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SUVOROVO WIND FARM – STAKEHOLDER ENGAGEMENT PLAN
1. INTRODUCTION
Suvorovo Wind Farm (further in this document “ the Project ”) is the pioneer project of utility scale wind farm developed by Eolica Bulgaria A.D., (further in this document “ the Company ”) company created as a joint venture between Spanish Grupo Enhol’s international branch Generación Eólica Internacional, S.L., and the Bulgarian company Balkars Consortium.
The project is located in the municipality of Suvorovo, 30 km inland from the Black Sea, and about 20 km from the city of Varna, second populated city of Bulgaria and main commercial harbour of the country. Because of the location, the wind farm benefits from an easy access by sea for heavy transports related to multi-megawatt turbines. The Project will be composed of following infrastructures:
• 30 × Gamesa G90/2MW wind turbines, 80 m hub height and linked by 20kV underground grid connecting to substation.
• 110/20kV Suvorovo WF electrical substation.
• 110kV Power line from Suvorovo Substation to NEK’s ValchiDol substation with connecting equipment at ValchiDol.
• Access roads (involving the upgrade of the local road from Suvorovo and agricultural tracks within the site area to accommodate construction traffic).
• Construction/lay-down facilities, likely to be situated on an adjacent disused airfield.
• Local offices and accommodation for construction workers in Suvorovo.
• Small site for the disposal of excess excavated materials just north of Suvorovo.
The Project started in 2004, when some of the Bulgarian administrative procedures related to the project where not still fully developed. Due to this, the general procedures for wind farm development in Spain were used as guidelines, paying special attention to those subjects (environment, public information) that are key in countries where wind power is widely implemented. A bird monitoring programme was undertaken during years 2005-2006, and the Environment Impact Assessment (EIA) was completed in April 2006. The Project has been fully developed according to the Bulgarian legal framework, and two separate procedures have been followed, one to secure consent for the wind farm and substation (subject to the EIA), and a second to secure consent for the 110kV overhead power line (not subject to the EIA).
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The Company is an investor in the Project and brings a strong commitment to disclosing information relating to the Project, increasing public awareness of wind power in general and Suvorovo Wind Farm in particular, and to understand and address any issues raised by stakeholders, particularly those that will be affected by the project.
The Stakeholder Engagement Plan hereby intends to be a compilation of those public information activities carried out by the Company, a definition of procedures that will be further used to communicate with stakeholders from planning through to construction and operation, and a mechanism for anyone who wishes to raise a concern or grievance in relation to the Project.
2. REGULATORY REQUIREMENTS
Public consultation on the Project to date has been undertaken in compliance with Bulgarian laws and specific requirements set by the Regional Inspectorate for Environment and Water. These requirements refer to both consultations on the wind farm (wind turbines & substation) and 110kV power line.
The EIA of the Project was carried out according to Bulgarian Environment Protection Act 2002, and public consultation have been held as per Article 95 of this Act, as elaborated in the section 4 (only the wind farm was subject to this process).
In addition to this, the Regional Inspectorate for Environment and Water of Varna (RIOSV Varna in Bulgarian) stated in letter 656/13.2.2006 that specific consultations had to be held with:
• Regional Directorate for Agriculture and Forest
• NEK – for possibility of connection to electric grid
• National Institute for Monuments and Culture
• Ministry of Health
• Geozashtita EOOD
The permitting process of the 110kV power line has included a wide consultation with stakeholders, as it involves different municipalities (Suvorovo, ValchiDol), communication infrastructures (roads and railway) and strategic infrastructures such as HV electric grid and gas pipes. Environmental stakeholders have also been involved including the RIEW and the Forest Council.
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3. OTHER REQUIREMENTS
The guidelines followed by Eolica Bulgaria on public consultation, as part of a wider process as the Environment Impact Assessment, come from the know-how of the main shareholder, Grupo ENHOL, about the wind power market in Spain.
In addition to Bulgarian requirements, the EU Directive 96/61/CE “Integrated Control and Prevention of Pollution” has been followed for public information and consultation, the EBRD performance requirements (in particular PR 10) and the detailed guidelines available under Spanish requirements (Act 16/2002) have been used as good international practice.
4. SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES
The environment permitting process that lead to public information and consultation started after the confirmation by Regional Inspectorate RIOSV Varna by letter 13.01.2005 that an EIA was required for the wind farm element of the Project. After the formal application was submitted, the Regional Inspectorate set by 13.2.2006 the requirements on the Environment Study, and specific consultations to affected parties:
• Regional Directorate for Agriculture and Forest
• NEK – for possibility of connection to electric grid
• National Institute for Monuments and Culture
• Ministry of Health
• Geozashtita EOOD
In addition to these stakeholders identified by Regional Inspectorate, Eolica Bulgaria requested the opinion of the NGOs Bulgarian Society for Bird Protection BDZP – Birdlife, and Wilderness Fund about the possibility of building a wind farm in Suvorovo area.
The process of disclosure for the wind farm has been arranged with direct communication to the Municipality of Suvorovo, publication in the official gazette and meeting held on 12.10.2005 in hall 3 of Suvorovo Town Hall. Minutes of this meeting are available on request. Further to this meeting, Municipality of Suvorovo arranged a new meeting on 5.07.2006 in order to increase the public knowledge about the project and the project has been discussed at several meetings of the Municipal Council. These meetings are open to the public and transmitted on local Satellite TV
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Municipality of Suvorovo supported strongly in communicating to landowners, due to the big number of landowners that made difficult to reach all of them directly. The landowners do not make a direct usage of their plots, they are grown by several cooperatives and major farmers. These are identified stakeholders and have been
Overhead 110kV power line
The procedure of the 110kV power line, which has been separately developed on behalf of NEK, was arranged 2 years later than start of activities for the wind farm element of the Project. As the line affects more than one municipality (in this case, ValchiDol and Suvorovo), the procedure is applied in the Regional District of Varna, as higher level Authority. The Regional Inspectorate for Environment and Water has confirmed that no EIA was required for the power line project, based on the minor impact of the design accepted and the choice of route, which parallels an existing road, railway and power line as far as possible).
In a meeting held on 30.3.2007 in the city of Varna, the engineering company El-Konsult EOOD submitted for consideration 3 different route proposals. The stakeholders involved in the discussion and decision were:
• The Deputy Government of the District of Varna • The office of Regional Development Ministry in Varna • The mayors and experts of municipalities of Suvorovo and Valchi Dol • The Spatial Zoning Plan offices of ValchiDol and Suvorovo • The Municipality Property office of Suvorovo • The local offices in ValchiDol and Suvorovo of the Ministry of Agriculture and Forest • The electric distribution grid company of the region of Varna • Fire Protection Department of Varna • Railway office of the District of Varna • Road & Transport office of the District of Varna • The Regional Inspectorate for Environment and Water (RIOSV) of Varna • The Regional Inspectorate for Public Health (RIOKOZ) of Varna • Varna District office of NEK EAD • Varna District office of Bulgargaz
As result of the discussion, one of the three different proposals was accepted, and the Spatial Zoning Plan (PUP) of ValchiDol and Suvorovo has been updated according to this power line design. The process of approval of the new PUP requires public consultation by publication in the
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Because the accepted route design follows an existing (railway, roads and power line Eolica Bulgaria has requested the formal opinion of the relevant infrastructure companies.
5. IDENTIFICATION OF STAKEHOLDERS AND COMMUNICATION METHODS
In order to ensure a well implemented Stakeholder Engagement Plan, the Company has identified several groups of stakeholders, each one with different characteristics and sensitivities that dictate the type of approach required in terms of communication and feedback mechanisms. Stakeholders are presented in the table below and, for each group and members of the groups, anticipated issues have been identified along with the relevant location of EIA and relevant information, and how communication will be undertaken between the Company and the groups/members.
The responsibilities and terms for communications are set in accordance to the sensitivities of each group, and defined as follows:
Companies – Administrative Bodies & Authorities – Municipalities
Answer: Project Manager Eolica Bulgaria (B. Bakalov) Decision: General Manager Eolica Bulgaria (S. Burhanlarski) Terms: Deadlines for disclosure of information those described in point 6 of the Plan hereby. Reaction deadlines are set as follows (in labour days): • Registering of Communications: 1 day • Study & Decision: 3 days • Answer: 1 week (or less if required by request)
Sensitive Population - Organisations
Answer: Site Engineer Eolica Bulgaria (H. Marinov) Decision: General Manager Eolica Bulgaria (S. Burhanlarski) Terms: Deadlines for disclosure of information those described in point 6 of the Plan hereby. Reaction deadlines are set as follows (in labour days): • Registering of Communications: 3 days
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• Study & Decision: 1 week • Answer: 2 weeks
Internal Stakeholders & Contractors
Answer: Project Manager Grupo ENHOL (J. Basurte) ( Spanish & English ) Project Manager Eolica Bulgaria (B. Bakalov) ( Bulgarian ) Decision: Project Manager Grupo ENHOL (J. Basurte) Terms: Deadlines for disclosure of information those described in point 6 of the Plan hereby. Reaction deadlines are set as follows (in labour days): • Registering of Communications: 3 days • Study & Decision: 1 week • Answer: 2 weeks
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5.1. Companies
STAKEHOLDER Relevant Issues Location of EIA Materials Communication/ Stage Deadline MEDIA BULGARGAZ Construction Plan, grievance Suvorovo Town Hall Official letter Construction 7 August 09 mechanism. Nesavisimost. 1 - Suvorovo Phone 05153 2160 BTK Construction Plan, grievance Suvorovo Town Hall Official letter Construction 7 August 09 (Telecommunications) mechanism. Nesavisimost. 1 - Suvorovo Phone 05153 2160 NEK EAD Construction Plan, grievance Eolica Bulgaria Official letter Construction 7 August 09 mechanism. Coordination. Bacho Kiro 26-30 - Sofia Regular meetings Monthly Phone 029887111 Regular meetings Operation 3 Monthly www.eolica-bg.com Italcementi Devnya Construction Plan, Transport Suvorovo Town Hall Official letter Construction 7 August 09 Plan, grievance mechanism. Nesavisimost. 1 - Suvorovo Phone 05153 2160 Solvay Devnya Transport Plan, grievance Suvorovo Town Hall Official letter Construction 7 August 09 mechanism. Nesavisimost. 1 - Suvorovo Phone 05153 2160
5.2. Administrative bodies & authorities STAKEHOLDER Relevant Issues Location of EIA Materials Communication/ Stage Deadline MEDIA Varna District Power Line Construction Plan, Suvorovo Town Hall Official letter Construction 7 August 09 Authority for Roads grievance mechanism. Nesavisimost. 1 - Suvorovo Official letter Constrc. PL 25 August 09 Phone 05153 2160
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Varna District Power Line Construction Plan, Suvorovo Town Hall Official letter Construction 7 August 09 Railway grievance mechanism. Nesavisimost. 1 - Suvorovo Official letter Constrc. PL 25 August 09 Phone 05153 2160 Varna District Fire Construction Plan, grievance Suvorovo Town Hall Official letter + meeting Construction 7 August 09 Department mechanism, HSEL dossier. Nesavisimost. 1 - Suvorovo Official letter + meeting Constrc. PL 25 August 09 For operation : Emergency Plan Phone 05153 2160 Meeting Operation TOC week Regional Construction Plan, Power Line (directly submitted) Official letter + meeting Construction 7 August 09 Inspectorate for Construction Plan, grievance Official letter + meeting Constrc. PL 25 August 09 Environment and mechanism Water (RIOSV) For operation : Follow up Regular meeting (first 2 Operation 3 Monthly reports years) Regional Construction Plan, grievance Suvorovo Town Hall Official letter + meeting Construction 7 August 09 Inspectorate for mechanism, HSEL dossier. Nesavisimost. 1 - Suvorovo Official letter + meeting Constrc. PL 25 August 09 Health (RIOKOS) For operation : Emergency Plan Phone 05153 2160 Meeting Operation TOC week Regional and Local Construction Plan, Power Line Suvorovo Town Hall Official letter Construction 7 August 09 Offices of Agriculture Construction Plan, grievance Nesavisimost. 1 - Suvorovo Official letter Constrc. PL 25 August 09 & Forest mechanism Phone 05153 2160 Regional Office of Construction Plan, Power Line Suvorovo Town Hall Official letter Construction 7 August 09 Ministry of Local Construction Plan, Transport Nesavisimost. 1 - Suvorovo Official letter Constrc. PL 25 August 09 Development Plan, grievance mechanism Phone 05153 2160 Varna Region Construction Plan, Power Line Suvorovo Town Hall Official letter Construction 7 August 09 Government Construction Plan, Transport Plan, grievance mechanism Nesavisimost. 1 - Suvorovo Official letter Constrc. PL 25 August 09 Phone 05153 2160
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energía EOLICA BULGARIA AD 5.3. Municipalities STAKEHOLDER POP. Relevant Issues Location of EIA Materials Communication/ Stage Deadline MEDIA
Suvorovo 5.000 Construction Plan, Suvorovo Town Hall Notification on public Construction 7 August 09 Municipality Power Line bulletin board. Construction Plan, Nesavisimost. 1 - Suvorovo Regular meetings. Transport Plan, Phone 05153 2160 Monthly grievance mechanism Besti Suvorovo www.suvorovo.bg newspaper
Presentation to local www.eolica-bg.com council meetings, as required. Operation Meeting at TOC
3 Monthly ValchiDol 3.600 Power Line ValchiDol Town Hall Notification on public Constrc. PL 7 August 09 Municipality Construction Plan, bulletin board. Transport Plan, Hristo Botev. 1 - ValchiDol grievance mechanism Phone 05131 2317 Letter + meeting www.valchidol-bg.com Ekip 2000 newspaper
www.eolica-bg.com Shtipsko 260 Construction Plan, ValchiDol Town Hall Notification on public Construction 7 August 09 Municipality grievance bulletin board. mechanism. Hristo Botev. 1 - ValchiDol Letter Phone 05131 2317 www.valchidol-bg.com Ekip 2000 newspaper
www.eolica-bg.com
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Drondar 280 Construction Plan, Suvorovo Town Hall Notification on public Construction 7 August 09 Municipality grievance bulletin board. mechanism. Full Nesavisimost. 1 - Suvorovo dossier available in Phone 05153 2160 Letter Suvorovo. Besti Suvorovo newspaper www.eolica-bg.com Devnya 9.450 Construction Plan, Suvorovo Town Hall Notification on public Construction 7 August 09 Municipality grievance bulletin board. mechanism. Nesavisimost. 1 - Suvorovo Phone 05153 2160 Letter + meeting www.suvorovo.bg
www.eolica-bg.com Chernevo 1.275 Construction Plan, Suvorovo Town Hall Notification on public Construction 7 August 09 Municipality grievance bulletin board. mechanism. Nesavisimost. 1 - Suvorovo Phone 05153 2160 Letter + meeting www.suvorovo.bg
www.eolica-bg.com
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5.4. Sensitive population STAKEHOLDER POP Relevant Issues Location of EIA Materials Communication/ Stage Deadline . MEDIA Farmers on site 1 Construction Plan, Suvorovo Town Hall Direct meeting Construction 7 August 09 near airdrome grievance mechanism Nesavisimost. 1 - Suvorovo Besti Suvorovo Phone 05153 2160 newspaper www.suvorovo.bg
www.eolica-bg.com Abandoned fish 1 Construction Plan, Suvorovo Town Hall Direct meeting Construction 7 August 09 farm nearby WTG grievance mechanism. Nesavisimost. 1 - Suvorovo Besti Suvorovo 6 Phone 05153 2160 newspaper www.suvorovo.bg
www.eolica-bg.com WTG Landowners 30 Construction Plan, Suvorovo Town Hall Direct meeting Construction 7 August 09 grievance mechanism. Nesavisimost. 1 - Suvorovo Besti Suvorovo WTG land payments Phone 05153 2160 newspaper www.suvorovo.bg
www.eolica-bg.com
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Agriculture - Construction Plan, Suvorovo Town Hall Direct meeting Construction 7 August 09 cooperatives Transport Plan, grievance Nesavisimost. 1 - Suvorovo Besti Suvorovo growing in the site mechanism Phone 05153 2160 newspaper “Brazdi” Agrarian Crop losses compensation agreement Cooperative www.suvorovo.bg “Harvatovi” OOD www.eolica-bg.com BG Agro agriculture Co. AC “Veliko Zlatev Chovanov” Ianka Mihaleva Ani Liubenova Residents near Construction Plan, Power ValchiDol Town Hall Notification on public Constrc. PL 25 August 09 the power line Line Construction Plan, bulletin board grievance mechanism Hristo Botev. 1 - ValchiDol Phone 05131 2317 Ekip 2000 newspaper www.valchidol-bg.com
www.eolica-bg.com Residents near Construction Plan, Suvorovo Town Hall Notification on public Construction 7 August 09 grievance mechanism the proposed Nesavisimost. 1 - Suvorovo bulletin board office/residential Besti Suvorovo accommodation Phone 05153 2160 newspaper and the inert www.suvorovo.bg waste site in Suvorovo. www.eolica-bg.com
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5.5. Organisations STAKEHOLDER Relevant Issues Location of EIA Materials Communication/ Stage Deadline MEDIA BDZP Birdlife Impacts to birds, bats. www.eolica-bg.com Direct meeting, web Construction 7 August 09 Construction Plan, Environment follow up, grievance mechanism. Operation 1 month before For operation : Monitoring TOC & Mitigation measures follow up Wilderness Fund Construction Plan, www.eolica-bg.com Direct meeting, web Construction 7 August 09 Environment follow up, grievance mechanism. 1 month before TOC For operation : Monitoring Operation & Mitigation measures follow up Zeleni Balkani Construction Plan, www.eolica-bg.com Direct meeting, web Construction 7 August 09 association* Environment follow up, grievance mechanism.
For operation : Monitoring Operation 1 month before & Mitigation measures TOC follow up Bulgarian Academy Construction Plan, www.eolica-bg.com Direct meeting, web Construction 7 August 09 of Sciences Environment follow up, grievance mechanism. For operation : Monitoring Operation 1 month before & Mitigation measures TOC follow up
5.6. Internal stakeholders STAKEHOLDER POP. Relevant Issues COMMUNICATION Methods Eolica Bulgaria employees 5 Plans and follow up. Monitoring and Electronic bulletin performance records. Grievance
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energía EOLICA BULGARIA AD Dimitrina Koleva mechanism Contracts [email protected] HR procedure Internal Communication procedures
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Grupo ENHOL employees 40 Plans and follow up. Monitoring and Electronic bulletin performance records. Grievance Cirstina Añon mechanism HR procedure [email protected] Internal Communication procedures Contractors - HSEL policy and requirements Formal written communication. (contract), environment requirements, grievance mechanism Contracts. Bulletin board on site with notices posted. www.grupoenhol.es Supervisor briefings/ Toolbox www.eolica-bg.com talks http://www.eolica-bg.com
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6. DISCLOSURE OF INFORMATION
Eolica Bulgaria, in the role of developer and investor, intends to set a good knowledge of both the Project and wind power in general. Therefore Suvorovo Wind Farm project is intended to be shown by the Company as an example of good practice in development of wind power, with the aims to involve stakeholders and to keep good communication practises during the lifetime of the project.
According to this strategy, the target of the information disclosure and communication will be:
• To provide to local communities a schedule and information on activities that will be arranged, together with the mechanisms for their feedback.
• To improve the knowledge of what the wind farm project involves, with all stages and expected performance.
• To make public the commitment of the company to ensure the best practices in terms of environment protection and health & safety for workers and contractors.
• To make available to the public a grievance procedure, in order to collect the negative feedback and to act in correcting the causes that may lead to a negative opinion on wind power and the Suvorovo Wind Farm in particular.
The information disclosure up to date has been mainly by direct official communication to affected parties and entities. Such procedures will be also used for start of construction, by providing access to all stakeholders to the following information:
1. Environment and Social Impact Assessment and its Non-technical Summary (NTS).
2. The Stakeholder Engagement Plan, including grievance mechanism (SEP).
3. Environmental and Social Action Plan (ESAP).
4. Health and Safety Policy, including Company’s contractor requirements.
5. Grievance mechanism.
All of them are or will be available to public on company’s webpage http://www.eolica-bg.com , and also in parent company’s http://wwwgrupoenhol.es .
Term : the dossier of information of points 4 & 5 was made available by 15 th July. Deadlines for rest of information are:
SEP – 29.07.2009
NTS – 31.07.2009
ESAP – 7.08.2009
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energía EOLICA BULGARIA AD Additionally, those stakeholders that are directly involved in the activities of construction will be granted access to following information:
6. Construction Plan.
7. Power Line Construction Plan.
8. Transport Plan.
This information will be directly provided to interested stakeholders in written format, including direct meeting in case of municipalities and local individuals.
Term : The dossiers of points 6 to 8 will be provided to relevant stakeholders during first week of August (3.08.2009 to 9.08.2009)
Follow up information such as internal bulletins and follow-up reports will be forwarded to stakeholders on two month basis during construction stages, and yearly basis after start of operation.
7. GRIEVANCE MECHANISM
Eolica Bulgaria will implement a grievance mechanism to ensure that it is responsive to any concerns or complaints, particularly from affected stakeholders and communities. Special care will be taken in the training of company staff regarding the stakeholders’ opinion and communication mechanisms. An outline of the process of the mechanism is given in Annex 2 below.
As an integral part of this process, the commitment of the Company is to process all written grievances, and to process verbal grievances from local communities and individuals. Every grievance will be acknowledged within one business week, and will be answered in three business weeks.
The grievance form will be assigned to a staff member and will be available from relevant local authorities, as well as the company, and the website. A digital form will be implemented in Bulgarian in Eolica Bulgaria’s web page ( http://www.eolica-bg.com ) and is available in Annex 1
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energía EOLICA BULGARIA AD Annex 1 - Public Grievance Form
Reference No: Full Name
Contact Information By Post: Please provide mailing address: ______Please mark how you wish ______to be contacted (mail, telephone, e-mail). By Telephone: ______
By E-mail ______
Preferred Language for Bulgarian communication English
Description of Incident or Grievance: What happened? Where did it happen? Who did it happen to? What is the result 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: ______
Dimitrina Koleva, Assistant , EOLICA BULGARIA AD Please return this form to: Bacho Kiro str. No. 26-28-30 Business Center ‘PLATINIUM PLAZA’ block 1, 3rd floor 1000 SOFIA [email protected]
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energía EOLICA BULGARIA AD Annex 2 - Grievance Procedure Chart
Complaint / suggestion
TO COMPLAINANT
Record (complaint Reception form & date log) acknowledge + answer
Analyse & open Non Conformity
YES NO Corrective Action plan required?
Define Corrective Inmediate Action Plan: Corrective Action * tasks * responsible * schedule
Implementation & follow - up
NO YES
Succesful?
Communication Close to complainant Non Conformity
Record + “Lessons from experience”
End
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