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6.18.09074.GLA.R.002

B1

East Renewable Energy AB

Syvash Wind Farm

Preliminary Environmental and Social Management Plan

04 May 2018

[Subject]

Syvash Wind Farm - Preliminary Environmental and Social Management Plan

Report Details

Client: East Renewable Energy AB

Client Contact: Boerge Tvorg

Report Distribution:

East RenewableEnergy AB:

Boerge Tvorg, Thorstein Jenssen

Wood: Chris Parcell, File

Report Classification:

Confidential

Approval Record

Name Job Title Signature

Prepared by: Vicky McLean Senior Consultant SIGNED

Reviewed by: Suzy Yendell Senior Consultant SIGNED

Authorised by:Chris Parcell

Director of Feasibility and Development

SIGNED

Date of issue: 04 May 2018

Amendment Record

Revision Number Date Summary of Amendments Purpose of Revision

A1 26/04/2018 n/a First draft

A2 01/05/2018 Minor amendments following review

Internal authorisation

B1 04/05/2018 Minor amendments following authorisation

Client issue

NOTICE

6.18.09074.GLA.R.002 Revision B1 Page 1 of 54

Certified to ISO 9001, ISO 14001, OHSAS 18001 and ISO17025


This document entitled Preliminary Environmental and Social Management Plan, document number 6.18.09074.GLA.R.002 B1 has been prepared solely for East Renewable Energy AB in connection with Syvash Wind Farm . This document in whole or in part may not be used by any person for any purpose other than that specified, without the express written permission of Wood Group UK Limited.

Any liability arising out of use by a third party of this document for purposes not wholly connected with the above shall be the responsibility of that party who shall indemnify Wood Group UK Limited. against all claims costs damages and losses arising out of such use.




Contents

1 Introduction..........................................................................6

1.1 Aims and Scope of the Environmental and Social Management Plan (ESMP).....6

1.2 Implementation of the ESMP.................................................................................6

1.3 Structure of the ESMP...........................................................................................7

2 East Renewable Energy AB Environmental and Social Policy....8

2.1 East Renewable Energy AB’s Commitment...........................................................8

2.2 Providing a Healthy and Safe Working Environment.............................................8

2.3 Public Safety..........................................................................................................9

2.4 Community Engagement.......................................................................................9

3 Roles and Responsibilities...................................................10

3.1 Corporate Management Structure.......................................................................10

3.2 Responsibilities....................................................................................................10

3.3 Contact Details.....................................................................................................11

3.3.1 East Renewable Energy AB LLC...................................................................11

3.3.2 EPC Contractor..............................................................................................11

3.4 Environmental Management Plan (EMP).............................................................11

3.4.1 East Renewable Energy AB...........................................................................11

3.4.2 EPC Contractor..............................................................................................11

3.4.3 Plan Hierarchy................................................................................................13

4 Compliance with Legal Requirements...................................14

4.1 Ukrainian Legislation............................................................................................14

4.2 International Criteria.............................................................................................14

5 Environmental and Social Baseline.......................................15

5.1 Summary of Site Environmental Conditions........................................................15

5.1.1 Landscape Conditions....................................................................................15

5.1.2 Terrestrial Ecology.........................................................................................15

5.1.3 Birds...............................................................................................................17

5.1.4 Hydrology and Hydrogeology.........................................................................19

5.1.5 Geology and Soils..........................................................................................20




5.1.6 Cultural Heritage............................................................................................20

5.1.7 Noise..............................................................................................................21

5.1.8 Transportation................................................................................................21

5.1.9 Socio-Economic Conditions...........................................................................22

5.2 Overview of Construction Works..........................................................................22

5.3 Potential Environmental and Social Impacts and Mitigation................................24

6 Management and Mitigation Measures.................................46

6.1 General Management Approach..........................................................................46

6.1.1 Management Awareness...............................................................................46

6.1.2 Grievance and Incident Procedures...............................................................47

6.1.3 Environmental Audits.....................................................................................47

6.1.4 Project Environmental Committee.................................................................48

6.1.5 Occupational Health and Safety....................................................................48

7 Monitoring of Environmental and Social Performance............51

7.1 Monitoring Programme........................................................................................51

7.2 Key Performance Indicators.................................................................................51

7.3 Reporting..............................................................................................................51

8 ESMP Review......................................................................52

8.1 Scheduling and managing reviews......................................................................52

9 Record Keeping...................................................................53

Tables

Table 3-1: Summary of Environmental and Social Impacts (TBC).................................14

Table 5-1: Summary of Impacts and Mitigation..............................................................25




Glossary

Abbreviation or Term Definition

BOP Balance of Plant

EBRD European Bank of Reconstruction and Development

EHS Environment, Health and Safety

EIA Environment Impact Assessment

EPC Engineering, Procurement and Construction

EPs Equator Principles

ESAP Environmental and Social Action Plan

ERE-AB East Renewable Energy AB

ERP Emergency Response Plan

ESMP Environmental and Social Management Plan

ESIA Environmental and Social Impact Assessment

GIS Geographical Information Systems

Ha Hectare. Equivalent to an area of 10,000m2

HGV Heavy Goods Vehicle

IFC International Finance Corporation

IUCN International Union for the Conservation of Nature

LCT Landscape Character Types

LVIA Landscape and Visual Impact Assessment

NES National Environmental Strategy

RDBRed Data Book. - The IUCN Red List of Threatened Species is a comprehensive, global approach for evaluating the conservation status of plant and animal species.

SEP Stakeholder Engagement Plan.

VP

Vantage Point when used in the context of ornithological surveys to describe a specific location chosen to undertake bird surveys.

Viewpoint when used to describe specific locations used to assess visual impacts.

WMP Waste Management Plan

WTG Wind Turbine Generator




1 Introduction

1.1 Aims and Scope of the Environmental and Social Management Plan (ESMP)

This ESMP for the construction phase sets the standards of environmental performance for Syvash Wind Farm.

These standards will form the basis against which the site will be measured during environmental audits. The primary purpose of this document is to act as the mechanism by which the project developer and sub-contractors will incorporate the requirements of the ESIA together with Equator Principles and EBRD Performance Requirements into the construction and operation of the wind farm.

This ESMP for the Syvash Wind Farm will enable factors that affect wind farm construction, operation and decommissioning to be addressed. The ESMP will be further updated and expanded prior to commencement of construction, following the first construction site audit and on finalization of the East Renewable Energy AB Environmental and Social Management System.

The document sets a number of objectives to ensure that the site is operated in an environmentally acceptable manner through managing the site’s significant environmental aspects. The scope of this ESMP for the Syvash Wind Farm includes all activities, whether conducted by East Renewable Energy AB or other companies and sub-contractors that are part of the construction, operation and decommissioning of the wind farm. It will be detailed in all contractor’s contracts that they will have to demonstrate compliance with the sections of this ESMP relevant to their activities.

Each significant aspect has one or more objectives, which are followed by mitigation measures to ensure that the objectives are met through operational controls.

An Environmental Manager will be established to communicate progress of site operations and report the internal environmental performance audit results during the construction phase.

The ESMP will be reviewed and updated once an EPC contractor has been appointed with a final version prepared prior to the commencement of construction works.

1.2 Implementation of the ESMP

In order to successfully implement the ESMP, the following key tasks will be undertaken:

Preparation of audit checklist based on the targets and objectives. Undertake inspection/audit of site and project operations, including records of

training, waste management etc. Prepare a report detailing areas of compliance/non-compliance.




Prepare a list of actions (action plan) to address non-compliances with associated timescales for completion; and

Audit the actions to ensure issues have been addressed.

It will be the responsibility of East Renewable Energy AB to monitor the effectiveness of the project ESMP and identify improvement actions as necessary.

1.3 Structure of the ESMP

The ESMP is structured as follows:

Chapter 2: East Renewable Energy AB Environmental and Social Policy. Chapter 3: Roles and Responsibilities. Chapter 4: Compliance with legal requirements. Chapter 5: Environmental and Social Baseline. Chapter 6: Management and Mitigation Measures. Chapter 7: Monitoring of Environmental and Social Performance. Chapter 8: Review of the Management Plan. Chapter 9: Record Keeping.

These topics are discussed in subsequent chapters.




2 East Renewable Energy AB Environmental and Social Policy

2.1 East Renewable Energy AB’s Commitment

This Plan identifies specific actions that East Renewable Energy AB considers necessary to address the E&S issues related to our business activities, in satisfying national and international standards.

From planning through to decommissioning, East Renewable Energy AB regards their employees, contractors, and visitors as the top priority in their E&S performance. General Manager(s), Department Managers, Workers, and Contractors should all understand their roles and responsibilities, effectively implement the ESMP, and strive to achieve sustainable development and maintain ‘zero fatality.’

To reflect their commitment in detail, this ESMP has been developed to provide clear instructions on how to comply with the relevant requirements and how to implement procedures, so they ensure that the E&S risks are managed and mitigated properly. The ESMP clearly defines the standards of environmental performance for Syvash Wind Farm and the requirements for assessing, monitoring, and reporting E&S performance.

This ESMP will evolve and mature over the years to satisfy the needs of East Renewable Energy AB’s business development. The Director and the E&S Manager shall ensure this ESMP is updated on a regular basis, and are directly responsible for its effective implementation.

2.2 Providing a Healthy and Safe Working Environment

East Renewable Energy AB is committed to:

Minimising occupational accidents, incidents and occupational diseases;

Integrating E&S performance into our operation processes and services;

Promoting environmentally friendly product design and procurement;

Holding the environment, health, safety, and community as our core values;

Providing a safe workplace with ‘zero fatality; and

Increasing public disclosure and transparency through community outreach.




2.3 Public Safety

Whenever there is business operation in or nearby residential communities, the likelihood for the residents being impacted increases. These potential risks and impacts must be properly managed to the level of maximum control achievable. East Renewable Energy AB will effectively manage the risks by providing training to raise public safety awareness, and to maintain regular communication with community residents in order to understand their needs and concerns.

2.4 Community Engagement

East Renewable Energy – AB are committed to a programme of community engagement. The Project Stakeholder Engagement Programme seeks to define a technically and culturally appropriate approach to consultation and disclosure. The goals are to ensure that adequate and timely information is provided to Project-affected people and other stakeholders, that these groups are given sufficient opportunity to voice their opinions and concerns, and that these concerns influence Project decisions.




3 Roles and Responsibilities

3.1 Corporate Management Structure

The following chart shows the corporate management structure in relation to the various environmental and social management aspects. This is indicative and will be updated once the EPC contractor has been appointed.

3.2 Responsibilities

Responsibilities of parties of Syvash Wind Farm project are presented below. The responsibilities of implementing the specific actions stated in the ESMP will be set out in the East Renewable Energy AB Environmental and Social Action Plan (ESAP).

East Renewable Energy AB has the overall responsibility of developing, reviewing, and updating the ESMP. It will also on a regular basis, monitor and audit the implementation of the ESMP. East Renewable Energy AB will provide appropriate training for their staff in relation to implementing the ESMP.

The Construction Phase Owners Engineer (INSERT NAME) will act as the Project Manager contracted by East Renewable Energy AB, will be responsible for day-to-day management and overseeing of the implementation of the ESMP and relative contract obligations of the contractors.

The EPC contractor (INSERT NAME OF CONTRACTOR) shall be responsible for management of the construction site and their activities in compliance with the ESMP, the relevant laws and regulations and the international standards set out in the ESMP, including taking the required precautions, carrying out the necessary actions to minimise environmental and social impacts that may occur during the construction of Syvash Wind Farm.



EPC Contractor (TBC) Environmental & Social Manager

Wood Environmental & Social Manager

East Renewable Energy AB Environmental & Social Manager


East Renewable Energy AB shall periodically review and monitor the implementation of the ESMP, and provide guidance and support in the framework of its ESMS.

The Lenders and Shareholders will require compliance with the respective performance standards and requirements.

3.3 Contact Details

3.3.1 East Renewable Energy AB LLC

[TBC]

EHS Manager

East Renewable Energy AB

Add address and contact details

3.3.2 EPC Contractor

[TBC]

3.4 Environmental Management Plan (EMP)

3.4.1 East Renewable Energy AB

East Renewable Energy AB’s Project environmental and social management system consists of the following plans:

Environmental and Social Management Plan (ESMP).

Occupational Health and Safety Plan (OHSP).

Stakeholder Engagement Plan (SEP).

East Renewable Energy AB’s Project EMS will be the primary EMS which provides overall control over the project and contractors. Where discrepancies occur, East Renewable Energy AB’s Project EMS will take precedence over the sub-contractor’s management plans with the exception of health and safety issues. The EPC contractor will be the principle contractor on site and all work on site including that of East Renewable Energy AB’s staff will be in accordance with the provisions of the EPC contractor’s H&S Plan.

3.4.2 EPC Contractor

[EPC Contractor] has an existing EMS already in place and will implement this as part of its role of BOP contractor. The EPC contractor will implement the following plans, to be expanded as the Project develops:

East Renewable Energy AB Syvash Wind Farm Project Environmental Management Plan.




East Renewable Energy AB Syvash Wind Farm Project Occupational Health and Safety Plan.

Waste management plan.

Wastewater management plan.

Dust reduction plan.

Noise pollution plan.

Flora and fauna plan.

Cultural heritage management plan.




3.4.3 Plan Hierarchy

The hierarchy of management plans is set out below.

Table 3-1: Summary of Environmental and Social Impacts (TBC)

Title Effective Date Comments

Overarching plans to be in place for lifetime of Project

East Renewable Energy AB Environmental and Social Management Plan.

East Renewable Energy AB Stakeholder Engagement Plan.

EPC Contractor plans (TBC)




4 Compliance with Legal Requirements

East Renewable Energy AB will follow procedures and guidelines set out in their Environmental and Social Management System. Another key consideration of this ESMP is making sure all activities comply with national and international legislation and standards.

4.1 Ukrainian Legislation

The below mentioned laws and regulations include the legal requirements to reduce environmental impacts that may occur during construction activities of Syvash Wind Farm:

Law of Ukraine on Environmental Protection. Law of Ukraine on Flora. Law of Ukraine on Fauna. DBN A. 2.2-1-2003 “Environmental Impact Assessment during Design and

Construction”. SNiP II – 12-77 “Protection from Noise”. GOST 12.1.003-83 “Noise. General Safety Requirements”. DSP 3.3.6.037-99 “Sanitary Regulations of Industrial Noise, Ultra- and

Infrasound”. Sanitary Norms of Permissible Noise in Residential and Public Buildings and on

the Territory of Residential Development. The Sanitary Norms SN # 3077-84”. Regulation No. 935 of the Cabinet of Ministers of Ukraine “On the Measures for

Protection of Wetlands of International Importance” dated 23.11.1995. Regulation No. 1287 of the Cabinet of Ministers of Ukraine “On the Procedure

for Assignment of the Wetlands of International Importance Status to Wetlands” dated 29.08.2002.

CMU Resolution # 465 dated 25 March 1999, Kyiv On Approval of the Rules for Protection of Surface Waters against Pollution with Wastewater (as amended by CMU Resolution #748 (748-2013-п) dated 07.08.2013).

GOST 12.1.007-76 “SSBT (System of Occupational Safety Standards). Harmful Substances. Classification and General Safety Requirements”.

4.2 International Criteria

The Equator Principles, EBRD Performance Requirements, and the IFC Performance Standards (PS) were considered during the preparation of the ESMP as lenders requirements.




5 Environmental and Social Baseline

5.1 Summary of Site Environmental Conditions

5.1.1 Landscape Conditions

The Syvash is Europe’s largest shallow salt-water bay (lagoon of the Azov Sea), one of the most valuable territories within the Azov-Black Sea ecological corridor and Europe as a whole. There are two Ramsar land sites in this area: the Central Syvash and Eastern Syvash. The water area of the Western Syvash adjacent to the Project site is not part of the wetlands.

The water area of the Syvash occupies about 2,640 km2 and is characterized by a very complex configuration of the coastline. Shoreline is low, flattened, foggy, and in the summer covered with a layer of salt. A system of small bays has formed here, which are divided by small peninsulas, spits; large, small and very small islands are scattered in the bays. In general, it is a maze of shallow water and semi-desert landscapes. The Syvash forms numerous bays, peninsulas and more than 60 islands. The northern and western shores of the Syvash are heavily cut, with winding outlines.

According to the physical-geographical zoning of Ukraine, the project area is located in the Syvash-Pryazovia lowland steppe of the Black Sea-Pryazovya dry-steppe biotic province. This landscape type is representative of the wider area. The following smaller landscape character types have been identified within the Project’s area of influence.

Syvash-Pryazovia lowland steppe. Syvash lake. Small villages and settlements.

The Project would be located on the boundary of the Syvash-Pryazovia lowland steppe and Syvash lake LCTs.

5.1.2 Terrestrial Ecology

5.1.2.1 Designated Sites

There are no designated sites included within the search area around Project that are designated specifically for their value for terrestrial ecology and or terrestrial receptors they support.




5.1.2.2 Habitats and Vegetation

The habitats within the Project are farmland, fallow fields and grassland all of which have been subject to various levels of human disturbance. Within and immediately adjacent to the site there are areas of steppe vegetation and salt marshes plus a number of aquaculture ponds with desalinated water. Sand-shelly spits and islands and reeds are present along the coastline.

Almost 40% of the projected area of Project is occupied by agricultural land (agricultural fields, fallow land and pastures). Russia Knapweed (Acroptilon repens) was dominated across the agricultural lands within coverage in some survey plots reaching 30 – 40%. The main dominant on the fallow lands (especially the old ones) is the Tauric wormwood (Artemisia taurica) with coverage in some survey plots between 10 to 60%.

None of the plant species identified within the ruderal habitat classification are listed in the Red Book of Ukraine (2009) or are included as rare plant communities listed in the Green Book of Ukraine (2009).

Meadow vegetation occupies 55% of the Project area with the majority of these assessed as being secondary meadows growing on areas that would have formally been steppe grassland habitats. One species listed in the Red Book of Ukraine (2009) – Lepidium syvaschicum is found within the flood meadow habitats and this species is also listed in the European Red List (1991).

This type of vegetation occupies 5% of the projected area of Syvaska and is confined to artificial ponds, permanent streams and areas with excess moisture. Due to the high mineralization of surface waters and the periodic drying of watercourses, flora and vegetation are fairly poor. No species listed in the Red Data Book of Ukraine (2009) [46] or vegetation groups included in the Green Book of Ukraine (2009) were recorded in areas of wetland vegetation however these habitats are considered to be an important habitat component within Project.

Naturally occurring woodland is absent from Project however man-made plantations (tree belts) are present within the farmland and along the roads. Small standalone wooded copses are also present. All areas of planted woodland are considered to be between 40 and 50 years old. None of the plant species identified within the ruderal habitat classification are listed in the Red Book of Ukraine (2009) or are included as rare plant communities listed in the Green Book of Ukraine (2009). However, despite the relatively low botanical value of these areas they are considered to be of importance due to their function of protecting arable land from erosion and retention of moisture. In addition, they have a high intrinsic landscape value as well as providing habitats suitable for a range of breeding & wintering birds and large mammals including Wild Boar and Roe Deer.




5.1.2.3 Fauna

It is assumed that large mammals including Wild Boar, Deer and Eurasian Otter could be present within and or adjacent to Project based upon species range. Eurasian Otter are listed as Vulnerable in the National Red Data Book, Near Threatened by the IUCN and are also included on Annex II of the EU Habitats Directive. European Mink which are listed as Critically Endangered by both the IUCN and the National Red Data Book are considered to be absent based on known geographical ranges.

Ponds and wetland areas are present in the villages located within Project buffer zones are suitable breeding habitats for amphibians. Toads and frogs were recorded calling from suitable waterbodies within the survey area, although were not confirmed as breeding within the Project site itself.

Two species of snake (Caspian Whip Snake and Eastern Steppe Viper) were recorded in or within the buffer zone of Project. Grass Snake, Blotched Snake and Smooth Snake are also known to occur in the biogeographical area of the Project.

Habitats within Project are largely agricultural which are unsuitable for hibernating, breeding, foraging and commuting reptiles, however edge habitats (shelter belts, ruderal, wetlands, field margins, verges etc.) are all ideal habitats for reptiles for breeding, hibernating and commuting.

Habitats on the site are suitable for foraging and commuting bats and suitable roosting habitats are available within trees in shelter belts as well as in buildings within adjacent settlements, although no roosts were identified during the field surveys within Project. A total of 14 bat species utilizing habitats within and adjacent to the wind farm were identified and of these a single pass of Barbastelle and Giant Noctule were recorded during the survey effort.

The most frequently recorded bats were Common Noctule, Kuhl’s & Nathusius’ Pipistrelle and Parti-colored bats with generally increased activity of Common Noctule in Spring 2017 and greater frequency of the Pipistrelle species in the autumn 2017 surveys. Recorded bat activity is described in the University species reports as being low across the Project and no areas of high activity were noted (e.g. habitat features / roosts).

5.1.3 Birds

5.1.3.1 Protected Areas




There are a number of protected areas in the vicinity of the Project in relation to birds. Karkinits'ka and Dzharylgats'ka Bays International Bird Area (IBA) is 10 km south-south-west of the Project site. It consists of 87,000 ha and has a threat score of high, condition as very unfavourable and an action score of medium.1 The high threats to the site include fishing and harvesting of aquatic resources, agricultural and forestry effluent and domestic and urban waste water. Both the grassland and marine coastal areas are considered to be in poor condition and very unfavourable. The key species populations within the site which are considered to be very unfavourable include the Red-breasted goose, Mallard, Egretta garzetta, Slender-billed curlew, Sterna nilotica, Little turn, Caspian turn and White-tailed sea-eagle. Conservation management measures are being implemented to improve the protected area.

Askania Nova Biosphere Reserve is located 23 km north of the Project site and consists of plots of natural steppe with man-made ponds bordered by cultivated land. The site has populations of IBA trigger species including red-breasted goose, greater white-fronted goose, ruddy shelduck, demoiselle crane, common crane, black-winged pratincole, paillid harrier, water birds and soaring birds / cranes.

Syvash Bay IBA is located 24 km south-east of the Project site. An extensive system of lagoons with sandy islands and shores, surrounded by steppe, in the coastal zone of the Black Sea and Sea of Azov. It is an important site for water birds and birds of the steppe biome.

5.1.3.2 Bird Species

A total of 44 species were registered in the Spring 2013 migration period involving 32,942 individuals. The most numerous species included ruff, Mediterranean gull, dunlin, pied avocet, common shelduck, gull-billed tern and black-winged stilt. During the Spring 2015 migration a total of 34 species were recorded (2,536 individuals). The most numerous species were ruff, rook, common starling, Eurasian skylark, mute swan and black-headed gull. Finally, during the 2017 Spring migration, 89 species were observed (14,232 individuals). Most numerous species were ruff, common starling, black-headed gull, Caspian gull, greater white-fronted goose, common shelduck and rook.

Autumn migration surveys in 2012 and 2017 resulted in peak counts of several notable species including white stork, lapwing, ruff, sandpipers, black-headed gull, Mediterranean gull, dunlin and slender-billed gull amongst others.

With regards to breeding birds, based on information from the 2010 to 2015 surveys, it was considered that the number of nesting birds in the Project area has significantly reduced during recent years. In 2017, a total of 37 species and 638 nests were recorded, although just 12 species were observed in the area of the Project with 38 nests confirmed. The largest numbers of nests were for great reed warbler, which are

1 http://datazone.birdlife.org/site/factsheet/karkinitska-and-dzharylgatska-bays-iba-ukraine



http://datazone.birdlife.org/site/factsheet/karkinitska-and-dzharylgatska-bays-iba-ukraine


common in the region. Four Red Book of Ukraine species, glossy ibis (15 pairs), red-crested pochard (2 pairs), black-winged stilt (2 pairs) and oystercatcher pairs were recorded. None were confirmed as nesting within the Project area, although they were present in wetland habitats immediately adjacent.

Wintering bird surveys were completed in 2013, 2015 and 2017. During 2013, the most numerous winter gatherings were mainly of small numbers of common terrestrial species but mallards (3,390), common gulls (150) and rare observations of hen harrier and white-tailed eagle. The most abundant rare species were common goldeneye. In 2015, a total of 2,165 individuals of 19 species registered within Project area. Rooks had greatest numbers and species dominated by terrestrial species with aquatic species recorded. During 2017, a total of 11,189 individuals of 30 species were recorded but only 165 individuals were recorded within Project site, which was attributed to poor food supply. Most numerous birds within Project site were mallard (70) and common starling (40). Four Red Book Ukraine species were recorded: ruddy shelduck, hen harrier, white-tailed eagle and lesser short-toed lark.

5.1.4 Hydrology and Hydrogeology

The Project site is located in close proximity to the Gulf of Central Syvash water body. No major water courses / rivers are identified within the site boundary. Within the Project site, surface water is characterised by artificial ponds, drainage channels, streams and marsh / wetland areas with excess moisture. Irrigation infrastructure is present in the form of large drains and associated irrigation equipment, of note, a large channel runs to the south and west of the eastern portion of the site outwith the land plot boundaries.

Due to the high mineralization of surface waters and the periodic drying of watercourses, flora and vegetation are fairly poor. Localised wetland areas are present on the low lying coastal areas of the site.

There is a high water consumption in the region from irrigation systems for agricultural operations. There is one ground water well in place associated with the existing wind turbine generators (WTG) on site and is located adjacent to the current operations building. Two further wells are located within the site boundary utilised for irrigation purposes.

Average precipitation is in the region of 400 mm. Most of the precipitation occurs in summer as rainfall. During winter in the coastal area snow fall typically amounts to approximately 15 days.




The Project is located in the Fore Black Sea artesian basin hydrogeological area.2 Hydrogeological conditions in the region are complex because of diverse and discontinuous aquifers and low-permeable rocks, facial variability of the host rock lithological composition, diversity of groundwater quality. The region belongs to the zone of insufficient moisture and groundwater supply.

Shortage of fresh groundwater is a key issue in the Kherson region due to current irrigation practices, aquifer overexploitation and a complex of natural conditions. The main source of drinking water in the Region is the upper Miocene (the main Neogene) water-bearing aquifer complex, widespread in Kherson region.

The Project site is located predominately within an area of low flood risk, with some areas of higher risk of flooding identified associated with surface water bodies feeding into the Syvash Bay.

5.1.5 Geology and Soils

The Project site is predominately of flat terrain, absolute heights vary between 6 and 21 m above sea level. In the south and especially in the south-east, the flatness of the surface is disturbed by the pools (their depth is of 6-8 m (sometimes up to 15 m)) and gullies (the depth of their inlets reaches 10-15 m).

Geomorphologically, according to the Geological Map of Ukraine3, the Project area is located within the Akshahylsky Regional State (clays, alerites, sands and conglomerates. Akania Melitopol terrace.

According to the WHO Seismic Hazard Distribution Map of Ukraine4 the Project site is identified being in an area with low seismic hazard (0.2 – 0.8 PGA, m/s2). An area of medium seismic hazard lies to the south of the Project (0.8 – 2.4 PGA, m/s2). No significant earthquakes are identified by WHO in the Project area.

The soils within the Project area are characterised by their salinity typically due to previously higher ground water levels and bioclimatic factors. Some signs of erosion were identified during the site visit however this was not identified to be significant or widespread.

2 Mineral Resources of Ukraine Groundwaters http://eng.minerals-ua.info/golovna/vodi-pidzemni/

3 Mineral Resources Ukraine (2007).

4 WHO (2010).




5.1.6 Cultural Heritage

The District Inspection for the Historical and Cultural Monuments Protection from the Office for Cultural Affairs of the Kherson District State Administration confirmed that sites of archaeological importance were within the Project area. The District Inspection for the Historical and Cultural Monuments Protection, in accordance with Article 17 of the Law of Ukraine "On the Protection of Cultural Heritage", require that all monuments of archaeology constitute state property and prohibits the use of areas and conservation zones of the mounds. The mounds have been excluded from the site boundary to ensure no direct impacts occur.

Further features were identified during the site visit outwith the site boundaries including historic heritage, including a war memorial and grave sites located to the south of Novovolodymyrivka. A cemetery is also present to the south of Pershokostyantynivka. A 300 m buffer is maintained in accordance with national requirements.

5.1.7 Noise

Background Noise (BGN) monitoring was undertaken at a total of four locations representative of settlements in close proximity to the Project. BGN was measured for two weeks between 29 March 2018 and 12 April 2018 at Pweahokoatyantynivka (Location A), Hryhorvika (Location B), Novovolodymyrivka (Location C) and Strohanivka (Location D). Measurements were made in accordance with best practice set out in ETSU-R-97.

The measured LA90 noise levels at 10-minute intervals have been correlated with the wind speed measurements at 10 minute intervals standardised to a height of 10m. IFC EHS guidelines, on which the Project WTGs operational noise assessment is based, use one hour LAeq (dBA). On review of the data obtained, the background LAeq was found to vary dramatically. Following the guidance of ETSU-R-97, the LA90,10min was used as the background noise descriptor.

Table 5-2: Background Noise Levels, LA90 + 2 dB, (Approximate LAeq)

Receptor Location A Location B Location C Location DWind

Speed (m/s)

Quiet Day

Night-time

Quiet Day

Night-time

Quiet Day

Night-time

Quiet Day

Night-time

4 33.8 28.5 30.3 24.9 35.0 32.9 33.8 28.5

5 36.0 30.6 31.8 26.4 36.7 34.0 36.0 30.6

6 39.0 33.0 33.6 28.7 38.7 35.8 39.0 33.0

7 42.6 35.5 35.9 31.9 41.0 38.2 42.6 35.5

8 46.9 35.5 38.5 31.9 43.7 38.2 46.9 35.5




Receptor Location A Location B Location C Location DWind

Speed (m/s)

Quiet Day

Night-time

Quiet Day

Night-time

Quiet Day

Night-time

Quiet Day

Night-time

9 46.9 35.5 38.5 31.9 43.7 38.2 46.9 35.5

10 46.9 35.5 38.5 31.9 43.7 38.2 46.9 35.5

11 46.9 35.5 38.5 31.9 43.7 38.2 46.9 35.5

12 46.9 35.5 38.5 31.9 43.7 38.2 46.9 35.5

5.1.8 Transportation

The transportation of abnormal loads from Nikolaev Port in Mykolaïv to site is likely to require works to be carried out particularly when the loads reach the T2206 road. The roads leading to the site are in poor condition and would need to be upgraded to accommodate HGVs and abnormal loads.

5.1.9 Socio-Economic Conditions

According to the State Statistics Service of Ukraine5, the population of Kherson Oblast in February 2018 was estimated as being 1,046,100. The total area of the Kherson Oblast is 28,461 km2. The city of Kherson is the largest in the Kherson Oblast, with a population of 299,100. The population of the Kherson Oblast is approximately 41.0% male and 59.0% female.

Communities located within approximately 5 km of the Project site include: Pershokostyanivka, Hryhorivka, Pavlivka, Novovolodymyrivka, Strohanivka and Ivanivka.

The primary employment sector within the local communities and the greater Chaplynka district, is agriculture: more than 78% of the employable population is engaged in this sector. The region is characterised by large scale arable farming. Principal crops include wheat and other grain crops, sunflowers and soya. During the 2018 site visit, the key land use of the Project site was confirmed as agricultural (arable and livestock grazing).

According to anecdotal information obtained during the site visit (provided by a Community Chairman), unemployment in the Chaplynka district is between 15 and 20%. This has reportedly led to migration of young people away from the area.

Groundwater is used as a source of fresh water in the Kherson region6.

5 www.Ukrstat.org

6 Scherbak, 2013




During the site visit, it was noted that properties in areas of the Chaplynka district make use of septic tanks for sewage disposal, and are not serviced by a municipal sewer system.

It was also noted during the site visit that the communities in the Chaplynka district dispose of their domestic (household) waste by burning it in small fires along the road side. There do not appear to be municipal waste collection services operating in the area.

5.2 Overview of Construction Works

The wind farm is expected to be constructed from Q3 2018 to Q4 2019. The following sub-sections describe transportation of workers, materials, and equipment to the site, the temporary works to be used during construction, and construction of the various project components.

Construction works will consist of the following:

Temporary Works. Control Centre Compound. Access Road. Grid Connection (on site). On-Site Roads and Underground Cabling. 67 Wind Turbines with capacity up to 4.2MW.

[PROJECT DETAILS TO BE INSERTED WHEN DETAILED EPC DESIGN AVALIABLE].

Temporary works to be used during construction will consist of a temporary compound and staging area located near the future control centre and sub-station, and possibly other smaller temporary compounds in other areas of the site. The main compound will include a parking area, a generator with fuel storage, and temporary buildings to provide support facilities for managers and workers, secure storage, site offices, and welfare and first aid facilities.

It is anticipated that up to three permanent meteorological masts will be installed on-site during construction.

There is currently no paved road from the main public road to the site. On-site roads are required to connect the WTGs to each other and to the substation (control) building and compound. All access roads will be approximately 4 - 6 m wide. Where roads have to cross existing erosion features or ephemeral streams, drainage features will be incorporated into the design to control overland flow and minimize erosion. If major gullies or other erosion features are crossed, culverts will be installed to convey storm water under the road.




Typical road construction specifications include excavating topsoil and subsoil, grading to desired slope and grade using cut-and-fill methods, placement and compaction of gravel where needed, excavation of a drainage ditch along uphill sides where appropriate, and placement of low berms on downhill sides where necessary. Any surplus topsoil will be stockpiled and protected from erosion, for use in future reinstatement.




5.3 Potential Environmental and Social Impacts and Mitigation

Table 5-1 summarises the potential impacts on the environmental and socio-economic resources as reported in the ESIA together with proposed mitigation measures. All impacts are adverse unless otherwise stated.




Table 5-3: Summary of Impacts and Mitigation

Environmental Receptor

Predicted Impact Mitigation

Landscape and Visual Impact

Impacts on landscape character and visual amenity during construction

The main impacts on landscape character and visual amenity result from the areas for temporary works, construction compounds, access road and on-site roads, areas for WTG and control centre foundations. New machinery and equipment will be introduced into the landscape, including a crane, trucks (usually 20-tonne trucks, but sometimes larger), excavators, bulldozers, and other heavy equipment. In addition, there will be temporary accommodation and storage areas.

The impacts will be temporary and medium term with the significance being Slight and not significant.

Limiting damage to any grassland by keeping the construction areas and roads to a minimum, and maintaining strict requirements for vehicles to remain on the roads at all times.

Reinstating grassland where construction areas and roads are no longer required. This would reduce the duration of the visual impact.

Provision of adequate facilities for the disposal of garbage.

Training of the workforce in waste management.

Reduce the amount of waste to the maximum extent possible.

Collect all solid waste and store until transported to an appropriate waste disposal facility and disposed.

Organization of clean-ups for existing garbage.

Impacts on landscape character and visual amenity during operation.

The main source of impact to the LCT during operation is the erection of the 67 WTGs.

Other elements of operation of the Project that will affect the landscape comprise:

On-site roads, including WTG access roads, and occasional vehicles that pass along the roads.

Mitigation options are fairly limited during operation and would be focused on the full implementation of the community benefits package to ensure that any visual impacts on the local population is offset by an appropriate level of community benefit.






Additional structures at the Control Centre.

Terrestrial Ecology

Designated sites, habitat and flora

Direct loss of vegetation and habitat (including food sources).

Indirect impacts associated with construction include potential pollution of water courses and or other areas of higher habitat value as well as disturbance of fauna as a result of construction activities, noise, lighting and movement of vehicles and people.

Unmitigated, the potentially negative impacts of pollution on habitats and flora of Project are considered to be of low to moderate significance.

Avoidance of habitats that support fauna receptors of moderate to high sensitivity.

Speed limits enforced on the construction site.

Clearly sign any animal crossings during construction and, if necessary, employ additional mitigation to reduce conflict with on-site traffic.

Enforcement of standard pollution control measures during construction such as storage of fuel and lubricants in double-bunded containers and ensuring availability of spill kits in appropriate locations.

No hunting or collecting of flora or fauna within the Project area.

Shelter belts protected from felling and / or collection of fire wood by construction areas.

Prohibit setting fire to woodland areas and / or meadow habitats.

Maintenance of excellent house-keeping practises and high levels of recycling.

Fauna Disturbance of fauna from presence of people, machinery, traffic, and noise.

Indirect impacts associated with pollution incidents could affect habitats and breeding sites. This is of low to moderate significance.

High sensitivity bat species could be indirectly affected through noise disturbance and/or lighting impacts considered to be moderate to






high significance.

Fauna – operational Possible killing and injuring of animals by site traffic resulting in negative impacts of low to moderate significance.

Killing of bats due to WTG operation, leading to moderate to high significant impacts.

Enforcement of speed limits on site.

Monitoring of road conditions and any damages repaired.

Maintenance of any animal crossings.

Completion of carcass searching programmes for at least three years of operation.

Additional bat surveys recommended to further inform potential mitigation.

Maintain the ban on hunting and collecting of firewood.

Prohibit fires to wooded areas or meadow habitats.

Implement enhancements where possible including increasing the quality and amount of wet meadow habitat and improving woodland areas.

Additional data requirements

Further survey work required to better inform adaptive management strategies to reduce potential impacts.

Pre-construction habitat survey.

Pre-and during construction amphibian surveys.

Pre-operational bat surveys (between May and October).

Pre-construction otter surveys.

Ornithology

Impacts during construction activities

Construction impacts are likely to include habitat loss and possible nest destruction for passerine and ground nesting bird species as well as disturbance impacts in the Project and adjacent areas.

Design and Planning

Avoidance of areas of highest quality habitats and use of buffer zones where possible between wet grasslands and marshes.

Site Preparation






Habitats that will be lost during construction should be removed outside of the bird breeding season (March to August inclusive). If this is not possible, a check must be done by the on-site ecologist to ensure breeding birds not directly affected.

Impacts during operational activities

Disturbance of birds from WTG noise, shadow flicker, people, and traffic.

Loss of birds from collision with WTGs.

Minimum of three years operational mitigation and monitoring including observer and / or technology-led shut down during migration and wintering seasons.

Enhancement measures

A number of enhancement measures identified which should be incorporated in to the Project in order to have a positive impact on breeding / resident birds:

Installation of small raptor (falcon) nest boxes on the pylons that are at least 1 km away from operational WTGs. These artificial nesting opportunities have been shown to be very successful in the UK and Europe.

Development and enhancement of wet meadow habitat and shelter belts / small copses.

Installation of bird boxes within the shelter belts that will provide a range of nesting opportunities for passerine birds.

Hydrology and hydrogeology

Surface water drainage

During construction earthworks, road construction and use of heavy vehicles could alter surface drainage patterns.

The route of the access tracks should be optimized to reduce the need for cut-and-fill material and run-off and erosion control features should be incorporated in designs.

Buffer distance of 50m is applied to any hydrological features shown on background maps or discovered by survey.

Prior to final positioning of the WTG locations, an area-wide sheeting flow study should be carried out using detailed topographical data, and soils data from the






ground investigation which will provide velocities and depths of flow during periods of intense rainfall.

Pollution prevention measures (applicable to all aspects) should be included in a Project ESMP.

Increased surface run-off

The removal of vegetation and compaction of will reduce infiltration and surface run-off will increase. The risk is greatest during severe precipitation events.

Ensure excavated areas are re-vegetated as soon as practical following initial vegetation stripping.

Soil erosion and sediment loading

The increased volume of water flowing down drainage channels and creeks is likely to cause additional soil erosion and increase the size of the channels.

Surface run-off will also contain larger amounts of suspended sediments during construction than would otherwise be the case.

Impacts to surface waters in operation confined to increased runoff and erosion, primarily in existing or new erosion channels that receive run-off from roads.

Ensure that drainage channels are vegetated as soon as practical following initial construction to stabilize areas of bare earth.

Water pollution from leaks and spills

Water discharge and pollution. Risk of soil and water pollution from leaks and spills through storage of oil

A designated storage area is established with an impervious base and impermeable bund walls. Capacity must be sufficient to contain the full volume within a bund and secured area.






All fuel, oil and chemical storage is stored in a designated secure area.

Establish a designated storage area with an impervious base and impermeable bund walls, and protected from precipitation. Capacity must be sufficient to contain the full volume within a bund and secured area.

Hoses and valves are checked regularly for signs of wear and ensure that they are turned off and securely locked when not in use.

Diesel pumps and similar items are placed on drip trays to collect minor spillages. Trays should be checked regularly and accumulated oil removed.

Do not leave vehicle unattended during refuelling, never leave open a delivery valve.

Water pollution from sewage effluent

Pollution of ground/surface water due to the inappropriate discharge of sewage effluent.

Sanitary waste to be collected in containers below portable toilets and transported for disposal. The waste will be disposed of by a licenced contractor.

Additional data requirements

Further survey work required to better inform the identification of potential impacts.

A construction water availability / resource use assessment and management plan will be developed to confirm construction water use.

Assessment of the ability and capacity of existing local supply to provide construction requirements.

Geology and soils

Soil erosion particularly as a result of loss of vegetation

Vehicle traffic along dirt tracks used during construction of on- and off-site roads, power lines, control centre and WTGs will cause soil compaction.

Off-road vehicle traffic will damage vegetation

Clearly demarcate storage and staging areas and store all materials, equipment and vehicles in demarcated area to reduce soil damage. Furthermore, vehicles should be confined to demarcated roadways.

Establish native grasses in erosion control channels and in other areas






and cause soil compaction.

Any vegetation and some soil will be removed for the construction camp, the control centre, WTG foundations, and both on- and off-site roads.

The use of heavy equipment, including cranes for WTG erection, will cause soil compaction if used off roads.

Blasting will result in the removal of any vegetation and topsoil and near-surface rock for WTG foundations, possibly for the control centre and for some on-site and access roads.

immediately after final disturbance.

Salvage and store topsoil and subsoil before areas are excavated, with topsoil stripped and stockpiled separately.

Segregate excavated soils into stockpiles dependant on material type and provide erosion control while stockpiled.

On completion of earthworks, backfill material in the same stratigraphic sequence.

When wide roads are narrowed after WTG construction, scarify compacted areas and establish native grasses.

Once construction and road-building are complete, scarify all areas compacted by off-road vehicle / equipment movements and establish native grasses.

Store all materials within designated areas of temporary storage facilities and provide supplies to clean-up of minor spills.

Confine all vehicles and equipment to the roadway and, to extent possible, minimize activities during wet conditions. When activities must occur in wet conditions, control storm water by using fabric, straw bales and other measures to impede storm water flow and prevent erosion.

When damage to wet soil occurs, repair once dry conditions return.

For storage of oil, establish a designated storage area, with impervious base and impermeable bund walls. Capacity must be sufficient to contain full volume within a bund and secured area.

Store all fuel, oil and chemical storage in the designated storage area.

Check hoses and valves regularly for signs of wear and ensure they are turned






off and securely locked when not in use.

Place diesel pumps and similar items on drip trays to collect minor spillages. Check trays regularly and remove any accumulated oil.

Reduce the amount of waste to the maximum extent possible.

Collect all solid waste and store until transported to the designated disposal site.

Soil erosion as a result of continued vehicle traffic during operational phase.

Movement of staff and materials to and from the site along the access roads may result in degradation of tracks and erosion.

Movements between the control centre and WTGs for operation and maintenance particularly if workers drive off designated tracks. Workers are expected to visit each WTG location least once per week for routine maintenance.

Confine all vehicles to roadways.

Monitor road condition regularly; then repair damaged and rutted roads rather than bypassing damaged sections.

Monitor erosion controls and repair as needed.

Where possible, maintain grass cover on berms and ditches.

Prohibit use of vehicles and equipment off prepared roads.

Re-stabilize existing eroded tracks and restore grass cover as needed.

Do not collect firewood from the site.

Reduce wastes to the extent possible and maximise re-use and recycling of materials. Collect and store all waste and garbage before disposal at the designated site.

Clean up and store oily and chemical waste and contaminated material before transport to the designated disposal site to reduce risk of soil and groundwater contamination.

Establish a designated storage area with an impervious base and impermeable bund walls, and protected from precipitation. Capacity must be sufficient to






contain full volume within a bund and secured area.

Store all fuel, oil and chemical storage in the designated secure area.

Do not leave vehicles unattended during refuelling, never leave open a delivery valve.

Check hoses and valves regularly for signs of wear and ensure that they are turned off and securely locked when not in use.

Place diesel pumps and similar on drip trays to collect minor spillages. Check trays regularly and remove any accumulated oil.

Archaeology and Cultural Heritage

Buried archaeological items

Due to presence of archaeological features within the area there remains the potential to uncover previously buried archaeology (chance finds) during construction works. The impact significance is Moderate and significant.

Detailed archaeology surveys are currently being carried out on site. The results of this survey will be fed into the detailed design process for the Project with infrastructure micro-sited to ensure that direct impacts on existing archaeological or cultural heritage features are minimised.

Specified buffers around isolated mounds and mound groups / fields of archaeological significance will be maintained.

A cultural heritage management plan will be developed in accordance with the requirements of EBRD PR 8 and IFC PS8.

East Renewable Energy AB or its contractors will not disturb any chance find further until an assessment by a competent professional is made and actions consistent with the requirements of with the requirements of Ukrainian Law, EBRD PR 8 and IFC PS8.






During construction, toolbox talks will be provided to ensure that workers will be alert to any signs of past cultural activity in the area.

Noise and Shadow Flicker

Construction noise General nuisance to local population caused by construction activities. Without a detailed noise management plan, the impacts could be significant.

Construction activities will be scheduled, unless otherwise agreed, from Monday to Friday 0700 to 1900 or Saturday 0700 to 1300. Unattended plant equipment should be kept to a minimum.

Implement a detailed Noise Management Plan for the construction phase, and set up community relations with a compliant reporting system.

Operational noise levels at nearby receptors

The preliminary worst case scenario noise model predicts exceedance of the night-time 45 dB limit at night, resulting in significant impact. Additional exposure levels at Locations A and D over 10 dB indicate a significant impact.

A further noise impact assessment and modelling exercise should be undertaken when final WTG type and layout are confirmed, allowing for the need of mitigation and possible curtailment schemes to be detailed.

For the current assessment;

Location A – curtailment scheme should be implemented during night-time at wind speeds between 4 – 6 m/s to reduce additional exposure below 10 dB. Curtailment during night-time between 6 - 9 m/s to ensure noise levels do not exceed 45 dB.

Location D – curtailment during night-time at 4 m/s to reduce additional exposure below 10 dB

Shadow flicker during operation

Four out of five representative shadow flicker receptors are expected to experience shadow flicker impacts in excess of the recommended

If any complaints are raised by the local community (through the grievance mechanism or other channels) relating to shadow flicker from the wind farm, the wind farm operator shall investigate and instigate, at their own expense and






limits subject to the actual orientation of windows.

within one month of being advised of the complaint, appropriate measures to mitigate the shadow flicker effects.

Measures include:

Provision of additional screening or provision of window blinds at the affected receptor.

Programming of WTGs to shut-down during periods when shadow flicker is predicted to occur at the affected receptors should screening and / or blinds be deemed ineffective.

Transportation and access

Abnormal loads and HGV traffic during construction

Impact of the Project HGV / abnormal load traffic during construction on the existing road.

Increased total daily traffic flow on the local road network.

Pre-construction

Finalise the proposed transport route to site undertaking an access route study to include:

Visual inspection of proposed route. The Project swept path analysis. Identification of possible pinch points. Identification of works required to bridges / boundaries etc. Consultation with local roads authorities to determine the suitability of

the proposed route.

Develop the final site layout plan and corresponding access tracks.

Review the potential to source the required road stone on-site via borrow pits, negating the need for transportation of these materials to site.






Develop a Construction Transport Management Plan (CTMP) to manage potential impacts on the road network and its users. This should include (but not limited to):

Details of the proposed route. Commitment to all construction vehicles only using approved access

routes to site. Movement of abnormal loads restricted to outside of peak traffic periods. The requirement (if any) for escort of abnormal loads. When required, on-coming traffic halted to enable abnormal load

transporters to negotiate any pinch points along the route. Temporary direction signs indicating local routes to site and site

entrances (statutory and site identification boards) provided along with advisory speed limit (to be agreed) signs along the length of the access route.

Maintenance of the access route during construction by the main contractor to a condition suitable for use.

Minimisation of mud and debris on road through use of wheel washing facilities at the site exit point and regular inspections of roads including maintenance such as road sweeping if required.

Encouragement of construction personnel to car share where possible. Development of Incident and Contingency Plan. Parking requirements / restrictions on site.

Consultation with local authorities regarding proposals and any authorisations /






escorts required for the movement of abnormal loads.

Consultation will be required with services / utility providers to determine the exact location of any underground and overhead services / utilities and prior to removal or re-alignment of any overhead cables.

Prior to construction of the Project, a series of leaflets and notices should be posted making local residents and businesses aware of any likely disruption.

Construction

Monitoring of the efficiency of deliveries of construction materials to the site and if necessary sufficient storage provision made available on site to prevent any delays to the construction process.

Construction TMP adhered to in order to reduce risks to drivers, local road users and pedestrians (where applicable).

Road works Damage to road edges and general ‘wear and tear’ of the road may occur through increased HGV movements.

It is recommended that the route for the transportation of abnormal loads, particularly where the route crosses any bridges, be verified through further assessment (including swept path analysis and route inspection).

Further re-enforcement work undertaken as necessary.

Operational impacts Increased loading on local roads during routine maintenance and servicing. The majority of these will be light vehicles with HGVs only required if WTG components need replacing.

Development of operational TMP.






Social Impacts

Population and employment

Temporary jobs during the construction phase of the Project.

Long-term, high quality jobs created for the life of Project.

Indirect job creation from service and supply jobs to meet demands from resident workforce.

Potential to fail to meet community expectations for job creation due to a) lack of suitability of local candidates, especially during construction and b) during the transition from construction to operations.

Communicate employment estimates, timeframes and skills requirements clearly to the community on a continuous basis.

Develop, in conjunction with local government authorities and other companies in the area, mitigation within the ESMP to address potential indirect impacts of the Project on the local community, including on community infrastructure such as water supply, public health infrastructure and waste water treatment.

Invest in skills training to enable greater employment of local population throughout Project life, for both construction and operations phases, to start as early as possible ensuring maximum employment during construction.

Implement a local hiring plan in consultation with the community and in a way that meets long term operational needs of the Project as well as the short term construction needs, taking into account the relatively low skill base of the local population when it comes to wind power related jobs.

Development of Influx Management Plan to set out measures to manage the influx of migrant labour during construction minimising impacts on local communities.

Economic displacement associated with Project site agricultural use is to be addressed through the development of a Livelihood Restoration Plan (LRP).

Development of Stakeholder Engagement Plan.



Suzy Yendell, 01/05/18,

Requirement for LRP to be reviewed prior to issue




Water use and resource studies will be conducted to understand the water use requirements of the Project and the water resources available in the region, to ensure that water is obtained from suitable sources and the Project does not have a negative impact on the current water supply for local communities and agriculture in the area.

Consultation activities will be conducted with local farmers to disclose Project activities and project schedules, and address farmers concerns regarding the availability of grazing land.

Construction activities will be conducted in such a way as to minimise the effects on local communities and farmers.

Reclamation of the land will be conducted to backfill and restore native vegetation.

Provide detailed and regular information to local community members about Project activity to mitigate community concerns as a result of misinformation.

Enhancement measures include:

Investigate local sourcing and procurement opportunities to promote sustainable small business development.

Invest in capacity building for small businesses to enable them to meet standards for procurement required by the company and to service the needs of influx populations and indirect employees (through service industries).






Work with local vocational training schools to develop curricula which will qualify local students to better meet the needs to the developing wind industry locally.

Construction workforce

Potential for direct short term negative impacts on a local scale if accommodation for a diverse workforce is not provided.

Contractors will be responsible for meeting the labour and working conditions set out in the Bid Documents which will be prepared as part of the contractor tendering process.

Construction camps. Worker illness or death from unsafe or unsanitary living conditions, as well as disruptions in Project schedule as a result of incidents (riots, security breaches, etc.) at the camps.

Camps, should they be deemed to be required, will therefore be designed and managed to meet the requirements set out by IFC and EBRD

Local economy. Initial investment in the Chaplynka District, due to the use of domestic materials, labour, and services. Construction supplies and equipment purchased locally are likely to have a minor beneficial effect.

Benefits due to local construction workers increased earnings.

Creation of full time jobs during operation could benefit the local economy.

Additional training resources and funding for local people to be employed during construction and operation.

Social cohesion. In the event that an accommodation camp is constructed for construction workers coming into

Establishing clear rules for worker behaviour will avoid these issues.






the area, there is potential for conflict between local livestock farmers and construction workers.

Medical facilities Risk of increased pressure to already stretched medical resources during construction due to population influx.

Negligible impacts during operation.

Investment in local social infrastructure (e.g. hospitals, schools, roads).

Safety risks from traffic.

The increase in HGV traffic during construction presents a risk of accidents.

Emergency response capacity is limited (lack of responders, transportation and equipment). Hence, response time to potential accidents is unlikely to be rapid.

Provide appropriate traffic safety training to all drivers (employees and contractors) as part of their induction and on an ongoing basis.

As part of pre-construction engagement activities, ensure that traffic safety and “rules of the road” are discussed with local communities. Discuss and address community concerns. Special sessions may be required for particularly vulnerable groups such as children. At minimum communicate type, frequency and traffic risks before heavy traffic begins for the construction phase.

Use grievance mechanism and other means to monitor driver conduct.

Implementation and compliance with the Community, Health and Safety Management Plan.

Personal safety. Increased risks to community safety and security are likely as a result of influx of workers and other individuals to the area as posing a threat to security, primarily in relation to their property and potential unruly or destructive behaviour.

Ensure that Project security is aware of the Project’s goals to establish good relationships with local stakeholders; the grievance mechanism for communities to voice concerns; and receives human rights and cultural sensitivity training to ensure the respect and protection of the local community.

Develop a code of conduct for security personnel, which outlines appropriate conduct, engagement and appropriate use of force. Ensure all security






personnel read and sign code of conduct as part of their induction program.

Introduce head of security personnel to neighbouring communities and outline the necessary safety precautions that will need to be put in place to ensure both the safety of the Project and safety of local communities.

Community safety meetings should be organised with all potentially affected groups and be conducted in advance of construction activities.

As part of ongoing stakeholder engagement efforts, ensure that all potentially affected stakeholders know how to contact the company and to file grievances (in accordance with the Grievance Mechanism).

Poor air quality. Construction activities will result in fugitive dust. It will be generated by vehicle traffic on unpaved roads, naturally occurring windblown dust from disturbed lands and dust generated during construction activities.

Fugitive dust will have the greatest potential impact on communities close to the site, and farmers who use grazing land close to the site.

Implementation and compliance with a Traffic Management Plan which should identify the strategies used to manage dust on the road during the execution of the Project.

Implementation and compliance with the Dust Management Plan (part of the overall ESMP).

Use of properly maintained vehicles and construction equipment with emission controls.

Communicate project risk to local communities and address concerns accordingly. Monitor any complaints filed (via grievance mechanism) from local stakeholders as an additional tool to monitor dust management measures.

Contamination of groundwater.

Population influx and increased Project waste and effluents may increase pressure on local waste management and sanitation services and infrastructure and have the potential to

Implementation of the Waste Management Plan, to ensure that household and project waste is disposed of in line with Ukrainian standards;

Where appropriate, support local public health campaigns against food and






contaminate groundwater, risking the spread of disease.

water borne diseases.

Implementation of a Camp Management and Security Management Plan to ensure the provision of a safe and healthy environment for workers.

Introduction & spread of communicable diseases.

The rapid increase in population from the presence of large, male workforces, coupled with in-migration of income seekers to the area of influence, increases the risk of introducing and spreading communicable diseases.

Close living conditions, poor water and sanitation, and deprivation (whether inside or outside of the construction camp), can increase the risk of respiratory disease, as well as food and water-borne diseases.

Ensure health screening is being conducted for employees and contractors before contracting workers and on a periodic basis throughout their employment/contract.

As part of health and safety induction for workers, provide awareness training on communicable disease prevention. Provide this training on an ongoing basis.

Work in collaboration with an onsite medical team to ensure that such awareness and education training is appropriately provided to workers and contractors.

Identify opportunities to support local public health campaigns that focus on prevention of communicable diseases.

Health services & infrastructure.

Project activities will result in an increase of non-resident population and workforce, which in turn could increase pressure on local health services and infrastructure.

Ensure that all Contractors are provided with adequate health care (for work related injuries and off the job-related health issues) that is independent of the local health care system.

Liaise with local health professionals to identify ways that the Project can provide sustainable investments in the health care facilities used by their workers.

Alcohol use. Population influx associated with the Project activities will increase the size of the workforce with disposable income in a generally

Enforce and monitor the zero-alcohol tolerance policy, including current intoxication, for workers during working hours.

Ensure random alcohol testing is conducted for workers entering and leaving the






impoverished area. This is likely to result in increased demand for alcohol in the area.

This could also result in a potential increase in aggression or conflicts between workers and community members.

site.

Design a system of penalties for anyone found with alcohol within the workers camp or on site.

Injury from construction activities and emergency events.

Potential for harm to workers due to accidents related to construction activities and emergency events.

Keep Project plant and equipment to pre-defined routes and areas. Use appropriate signage.

Provide information to local community via the SEP that they should not enter the construction area.

Develop an emergency response plan (ERP).

Work with local emergency responders to at minimum: (i) communicate ERP; (ii) depending on level of risk from emergency events build local capacity to ensure appropriate local response in case of emergency.

Communicate potential risks and ERP to those potentially most affected by emergency events.

Occupational and Public Health and Safety

Movement or operation of passenger and construction vehicles, equipment, and materials could cause injury or death to humans (drivers, passengers, pedestrians) or animals (livestock or wildlife).

Using hand tools or larger equipment could result in accidents that harm or kill workers.

ERE AB and its contractors will comply with international Occupational Health & Safety regulations.

A workforce manager in charge of all activities, and in charge of compliance with health and safety requirements reporting directly to the ERE AB project manager and will have independent lines of reporting to ERE AB upper management.

Prior to beginning work on the site, the workforce manager will develop a safety program to cover construction and then operation of the site.






Falling overhead objects could cause injury or death.

Falls into or collapse of open excavations could cause injury or death.

Falls from heights (buildings, WTGs) could cause injury or death.

Blasting could cause injury or death.

Contact with electrical lines or transformers could cause injury or death.

Noise and vibration could distress or injure workers or distress residents.

The safety program will include requirements for inspecting, testing, and calibrating safety equipment, for monitoring the working environment for hazards, and for monitoring worker health.

All incidents and accidents will be recorded if they resulted, or nearly resulted, in damage to equipment or injury.

On an annual basis, ERE AB will report to the lender on the status of the overall safety program, including information on training and on incidents. Both ERE AB and all its contractors will be required to produce a Health and Safety Plan for both construction and operational phases.




6 Management and Mitigation Measures

6.1 General Management Approach

6.1.1 Management Awareness

Objective: To ensure that the Project Management team is fully aware of the site environmental standards and are committed to complying with the standards.

It is the site management’s responsibility to ensure that the actions contained in this ESMP are conducted and maintained. Therefore the site management’s awareness of the environmental standards set out in the ESMP is critical to the successful working of the Syvash Wind Farm Site and the attitude that they take will be reflected in the overall conditions prevailing at the site.

The Site Manager will be appointed by East Renewable Energy AB and is responsible for the implementation of the ESMP.

Objective: To ensure that the Project Management team is fully aware of the site environmental standards and are committed to complying with the standards.

It is the site management’s responsibility to ensure that the actions contained in this ESMP are conducted and maintained. Therefore the site management’s awareness of the environmental standards set out in the ESMP is critical to the successful working of the Syvash Wind Farm Site and the attitude that they take will be reflected in the overall conditions prevailing at the site.

ACTIONS

a) Regular site environmental audits, undertaken by the Environment Team to assess the site’s environmental performance against the ESMP, will be used to educate and motivate site management to achieve the desired environmental standards on site by explaining the importance of conforming to the standards and focussing on any areas that require improvement. The responsibility to ensure the mitigation measures are implemented and the relevant environmental legislation is complied with, is set with the site management.

b) The site management will have had environmental awareness training. This will be conducted by talks from the environment team, and include the East Renewable Energy AB environmental policy and environmental issues raised within the ESMP.




6.1.2 Grievance and Incident Procedures

Objective: To ensure that any environmental complaints and incidents that occur on site are reported, investigated and appropriate action taken by following complaint and incident procedures.

Grievance and incident procedures will be in place, that state how any environmental complaint or incident that may arise from the site’s activities will be managed. Any complaint received will be logged at the site or the company offices. All complaints and incidents will be investigated and any necessary corrective and/or preventative action will be taken and recorded.

Complaints and incidents are logged and investigated.

ACTIONS

a) Contact telephone numbers including a 24 hour number will be published in leaflets distributed to occupants of neighbouring premises before site operations commence and will also be detailed on the site entrance sign.

b) The complaint and notifiable incidents procedure/s will be followed by the site management and office staff.

c) Any complaints and incidents are reported to the Environmental Manager who ensures that they are fully investigated, resolved and closed out.

6.1.3 Environmental Audits

Objective: To ensure that the site is regularly audited against this ESMP to monitor the achievement of the environmental objectives at Syvash Wind farm.

Environmental audits are fundamental to ensuring that the actions for each objective contained within this ESMP are established and maintained on the Syvash Wind Farm.

Audits are set to take place provisionally every month from the start of the construction works.

ACTIONS

Before an audit the following documents will be consulted in order to check conformance where applicable:

Any discharge consents and abstraction licences

Planning Permission and conditions

Records of any previous environmental audits, non-conformance notices, complaints and environmental incidents.

a) The measures to control significant aspects outlined in this report and their effective implementation will be checked during regular environmental audits of the site, during the site construction phase.




b) The local government environmental official, representatives from the local community and liaison committee members will be welcome to attend the audits.

c) The results of the audit will be recorded on the environmental audit report and any non-conformances found will be formally recorded along with the action required.

d) Each non-conformance will be issued to the relevant person/s to take the corrective / preventative action detailed within an agreed timescale.

e) The Environment Manager will monitor the progress of actions and once action has been taken it will be checked and if satisfactory the non-conformance will then be closed out. If there are any outstanding actions at the next audit, these will be priority items to check.

f) The audit results will be reported at the site liaison committee.

6.1.4 Project Environmental Committee

Objective 4: To establish and maintain regular environmental committee meetings to communicate the Syvash Wind Farm’s progress and environmental performance and to discuss and address any issues raised.

ACTIONS

a) A Syvash Wind Farm environmental committee will be established prior to commencing the site construction phase and meetings will be held regularly during the construction phase. Meetings will also be held at a frequency agreed by the team, possibly extending into the first year of the operational phase if considered necessary.

b) The purpose of the committee is to discuss relevant issues that arise out of the development which could have an effect on people living or working in nearby properties or enjoying nearby land.

c) Representatives from the local government, Contractors, Wood and local residents’ representative will join East Renewable Energy AB to form the environmental committee.

d) The aim of the committee is to act as a forum for the exchange of information on progress of the site and for the company to listen to any views of local residents relating to the development and respond accordingly.

e) Environmental audit findings will be presented to the committee.




6.1.5 Occupational Health and Safety

Occupational and public health and safety concerns associated with operation and construction of the wind farm will be similar to those from construction and operation of any industrial facility in a remote area. The major potential hazards include:

Movement or operation of passenger and construction vehicles, equipment, and materials could cause injury or death to humans (drivers, passengers, pedestrians) or animals (livestock or wildlife).

Using hand tools or larger equipment could result in accidents that harm or kill workers.

Falling overhead objects could cause injury or death to workers or trespassers. Falls into or collapse of open excavations could cause injury or death to workers

or trespassers. Falls from heights (buildings, WTGs) could cause injury or death to workers or

trespassers. Blasting could cause injury or death to workers or trespassers. Contact with electrical lines or transformers could cause injury or death to

workers or trespassers. Noise and vibration could distress or injure workers or distress residents.

East Renewable Energy AB and its contractors will comply with international Occupational Health & Safety regulations and standards (for example, EU Directive 89/3918 and OSHA9 standards) in addition to Ukrainian safety standards regarding construction works, electrical works, structural climbing and other hazards. In general, construction operations will be planned and implemented in accordance with these standards and with IFC safety guidelines.

There will be a workforce manager in charge of all activities, and in charge of compliance with health and safety requirements. This individual will report directly to the East Renewable Energy AB project manager and will have independent lines of reporting to East Renewable Energy AB upper management. Prior to beginning work on the site, the workforce manager will develop a safety program to cover construction and then operation of the site. The program will describe in detail the potential hazards and the ways in which they will be prevented or avoided. All construction workers (including contractors) will be required to complete a training program that covers the safety program, and training will cover hazard awareness, job- and site-specific hazards, emergency procedures for fire, illness or injury, and natural disaster.




Besides training, the safety program will include detailed requirements for inspecting, testing, and calibrating safety equipment, for monitoring the working environment for hazards, and for monitoring worker health. In addition, all incidents and accidents will be recorded if they resulted, or nearly resulted, in damage to equipment or injury or to humans or animals, will be recorded. On an annual basis, East Renewable Energy AB will report to the lenders and shareholders on the status of the overall safety program, including information on training and on incidents.

Workplace inspections will be undertaken on a regular basis to monitor H&S aspects on site.

Health and Safety aspects are covered in more detail in the East Renewable Energy AB Health and Safety Procedures.




7 Monitoring of Environmental and Social Performance

7.1 Monitoring Programme

A programme of Environmental and Social Monitoring will be undertaken in order to verify the effectiveness of the proposed mitigation measures in reducing impacts and also to allow mitigation measures to be refined or developed as needed to further address potential impacts or to develop plans for future development. More specifically, the objectives of the monitoring program are to:

Record project impacts during construction and operation. Meet legal and community obligations. Evaluate the effectiveness of the mitigation measures and identify any

shortcomings. Allow refinement and enhancement of mitigation measures to further reduce

impacts. Allow identification unforeseen issues or changes in operations and provide

information for development of mitigation measures to deal with those issues or changes.

The environmental and social monitoring program was developed in accordance with the best international practices for the wind energy sector.

7.2 Key Performance Indicators

Key environmental performance indicators for monitoring plan and a full monitoring programme will be developed as part of the final ESMP.

7.3 Reporting

Details of monitoring together with results will be summarised in a monitoring report which will be submitted to the Lenders for approval.

Each monitoring report will cover a period of three months and will be submitted one month subsequent to the end of that monitoring period.




8 ESMP Review

An effective ESMP requires monitoring and updating. If this is not undertaken, the policy that governs it may become out of date and ineffective.

8.1 Scheduling and managing reviews

The implementation of clear internal auditing systems will ensure that the measures contained in the policy are being implemented on a day-to-day basis. As part of the ESMP East Renewable Energy AB will:

Monitor the overall effectiveness of the ESMP against the Key Performance Indicators;

Develop mechanisms to monitor the targets and objectives;

Provide clear definitions of reporting and management responsibilities; and

Regularly schedule reviews of the procedures and practices that underpin the ESMP.

The ESMP will be reviewed following each detailed audit during construction. This is likely to occur on a two-monthly basis. During the first year of operation the ESMP will be reviewed every six months. Following this period, the ESMP will be reviewed annually.

The results of the review will be used to update the ESMP if deemed necessary to either ensure targets are met or to ensure continual improvements in environmental performance.




9 Record Keeping

The following documents are important to the environmental management of the Syvash Wind Farm Site. These will be available on site and will be kept up-to-date by Site Management.

The Syvash Wind Farm ESMP (this document) and all associated plans. Syvash Environmental and Social Impact Assessment. Planning permission, planning/loan conditions and associated documents. Any discharge consents and abstraction licences. Complaint and incident log books and procedures (including grievance

mechanism). Site inspection forms. Results of any site environmental monitoring. Contact names, addresses and telephone numbers for environmental or safety

incidents. Emergency Response Procedure. Environmental audit reports and non-conformance notices. Waste transfer notes for removal of waste from site. Site Waste Management Plan. Training records. Details of ESMP reviews.




6.18.09074.GLA.R.002 Revision B1 Page QACertified to ISO 9001, ISO 14001, OHSAS 18001 and ISO17025

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