Environmental Conditions (environmental decision) which is obligatory for a realization of an individual project.

In the administrative procedure for the project the Authorities obligated the Investor to prepare an EIA report.

The procedure involved among others obtaining positive opinions from the Regional Directorate of Environmental Protection (RDEP) in Białystok (issued on September 19, 2011) and the State County Sanitary Inspectorate in Grajewo (issued on September 16, 2011). Information on the planned investment together with EIA Reports were made available for comments of the public, including local communities and potential interested parties, such as nature protection bodies and ecological organizations. On September 5, 2011 the Rajgród Commune Head issued a note informing on the commenced proceedings regarding issuing the decision on environmental conditions for the Rajgród wind farm. Respective announcements on the amendments were available for the public, including publication of the enouncements on the official notice boards of the City Hall in Rajgród with copies on notice boards in the commune villages and was available at the commune office and publication on the webpage of the Commune of Rajgród (http://bip.um.rajgrod.wrotapodlasia.pl). The time period for filing complaints or comments was given for 21 days since the date of publishing the note. Following the preparation of the EIA reports, the Rajgród Commune Head issued the decision on environmental conditions of the Rajgród wind farm project, on December 21, 2011.

The key environmental conditions and comments resulting from the environmental decision are:

 to comply with the regulation on maximal environmental noise levels;  to perform monitoring of avifauna in three full-year cycles including the first, second and fourth year following the wind farm’s completion. Frequency of observations should be increased to 2-3 days a week in the period of spring migration (March 1 - April 10) and in the summer (July 1 – August 20);  to perform monitoring of bats’ population in a period of at least 3 years following the completion of the wind farm;  to perform environmental noise monitoring in two sessions: the first after the Building Permit has been issued but prior to the beginning of the construction phase (or, alternatively, after the wind farm has been completed but with the wind turbines switched off) and the second after the wind farm has been completed (in conditions similar to the first session);  to limit operation of the farm in case significant number of birds (in particular storks), are observed during migration periods. Similarly, operation of the farm should be limited if monitoring of bats and monitoring of noise reveal significant impacts.

What is the current condition of the existing environment?

Nature Protection

The planned wind farm is located away from environmentally sensitive areas. The nearest protected areas, identified by the EIA reports are:

 Biebrzański Park Narodowy (Biebrza National Park), approximately 8 km south-east from the nearest planned wind farm development,

 Nature reserve “Czapliniec-Bełda”, located approximately 2,5 km east from the planned wind farm development. Other nature reserves are located in a distance of over 20 km;

 Landscape Protected Areas “OCHK Pojezierza Rajgrodzkie”, located approximately 1 km north-east and east from the planned wind farm development, “OCHK Jezior Rajgrodzkich” located approximately 3,5 km north from the planned wind farm development, “OCHK Pojezierza Ełckiego”, located approximately 4 km west from the planned wind farm development and “OCHK Jeziora Rajgrodzkie”, located approximately 6 km east from the planned wind farm development.

 Natura 2000 Special Protection Area PLB200006 “Ostoja Biebrzańska”, the borders of which are located approximately 2 km south-east from the planned wind farm development;

 Natura 2000 Site of Community Importance PLH200008 “Dolina Biebrzy”, the borders of which are located approximately 8 km south-east from the planned wind farm development;

 Ecological sites “Ślepe Jezioro Okoniówek” in a distance of approximately 3,5 km north-east from the planned wind farm development.

 Natural monuments, the nearest of which are located in the Biebrza National Park, approximately 8 km away from the wind farm development.

The wind farm area was screened in 2009 for presence of valuable flora and fauna habitats (“opracowanie ekofizjograficzne” document). No such habitats were identified at the planned locations of WTGs or supporting infrastructure. However, wild mammals tracks as well as presence of 6 species of amphibians (e.g. frogs) and numerous insects were identified in the area. Potential impact of the wind farm on flora and these kind of fauna was assessed by the EIA reports as insignificant.

Below you will find a map presenting distance of the GWT locations (violet dots) to the nearest nature protection areas (source: Raport o oddziaływaniu na środowisko przedsięwzięcia: budowa farmy wiatrowej Rajgród)

Birds and bats issues

As a part of the pre-investment process, including preparation of the EIA reports, a monitoring of birds lasting over a year, including two spring migrations, was performed (January 2009 – August 2010). Monitoring of bats consisted of two independent series of observations (March – November 2009 and March – November 2010).

The monitoring of birds comprised point observations (3 points), transect observations (along 9km of transects), observations of hatching species in accordance guidelines of the Monitoring of Common Hatching Birds (issued by Ogólnopolskie Towarzystwo Ochrony

Ptaków) and monitoring of rare and medium-quantity hatching species. The intensity of observations depended on the part of the year. Observations included the use of air space by birds (species of birds, direction and height of flights, distances covered). The monitoring program included 38 field campaigns in January-December 2009 and 27 field campaigns in January-August 2010. The quantities of birds identified during the monitoring are typical for the Polish territory and do not deviate from those reported for other parts of the country. At the area of the planned wind farm, a total of 141 bird species were observed (including 29 species listed in Annex I of the Bird Directive). 83 bird species were classified as hatching birds (including 7 species listed in Annex I of the Bird Directive) and additional 10 species (including 5 species listed in Annex I of the Bird Directive) were using the area of the planned wind farm, but they did not fulfill criteria of hatching at the area. The area of the planned wind farm comprises an area of dense and numerous occurrence of white stork and crane, and is distinguishing with respect to occurrence of common species such as mallard, stock dove, grey nightingale and hooded crow. Other species commonly encountered at the area of the planned wind farm included skylark, yellowhammer, yellow wagtail and whinchat.

The most valuable hatching species observed at the site are these listed in the Annex I to the Bird Directive: white stork, marsh harrier, lesser spotted eagle, crane, shrike, corncrake and black woodpecker. It was a few nests of these species observed, with except for white stork, which was found to nest intensively in the villages surrounding the planned wind farm area.

At the area of the planned wind farm, no occurrence of species under zone protection of hatching sites were observed. Similarly, after resignation of two northernmost WTGs, the nearest hatching site of a species under zone protection (lesser spotted eagle) were observed to be located 1.5 to 2 km north of the planned WTGs location. Based on the results of the monitoring it was determined that hatching sites of other species under zone protection (such as black stork, white-tailed eagle, lesser spotted eagle, red kite) are located in a safe distance from the planned wind farm.

During point observations, the researchers observed number and species of flying birds, as well as flight altitude (in ranges 0-50 m, 50-170 m, and above 170 m) and direction. The report provides information on number of observed flights and dominant direction, and general information about dominant flight altitudes. The flight altitude up to 50 m (i.e. below lower range of WTGs’ blades) is indicated in the report as dominant for local and long distance flights.

Based on the monitoring results, the site was not identified as important migration corridor. The only more frequently observed species was goose (during spring migration), however not in quantities exceeding the average for northern Poland.

Forecast of mortality of all birds related to collision with WTGs at the area of the planned wind farm predicts average of 23.4–25.5 victims/year. Among the species particularly exposed to collisions, encountered frequently in the area, there are: buzzard, skylark and starling comprise the species.

The planned wind farm is not expected to deteriorate living conditions of populations of birds living at the area of Natura 2000 Special Protection Area PLB200006 “Ostoja Biebrzańska”, located approximately 2 km south-east from the planned wind farm development.

The general conclusion presented in the report was that the wind farm will not generate extensive impact on birds, the overall likelihood of negative impact was assessed as low to medium.

The monitoring of bats comprised of field, transect observations in 8 transects, during which noise detection was carried out. Three species of bats were identified in the area, including serotine bat (Eptesicus serotinus), common noctule (Nyctalus noctula), and Nathusius's pipistrelle (Pipistrellus Nathusii). All of these species are under strict protection.

These were observed flying along roadsides and in vicinity of buildings (transects No. 5-8). For detected bats an activity index was calculated following the guidelines for assessment of wind turbines on bats. For the transects located in the vicinity of the planned WTGs locations (transects No. 1-4), the bats activities established based on activity indexes was small. In general, the occurrence of bats in the area of the planned wind farm was rare, as most of the bats avoid open areas without wooded areas, roadsides and wet areas which comprise bats’ feeding grounds. The planned investment should not adversely impact the bats’ population in the area.

Taking into account results of the birds and bats monitoring, it was assessed that potential impact of the planned wind farm on these is low to medium. Social impacts The project has direct socio-economic impacts on development of the Radzyń Chełmiński commune and local inhabitants. The following direct impacts have been identified:

 increase of the commune tax income;

 increase of the annual income of land leasers;

Development of the Project will not require any displacement of the people or business. The negative impact is related to decrease of the land area used for agricultural purposes, however, this will be compensated by the land lease fees.

What impacts during construction will there be? The main impacts of the projects associated with the wind farm development relate to earth works (primarily during setting of foundations for the towers), construction works and increased transport traffic and include intrusion and disturbance within soils strata, temporary change of groundwater level (when groundwater draining is required during the construction), increased noise and vibration. To limit the impact the investor is obliged to undertake numbers of measure as:

 to limit potential impact on soil and groundwater quality resulting from potential fuel/oil leakages; construction backyards should be isolated from soils and groundwater ;  to reduce noise emissions during the investments; construction works which could cause excessive noise emissions should be reserved for daytime;  to comply with environmental noise standards.

What will be the impacts during operation? Completed investigations and public consultations conducted primarily as part of the environmental impact assessments procedure identified that main environmental impacts associated with the operation of the wind farm refer to increased noise levels, change in the landscape and influence on avifauna and bats.

Birds and bats The location of 11 WTGs will create some threat to birds and bats. Nevertheless it should be pointed out that a number of observations and reports on active wind farms and its impact on birds populations indicates that birds avoid collisions with wind farms. The number of deaths of birds resulting from collisions with wind turbines is significantly smaller than those caused by collisions with e.g. cars, power lines and houses.

To recognize the local birds populations and undertake applicable measures during the planning stage the investor has conducted a number of ornithological observation at the areas of the planned wind farm. In a view of the pre-investments monitoring results the identified avifauna was classified as a typical for the Polish territory and does not deviate from those reported for other parts of the country.

The general conclusion presented in the report was that the wind farm will not generate extensive impact on birds. It was concluded that the wind farm will not impact Natura 2000 site “Ostoja Biebrzańska”, the borders of which are located in a distance of 2 km south-east of the planned wind farm area.

The monitoring of bats comprised of field, transect observations, during which noise detection measurements was carried out. Three species of bats were identified in the area of the wind farm, all protected by national law and listed in Annex IV to the Habitat Directive. No significant habitats or hibernation sites were identified. The observed species belong to anthropofilic types, creating colonies within buildings but hunting on open fields and open spaces within woods.

Taking into account results of the bats monitoring, it was assessed that potential impact of the planned wind farm should not negatively impact on the local bats’ populations.

Noise generation Noise emission is considered as one of the most common environmental impacts generated by wind farms. For the purpose of noise impact assessment, a numerical modeling of noise distribution was conducted as part of the EIA report and during planning stages of the project (taking into account increased acoustic power of the chosen WTGs and a limited number of WTGs, in comparison with the assumption of the EIA report). Noise distribution calculations were conducted with use of a dedicated software („LEQ Professional 6.0”), compliant with Polish technical standards relating to the assessment and management of environmental noise. The calculations were conducted for selected eleven WTGs with maximum acoustic power (107 dB) at the borders of the acoustically protected areas - residential areas of

Bukowo, Kołaki, Karwowo, Skrodzkie, Kosiły Łazarze, Turczyn and Danowo villages. The calculation results were then verified against permissible noise levels specified by the dedicated Executive Order (Rozporządzenie Ministra Środowiska z dnia 14 czerwca 2007 r. w sprawie dopuszczalnych poziomów hałasu w środowisku).

The results of calculations indicated that the operation of the wind farms will not cause the breaches of the ambient noise standards at any of the acoustically protected areas both during the daytime and nighttime, and that the maximum noise levels at these areas borders will vary between 40.0 and 44.3 dB(A) for both nighttime and daytime. It should be mentioned here, that the WTGs, Siemens SWT-2.3-108, can be operated with reduced noise emission, which together with positive noise distribution calculation results (calculated with reduced noise emission for several WTGs) should secure the noise standards to be kept at the protected areas.

The maps illustrating the calculated acoustic climate, (with visible isolines of 40, 45 and 50 dB) are presented below (source: Additional calculations of the acoustic climate at the planned Rajgród FW6 wind farm, made after a decision was made to construct 11 WTGs of Siemens SWT-2.3-108 type).

Landscape The wind farm will be developed in purely agricultural area i.e. local landscape has already been influenced by humans. Construction of the wind farm will introduce new visual dominants (WTGs and newly constructed roads) to the landscape. Importance of its impacts on landscape depends on the scale of converted/impacted landscape (i.e. local, sub-regional or regional), what type of landscape is transformed (natural, semi-natural, agricultural, cultural, industrial etc.) and whether the impacted landscape is protected, as well as the on the number of people remaining/visiting the impacted landscape.

The landscape analysis, prepared as part of the EIA reports, showed that the WTGs, as new man-made element of the landscape will be visible mostly to local inhabitants (local villages Skrodzkie, Kosiły, Łazarze, Turczyn, Danowo, Wólka Piotrowska, Bukowo, Kołaki, Karwowo and adjacent villages: Czarna Wieś, Bełda, Miecze, Rydzewo, Wólka Mała, Toczyłowo, Kosówka, Długosze, Kopijki, Katarzynowo i Zawady-Twork) and, in limited scope, in the western part of the city of Rajgród and eastern part of the city of Grajewo (from a distance of 4.5 km and 7.5 km respectively). The WTGs will be also visible from roads running in the vicinity of the planned wind farm as well as from the national road No. 61 (1.2 km south of the site), country roads and from some protected areas, in particular Area of Protected Landscape „Pojezierze Rajgrodzkie”, the borders of which are located in a distance of 0.9 km east. However, the visibility of WTGs from the Area of Protected Landscape „Pojezierze Rajgrodzkie” will be limited by presence of a dense forest complex.

There are no cultural heritage registered as historical monuments objects located in the project area of influence. Cumulative visual impact is not expected as the nearest planned wind farm developments are considered for areas located in a distance of more than 10 km of the planned Rajgród FW6 wind farm.

The rotating blades of the turbine may cause the shadow flicker effect. Such impact impacts have been mentioned in the EIA reports, however, without a detailed assessment. It was concluded in the EIA report that such effect causes nuisance in a distance equal to 2-3 height of WTG, thus apart from some impact during winter season (i.e. due to presence of sun just above horizon) should not be an issue of concern at the subject wind farm.

Measure Aiming at Limitation of the Impact The main measure which may be used to prevent significant environmental impact of a wind farm is a good choice of the location. Thus, during the project preparation different locations of wind turbines have been analyzed. Preparation of the investment, apart from technological and economic issues such as winds characteristics and costs of land purchase and use, have taken into account the following issues, important from the perspective of environmental protection:

 existing land development and use, including distribution of residential housing, forests, farming lands, protected objects;  mutual impact of individual objects on each other, including also possible adding up of sound waves,  necessity of protecting the objects of residential housing against noise.  location from the perspective of birds and bats protection,

The second aspect of choice, very important from the point of view of environmental protection, was the choice of the producer and supplier of the equipment. The investor has chosen modern installations with minimal level of emitted noise. In summary it may be stated, that the layout of wind turbines has been planned in that way to achieve the following goals:

 to be located out of nature and landscape protected areas,  not to disturb the continuity of ecological corridors,  not to exceed the binding environmental noise quality standards,

Post construction monitoring Noise The environmental decision conditions oblige the investor to conduct a post construction noise level measurements and impact on the acoustically protected areas in two sessions: the first after the Building Permit has been issued but prior to the beginning of the construction phase (or, alternatively, after the wind farm has been completed but with the wind turbines switched off) and the second after the wind farm has been completed (in conditions similar to the first session). If the measurements indicate that permissible noise levels are exceeded, then noise reducing action will be necessary to be completed (i.e. reduction of the acoustic power of the subject wind turbine(s) or its temporary disconnection especially during the nighttime are should be considered).

Birds and Bats The post construction monitoring of birds and bats is required by the environmental decision. The monitoring of avifauna is to be performed in three full-year cycles including the first, second and fourth year following the wind farm’s completion. Frequency of observations should be increased to 2-3 days a week in the period of spring migration (March 1 - April 10) and in the summer (July 1 – August 20). The monitoring of birds shall include research of birds mortality and birds distribution and species composition with use of the same methodology as during the pre-investment monitoring program.

The monitoring of bats’ population is to be performed in a period of at least 3 years following the completion of the wind farm. Operation of the farm should be limited if monitoring of bats reveals significant impacts. The bats monitoring should be aimed at research of bats mortality (search for dead bats in the vicinity of wind turbines).

Both birds and bats monitoring results will be reported to RDOS in Białystok.

Environmental and Social Action Plan The developer is a newly created company which will manage construction of the wind farm and later its operations. As reported, all construction and operational tasks will be outsourced to certified and reputable companies. In order to meet the EBRD Performance Requirements as per Environmental and Social Policy (2008) and IFC Performance Standards as per International Finance Corporation’s Performance Standards on Social and Environmental Sustainability (2006), the company will need to establish and maintain

a management structure for environmental, health and safety and social issues management, as well as establish certain procedures and rules applying to service providers with respect to preparation and maintaining a program for monitoring of the construction works and then operation of the wind farm. It is proposed to develop a set of Key Performance Indicators (KPI) to monitor environmental, H&S and social matters during construction works and then operation of the wind farm. The KPIs should include but not be limited to: number and type of events that could affect environment during construction works; number and type of H&S accidents during construction works; number and type of events that could affect communities within the influence area of undertaken construction works and cargo deliveries; environmental emissions (including types and amounts of generated wastes) of the wind farm during its exploitation; number and type of H&S accidents affecting employees of the wind farm operator; number and type of accidents affecting external individuals and causing damages; number of third party grievances due to shadow flicker effect, electromagnetic impacts, noise and other impacts generated by operating wind farm.

It has been proposed to develop procedures for reporting on the project status to lenders and disclosure of information to external stakeholders. Annual reports to lenders should present among others: status of the project implementation; key performance indicators, summary of submitted grievances and description of how these have been addressed; summary of stakeholders engagement activities; environmental monitoring results and discussion; summary of actions undertaken to improve EHSS performance of the wind farm; summary of any EHSS legislative changes that may affect the project.

After completion of the construction works it has been proposed to undertake environmental monitoring in line with requirements of environmental. Should monitoring results indicate excessive impact of the wind farm develop and implement appropriate mitigation plan.

Additional information and grievance procedure The mechanism for the claim procedure will be implemented by the company as part of the project management system. The procedure assigns a coordinator of the integrated system, who will be responsible for reacting in case of complaints.

All requests for additional information related to the Wind farm should be addressed to the Environmental Specialist of the PEP Group:

Marta Porzuczek Polish Energy Partners S.A. 169 Wiertnicza Street, 02-952 Warszawa Tel: +48 22 39 08 116 Email: [email protected]