“nts” - total eren · 2020. 11. 20. · “nts” our ref.: p.016410.2004 aa 93004 ts:...
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TRACTEBEL ENGINEERING S.r.l. Viale Avignone, 12 – 00144 Rome – ITALY tel. +39 06 203990 - fax +39 06 203990 16 [email protected] tractebel-engie.com
“NTS”
Our ref.: P.016410.2004 AA 93004
TS:
Imputation:
Client : Lenders: EBRD, EIB, PROPARCO; Sponsor: TOTAL EREN
Project : 131,35 MWp Solar Tracking Bi-Facial PV project – Tutly Uzbekistan
Subject : NON-TECHNICAL SUMMARY
Comments:
01 2020/11/06 A A.JANAS G.MANCINI M.BALDINI
00 2020/09/28 I A.JANAS G.MANCINI M.BALDINI
REV. YY/MM/DD STAT. WRITTEN VERIFIED APPROVED VALIDATED
TRACTEBEL ENGINEERING S.r.l. – Company with a Sole Shareholder, Share Capital Euros 276.836,00 entirely paid up Tax Code, VAT No., Register of Companies (Chamber of Commerce of Rome) 10248651001, R.E.A 1220672. Company subject to Management and Coordination by Tractebel Engineering S.A. under article 2497 and following of the Civil Code
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P.016410.2004 RE 82001 00 2/12 CONFIDENTIAL
P.016410.2004 AA 93004 01 2/12 CONFIDENTIAL
Index
1. PROJECT DESCRIPTION ....................................................................................................... 3
Project Benefits .......................................................................................................... 4
Project cumulative impacts ....................................................................................... 4
2. IMPACTS, MITIGATION MEASURES AND SOCIAL BENEFITS ........................................... 6
Water resources ......................................................................................................... 8
Landscape and Visual Impact ................................................................................... 8
Local traffic, road safety, noise and vibration ......................................................... 8
Impacts to existing infrastructure and Public Services ......................................... 9
Consistency with Policy, Law and other plans ....................................................... 9
Social Management Plans, mitigation and compensatory measures ................. 10
Public consultations, Stakeholder Engagement Plan and Grievance Redress Mechanism ................................................................................................................ 10
3. IMPACTS MONITORING ....................................................................................................... 12
P.016410.2004 RE 82001 00 3/12 CONFIDENTIAL
P.016410.2004 AA 93004 01 3/12 CONFIDENTIAL
1. PROJECT DESCRIPTION
The European Bank for Reconstruction and Development (“EBRD”), The European
Investment Bank (“EIB”) and Proparco are considering providing financing to Total
Eren (“The Sponsor”) /Tutly Solar LLC (“The Project Owner”) for the construction
and operation of a 100 MW solar photovoltaic power plant (“the Plant”) in Tutly,
Uzbekistan. The construction phase is estimated to be completed within 12 months.
The Plant will operate for at least 25 years after which it will be either transferred to
the Government or decommissioned and the land will be returned to its original
state.
Construction of the Plant is expected to start in Q1 2021, with Commissioning of
the plant expected in Q4 2021.
The Plant will be constructed upon a piece of land (the “Project Land”) extending
over approximately 350 Ha comprised of flat arid steppe currently used by the local
population for livestock grazing. The Land is owned by the State of Uzbekistan and
has been leased to the Project Owner for the duration of the Plant’s operation.
According to Uzbek National legislation (“National legislation”) the project has been
categorised as a “Category II”, which corresponds to “medium risk of environmental
impact”. According to EBRD rating criteria, the project is classified as category B
(ESP, 2014).
The Project Owner has been granted a positive State Environmental Appraisal has
following its submission to the authorities of the first stage Environmental Social
Impact Assessment (ESIA). Prior to Commissioning of the Plant an updated version
of the ESIA will have to be filed and approved by the Authorities. Construction works
can begin without further permitting being obtained.
The precise breakdown of workers needed for the construction phase had not been
defined at the time of writing this NTS, however it is estimated that a maximum of
300 people will be engaged during the peak of construction. The operational phase
of the Project it is expected to employ 24 people of which 18 workers, and 6
administrative management staff and engineers. As part of the ESIA, the
Sponsor has developed an outline of the Environmental and Social Management
and Monitoring Plan (ESMMP) to provide the Project Owner and the EPC
Contractor with the appropriate framework. Under the ESMMP the Project Owner
will be responsible for approving appointments and contracts as well as the
appointment and supervision of the HSE Supervision Consultant.
P.016410.2004 RE 82001 00 4/12 CONFIDENTIAL
P.016410.2004 AA 93004 01 4/12 CONFIDENTIAL
Project Benefits
The Studies conducted on renewable energy in Uzbekistan show that solar energy
offers a very large potential (2058 Terawatt TW). The Project will contribute to the
Uzbek Government’s Goal to increase the Solar power to 2.3 % by 2025.
The Project will contribute to improve local power supply and reliability and will
promote economic development in the region as a result.
Further, as the Government is actively attracting the private sector to invest in
renewable energy, the success of the Project might create a precedent that will
encourage further private investment in the sector and in the Country.
The project alternatives considered include the “Do-Nothing” option and a
comparative analysis of anticipated impacts in terms of pollution from the
construction of a 100 MW fuel firing power plant.
From a socio-economic point of view, the project benefits will be evident in the
region when the additional energy availability will allow for further economic
development. The job creation will be limited to unskilled labor (temporary);
however, the local population may be incentivized to train in skilled professions
which may become useful during the lifetime of the project and beyond. Training
has been included amongst the requirements of the Environmental Social
Management Plan (ESAP) to be implemented as part of the implementation of the
Employment Management Plan.
Indirect benefits, depending on what will be defined as final plans by the Project
Owner and the Sponsor, may include access to a phreatic well providing drinking
water to the population, which currently has to rely on imported drinking water. The
Development of a Corporate Social Responsibility Programme (CSRP) would
include both financial as well as other forms of support.
Project cumulative impacts
The Project’s impacts on the environment from construction, operation and
decommissioning of the Plant have been evaluated in the ESIA, and, provided all
mitigation and monitoring measures are appropriately implemented, the majority of
identified impacts have been estimated to be of low magnitude and minor or
negligible significance.
The magnitude and significance of the Project impact on the local fauna has been
estimated to be of moderate magnitude and significance due to the presence within
the Project area of an endangered specie of Steppe Tortoise, (discussed in chapiter
2 hereunder). The Sponsor has committed to commissioning a detailed Specie
Management Plan (SMP) and a more overarching Biodiversity Management Plan
(BMP) that show a credible path to No Net Loss (NNL) to the satisfaction of the
Lenders.
P.016410.2004 RE 82001 00 5/12 CONFIDENTIAL
P.016410.2004 AA 93004 01 5/12 CONFIDENTIAL
The magnitude and significance of the impact from temporary workers
accommodation during construction and decommissioning were both estimated in
the ESIA to be Moderate. Provided that there is an implementation of a Workers
Accommodation Management Plan (WAMP) developed in line with EBRD and IFC
“Workers accommodation Process and Standard Guidance Note”, the residual
impact from temporary workers accommodation is considered minor.
The 350 Ha allocated to the Project (the Project Land) have been leased from the
State and represent 0.7% of the 52,000 Ha of available pasture land in the Tutly.
Unofficial uses comprise cattle farmers using the land for grazing. Alternative land
of equal convenience and quality has been provided for the unofficial users to
compensate for the loss of the Project Land.
Fig. 1 : Site location and distances identification
Road
Tutly 1.7 km
PV Plant area
P.016410.2004 RE 82001 00 6/12 CONFIDENTIAL
P.016410.2004 AA 93004 01 6/12 CONFIDENTIAL
2. IMPACTS, MITIGATION MEASURES AND SOCIAL BENEFITS
The impacts associated with this project are considered to be site specific and are
relatively easily assessed and mitigated. The technology that the Sponsor intends
to use is state of the art and in line with international Best Practice. The EPC
Contractor selected (soon to be appointed formally) has proven, during previous
and recent projects for the Sponsor, to have the required capacity to implement the
Lenders Performance Requirements.
Fig. 2 : Typical low vegetation and cattle grazing in the project area
The Project land is located within one of 52 existing Important Bird and Biodiversity
Areas (IBAs) in Uzbekistan, named Karnabchul Steppe (UZ018). IBAs were
created by the BirdLife, an International non-profit organization devoted to bird
conservation. An evaluation of possible negative impacts to the Karnabchul IBA
resulting from the implementation of the Project was undertaken in May 2019, the
conclusions of which are as follows:
• None of the mainbreeding avifauna species in the area are endangered;
• The project area maybe used occasionally by dispersedor migrant
houbaras;
• The solar project area is comparatively small when considered within the
project steppe area interested by birds migration;
• The impacts to migrant birds (such as houbaras) is considered very low or
negligible.
• An important population of Steppe Tortoises (Testudo horsfieldii) is
established within the Project area. This species is considered Vulnerable
A2d by IUCN.
The estimated total number of tortoises currently within the Project area site could
reach 7,830 individuals (assuming a density of 22.37 individuals per 1 ha).
P.016410.2004 RE 82001 00 7/12 CONFIDENTIAL
P.016410.2004 AA 93004 01 7/12 CONFIDENTIAL
The Karnabchul steppe extends over approximately 171,000 ha, with a density of
tortoises which varies from 7.9 to 11.5 individuals/ha (D.A.Bondarenko and others,
2017). The overall population is therefore estimated to be between 1,350,900.0 and
1,966,500 individuals.
Earth works to be undertaken between November and March 2021 will impact a
total of around 5.5 % (19ha) of the Project area. During this period the hibernated
tortoises will therefore be affected leading to an estimated loss of 123 individuals.
This represents approximately 1.6% of total population of the Project area, and less
than 0.006% of tortoises population in the Karnabchul steppe.
Assuming a 100% mortality rate (the worst-case scenario) for tortoises within the
350 ha of the Project area, the impact on a landscape-level basis is calculated at
0.58-0.4% of the tortoises population in the Karnabchul steppe.
Assuming the worse scenario, the overall loss of tortoises accounting for the total
number of Uzbek tortoises (10 mln), is considered to be negligible.
A detailed Species Management Plan (SMP) from a qualified biologist for the
tortoise that show a credible path to No Net Loss (NNL) is to be developed and
implemented by the Sponsor in collaboration with the Project Owner. This needs
to cover population estimates/modelling, loss accounting for project impacts, all
avoidance, management and mitigation measures to be implemented and show a
credible plan to achieve NNL. The Sponsor has also committed to developing a
robust biodiversity management plan (BMP), with the clear objective of NNL, and
where there is that an off-set programme to be implemented. The Sponsor has
committed to commissioning the Biodiversity Management Plan (BMP) to the
Lender’s satisfaction.
The local population (cattle farmers and other unofficial users of the Project Land)
has been provided with access to pasture-land of equal quality, distance and
accessibility compared to the Project area, which means that the residual impact
on the local population in Tutly is negligible.
Local residents and services providers might benefit from the Project as demand
for employment of unskilled workers and requirement for services associated with
the Project’s implementation are expected to arise as a consequence of the Project.
The EPC contractor will be required to implement a Labour and Employment
Management Plan (LEMP) in line with EBRD PRs in order to maximise bringing
project benefits to the local community. Although many skilled workers will have to
be brought from abroad or outside the local area, there will be a transfer of
knowledge to local contractors, and local population might be encouraged to train
in areas relevant to the project (e.g. electricians and operators). A number of
villages located within approximately 17 km radius from Tutly will benefit from the
positive impacts of the Project as a result of increased employment and business
(supply of goods and services) opportunities.
A more reliable supply of power and decrease in the power deficit in the region may
stimulate growth and investment.
P.016410.2004 RE 82001 00 8/12 CONFIDENTIAL
P.016410.2004 AA 93004 01 8/12 CONFIDENTIAL
Water resources
Within the Tutly settlement there are no available sources of drinking water for the
population and/or livestock. Drinking water is delivered by water trucks from the
Tim settlement, 40 km from Tutly. Each household is usually provided with concrete
water tanks, and abstracts water for livestock watering from the superficial aquifer
(approximately 20 m depth), which can be saline.
The superficial geology comprises sandy loams, which are relatively permeable.
There is an uneven distribution of precipitation throughout the year.
According to the residents of the Tutly settlement, the Project Land is located on
the path of mudflows that occur mainly from March to April. Mudflows 10-50 cm
high flow through the natural lowland from the mountains on the western side of the
project area and reach the village of Tutly. There is a risk that, if inappropriate
drainage is implemented, the mudflow diverted from the Project area, could impact
the residential areas of Tutly. Therefore, particular care must be taken to design an
adequate drainage system.
A small risk of localised ground contamination might arise as a result of the
construction works as a result of machinery refuelling or maintenance, as well as
possible water treatment activities and waste-water storage. However, this can be
minimised by appropriate use of adequate secondary bunding to relevant storage
tanks.
Landscape and Visual Impact
The topography of the project land and surrounding is flat with no neighbouring
sensitive uses including no aircraft landing strips in the immediate vicinity. The
potential issues associated with glare and glint caused by sunlight reflected off the
PV panels are considered low due to the design of the panels and the intended use
of antiglare coating.
Local traffic, road safety, noise and vibration
Accidents as a result of the increased traffic might increase on the roads near the
Project Area and to and from the Tutly settlement and the city of Navoi. However,
the project land is flat and visibility, except during dust storms (during which it is not
envisaged to carry on construction activities), is good. The development and
implementation of a Construction Traffic Management Plant (CTMP) by the EPC
contractor will contribute to mitigating all risks from traffic generated during the
construction phase.
The implementation of measures specified in the CEMP to be developed by the
EPC contractor as well as implementing best practice for the use and storage of
hazardous chemicals, management of waste from construction activities as well as
waste and wastewater from the workers accommodation compounds should
mitigate the risks of contamination.
P.016410.2004 RE 82001 00 9/12 CONFIDENTIAL
P.016410.2004 AA 93004 01 9/12 CONFIDENTIAL
The relative permeability of the superficial geology and the presence of superficial
groundwater means that frequent spillages might have an impact in the Project
Ares, which can be minimised by the implementation of the above.
Impacts to existing infrastructure and Public Services
The Settlement of Tutly and the neighbouring settlements do not have health
centres and the residents have limited access to trained medical staff. The
implementation of the Project, particularly in light of the COVID pandemic,
would require addressing the issue of sanitary conditions and availability of
medical staff for the project Workers. The implementation of an appropriate
Corporate Social Responsibility Plan (CSRP) which includes a programme for
enhancing the health infrastructure in the Tutly settlement might result in a
positive impact and provide the residents with increased access to trained
health workers. It should be noted that the SCRP is a developer initiative not an
EBRD requirement and EBRD will not provide any input nor funding towards it
and will not manage nor monitor its output.
The poor state of the roads represents one of the major issues in the Project
area. The implementation of the Project might result in a positive impact as a
result of roads maintenance associated with the construction works (prior to and
after completion) providing newly-paved roads and improved infrastructure to the
Project Area. Villages considered likely to benefit from such positive impacts
include: Gubdin-Obdun, Zhiydalik Sahkoba and Kurgancha.
Consistency with Policy, Law and other plans
The Studies conducted on the potential of renewable energy in Uzbekistan show
that the solar energy potential offers a very large potential (2058 Terawatt TW).
Accordingly, the Presidential Decree No. PP-3012 of the 26th May 2017 on the
Measures for Further Development of Renewables and Energy Efficiency and the
Social Sphere for 2017-2021 has been adopted. The Project will contribute to the
Uzbek Government’s Goal to increase the Solar power to 2.3% by 2025.
The Project will contribute to improve local power supply and reliability and will
promote economic development in the region as a result.
Further, as the Government is actively attracting the private sector to invest in
renewable energy, the success of the Project might create a precedent that will
encourage further private investment in the sector and in the Country.
P.016410.2004 RE 82001 00 10/12 CONFIDENTIAL
P.016410.2004 AA 93004 01 10/12 CONFIDENTIAL
Social Management Plans, mitigation and compensatory measures
Amongst the measures that the Sponsor is considering there is drilling a phreatic
well for the population of Tutly which would provide drinking water from the deeper
aquifer (200 m depth). This would allow the population to have access to better
quality water and would be a positive impact of the project.
An Environmental and Social Management and Monitoring Plan (ESMMP) will be
developed by the Sponsor (in collaboration with Tutly Solar LLC) and provide the
framework for the EPC Contractor’s development of a clearly defined
Environmental and Social Management System (ESMS). Tutly Solar LLC will be
responsible, amongst others, for obtaining all relevant permits for construction,
development and implementation of relevant E&S plans, review and monitor the
compliance of the EPC’s ESMS and all associated Management plans.
A CSRP shall be developed and agreed with Sakhoba MRG with a view to help the
local community. This will have to fit within the allocated CSRP budget, avoid
overlap with State programmes, and be sustainable or lead to job creation. For
example, as stated above, the CSRP could support the creation of a rural health
centre accessible to the local residents, help in providing drinking water for the
population, maintain roads. The female members of the public consulted requested
the construction of a public bakery. The degree of support and the budget allocation
must be proportionate to the Project and the financial standing of the Project Owner.
Public consultations, Stakeholder Engagement Plan and Grievance Redress Mechanism
A Stakeholder Engagement Plan (SEP) has been provided by the Sponsor and
disclosed to the Lenders. The SEP provides an organisational structure to support
Tutly Solar LLC (the project owner) who will be the executing agency in delivering
all stakeholder engagement activities.
Tutly Solar LLC undertook official consultations with stakeholders in May, August
and December 2019, and in February and August 2020. Consultations with the
population of the Tutly settlement were undertaken on the 21st December 2019 (for
which 39 participants signed the registration list) and another one on the 21st of
August 2020 (to which 9 households representatives attended). Questions
regarding the impacts on pasture land availability were raised during the meetings.
A formal complaint regarding the land allocation was lodged with the authorities;
the issue was resolved by granting the local population additional area for grazing
their livestock 1 km far from the settlement, at the lands owned by Tutly Korakul
Zamini LLC (who did not object to this decision).
P.016410.2004 RE 82001 00 11/12 CONFIDENTIAL
P.016410.2004 AA 93004 01 11/12 CONFIDENTIAL
A Grievance Redress Mechanism (GRM) has been established for the Project
taking into account the Uzbek national legislation, the specificity of the project
sites, and the results of public consultations. In addition, the Sponsor
undertakes to ensure that the GRM is developed and implemented accordance
with related policies of IFIs such as EIB, EBRD, WB.
The formal complaint filed by the local residents has been redressed by relying on
the existing GRM, and, according to interviews with local herders, the grievances
have been resolved to the satisfaction of the interested parties. The Sponsor has
undertaken to seek obtaining a formal agreement documenting the resolution
of the issues raised in the complaint.
The ESAP requires the Sponsor and the Project owner to implement a range of
management plans to be developed and implemented for, amongst others,
Environmental, Social, Occupational Health and Safety, Construction, Safety and
Bio-diversity Management plans. The EPC Contractor is required to develop and
implements EHS / OHS management plans in line with the Sponsor’s and the
Lenders requirements and, the Sponsor is required to Monitor and report on the
EPC Contractor’s performance against the set Policies and KPIs. The Sponsor is
required to develop and implement a specific Specie Management Plan with the
objective of achieving No Net Loss of the tortoises in the Project Area. The ESAP
sets requirements for reporting to EBRD and publish information regarding the
Project’s progress, as well as the results of surveys and monitoring programmes.
In addition, the Sponsor is required to Develop a Community Development Strategy
and Corporate Social Responsibility (CSR) Programme, establish a budget for it,
and report its implementation to stakeholders and Lenders.
P.016410.2004 RE 82001 00 12/12 CONFIDENTIAL
P.016410.2004 AA 93004 01 12/12 CONFIDENTIAL
3. IMPACTS MONITORING
Tutly Solar LLC (and the EPC Contractor) will have to develop and implement a
Construction Environmental and Social Management Plan (CESMP) which will
provide for workers awareness and training sessions in relation to the protection of
the local fauna.
Construction will be monitored weekly through the implementation of the above
plans and mechanisms. During the Operation phase, monitoring will be undertaken
monthly. Annual reports on the environmental and social performance as well as
grievances will provide the ongoing view of the performance of the implementation
of the Project against the plans. The reports will be checked against the Lenders
requirements and monitoring will be undertaken throughout the lifespan of the
Project.
This Non-Technical Summary and the Stakeholder Engagement Plan (SEP) will be
published prior to approval of the Lenders. The SEP provides a mechanism for
engaging with all stakeholders as well as the disclosure mechanisms for all relevant
information regarding the Project.
The Community Liaison Officer (CLO, which will be appointed in due time) will
manage communications amongst all stakeholders and ensure that an appropriate
grievances mechanism provides an efficient method of redress.
The GRM has been designed and will be disclosed as soon as possible and remain
available for review at the Project site, on the information boards in the Tutly
settlement as well as on the Project Owner’s website.
Further information can be obtained from the Project Owner’s Manager Ms. Ayzada
Seitniyazova, who is currently acting as CLO, until a separate appointment to this
role is made by the Sponsor/Project Owner.