Post on 26-Jan-2020
Environmental and Social Monitoring Report
Environmental and Social Monitoring Report – FY June 2019 Project Number: 50200-001 30 September 2019
Triconboston Wind Power Project (Pakistan)
Prepared by Triconboston Consulting Corporation (Private) Limited for the Asian Development Bank
This environmental and social monitoring report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “Terms of Use” section of this website.
In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.
Environmental & Social Performance Annual Monitoring Report-2018-19
3 x 49.735 MW Wind Power Projects
AMR SECTION I
INTRODUCTION
IFC’s I est e t Ag ee e t e ui es fo the Tricon Boston Consulting Corp. Pvt. Ltd. (TBCC), 3 x 49.735
MW Wind farm projects, to prepare a comprehensive Annual Monitoring Report (AMR) on the
Environmental and Social (E&S) performance of its facilities and operations. This document comprises
IFC’s p efe ed fo at fo E&“ pe fo a e epo ti g. This epo t for the period July 2018-June 2019 is
supplemented with annexes mainly related to Birds Monitoring Report (BMR), Stakeholders Engagement
Meetings (SEM) records, Grievance Records, Internal EHS and CSR Audit Reports, EHS Inspection Reports,
Training Evidences and CSR implementation evidences as appropriate in order to ensure that all relevant
information on project performance is reported.
Contents:
• Project Information
• Clie t’s Rep ese tatio “tate e t y “po so autho ized ep ese tati e
• Summary of Key E&S Aspects during the Reporting Period
o Compliance Evaluation
o Major Environmental and Social Achievements
o Major Challenges and Issues
• Key Project Implementation data relevant to E&S Performance Evaluation
• Compliance with IFC Performance Standards
• Action Plan Status and Update
• Deviations/non-compliances
• Clie t’s Feed a k
Environmental & Social Performance Annual Monitoring Report-2018-19
3 x 49.735 MW Wind Power Projects
AMR SECTION II
Project Information
Project Name 3 x 49.735 MW TriconBoston Consulting Corp. Pvt. Ltd.
Project Scope Construction and Operation of 3 x 49.735 MW Wind Farm
Current Stage Operations Phase
Project Chief Operating Officer Khalid Aslam
Plant Director Saquib Saeed
TBCC HSE Manager Abid Hussain
Admin & HR Manager Junaid Nizamani
O&M Contractor General Electric
O&M HSE Manager Arif Malik
HSE & CSR
Independent Monitoring Company
Arch Associates
Environmental & Social Performance Annual Monitoring Report-2018-19
3 x 49.735 MW Wind Power Projects
AMR SECTION I
INTRODUCTION
IFC’s Common Terms Agreement requires for TriconBoston Consulting Corporation Pvt. Ltd (TBCC)
project to prepare a comprehensive Annual Monitoring Report (AMR) on the environmental and social
(E&S) performance of its facilities and ope atio s. This do u e t o p ises IFC’s p efe ed fo at fo E&S performance reporting for the period July 2018-June 2019. The following template is
supplemented with annexes as appropriate to ensure all relevant information on project performance is
reported.
Contents:
• Project Information
• Clie t’s Rep ese tatio “tate e t y “po so autho ized ep ese tati e
• Summary of Key E&S Aspects during the Reporting Period
• Action Plan Status and Update
• Deviations/non-compliances
• Clie t’s Feed a k
Environmental & Social Performance Annual Monitoring Report-2018-19
3 x 49.735 MW Wind Power Projects
AMR SECTION II
Clie t’s Represe tatio “tate e t “po sor authorized represe tati e
I Khalid Aslam in my role of Chief Operating Officer and representing TriconBoston Consulting
Corporation Pvt Ltd certify that
a) The Project is in compliance with all applicable E & S Requirements as described in the Common Terms
Agreement, and all actions required to be undertaken pursuant to the Environmental and Social
Action Plan (ESAP) and any subsequent supplemental action plans.
b) Beyond what is reported in this AMR for the current reporting period, in relation to the Project, to the
best of my knowledge, after due inquiry, there are no:
• Circumstances or occurrences that have given or would give rise to violations of E &S and labor
Laws or E &S and labor Claims;
• Social unrest, local population disruption or negative NGO attention due to the project
• Material social or environmental risks or issues in relation to the Project other than those
identified by the E&S Assessment and the Environmental and Social Review Summary.
• Existing or threatened complaint, order, directive, claim, citation or notice from any Authority.
• Any written communication from any Person, in either case, concerning the Project's failure to
comply with any matter covered by the Performance Standards;
• Ongoing or, threatened, strikes, slowdowns or work stoppages by employees of the Borrower or
any contractor or subcontractor with respect to the Project;
c) All information contained in this AMR is true, complete and accurate in all respects at the time of
submission and no such document or material omitted any information the omission of which would
have made such document or material misleading.
d) There have not been any new company activities (e.g. expansions, construction works, etc) that could
generate adverse environmental effects and there have been no new ESIA studies, audits, or E&S
action plans conducted by or on behalf of TriconBoston Consulting Corporation, with respect to any
Environmental or Social standards/regulation/ applicable to the Project that IFC has not been notified
of
September 30, 2019
Signature Date
Environmental & Social Performance Annual Monitoring Report-2018-19
3 x 49.735 MW Wind Power Projects
AMR SECTION III
(a) Summary of Key E&S Aspects during the Reporting Period
This section aims to identify the key E&S progress/activities/incidents during the Reporting period
(include Summary of Key Findings for the Reporting Period e.g. non-compliances, significant incidents1,
social unrest, significant improvements/initiatives regarding E&S performance. Etc)
1. Key Project implementation data relevant to E&S performance evaluation:
1.1 Start of construction date: 04 Aug 2017
1.2 Start of commercial operation date: 04 September 2018
1.3 Gross electricity generation capacity (MW):3 x 49.735 MW (Total: 149.205 MW)
1.4 Net electricity generation capacity (MW): 149.205 MW
1.5 Gross Electricity generated during the reporting year (GWh/year): Tricon A: 136.9 GWh; Tricon B: 109.6
GWh; Tricon C: 111.8 GWh [Post COD Stats for respective plant]
1.6 Net Electricity generated during the reporting year (GWh/year): Tricon A: 133.9 GWh; Tricon B: 106.9 GWh;
Tricon C: 109.6 GWh [Post COD Stats for respective plant]
1.7 Plant capacity factor (%) – Gross Electricity generated (GWh/year) / Gross electricity generation capacity
MW x 8,760 hour/year: Tricon A: 31.4%; Tricon B: 24.5% ; Tricon C: 25.1% [Post COD Stats for respective
plant]
Please report on:
• Compliance with ESMP
o Currently Issue 1 of Operational Phase ESMP is followed for implementation. The
following areas has been updated w.r.t Operation Phase
▪ Environmental and Social Management Plan
▪ Stakeholders Engagement Plan implementation
▪ Birds Monitoring Plan
▪ Organization Structure and Job Descriptions
▪ Training Plans
▪ System Procedures related to O&M activities
▪ Emergency Preparedness and Response Plan
• Regular ornithological monitoring reports / on-site bird monitoring data
o Birds Monitoring Reports (BMR) for the period Jul 2018-Jun 2019 are attached in
Annexure -1. First Quarter 2019 data reflects the back migration while April-June 2019
data shows decline in birds population and number of species observed in the area
mainly due to high temperature in the area during summer
1 Examples of significant incidents follow. Chemical and/or hydrocarbon materials spills; fire, explosion or
unplanned releases, including during transportation; ecological damage/destruction; local population impact,
complaint or protest; failure of emissions or effluent treatment; legal/administrative notice of violation;
penalties, fines, or increase in pollution charges; negative media attention; chance cultural finds; labor unrest
or disputes; local community concerns.
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3 x 49.735 MW Wind Power Projects
• Progress in ESAP implementation and any updates in relations to ESAP action items
o All the construction phase related ESAP items have been closed.
o Noise Monitoring and Shadow Flicker Monitoring has been initiated in Operational
Phase as required by ESAP
• Major Environmental and Social Achievements
o No equipment safety related incident during transportation and installation of 696
components of WTGs
o Based on the E&S compliance during construction phase, IFC has rated Tricon Boston
Consulting Corp Pvt Ltd E&S perfor a e as E elle t o Using ISO standards, initiation of development and implementation of Quality,
Environment, Occupational Health & Safety, Social, Energy and Asset Management
Systems development as single integrated management system in Tricon Boston
Consulting Corp Pvt Ltd
o Fully Equipped Clinic with ambulatory support to handle the emergencies has been
established at Tricon Boston site. The clinic will cater to both, personal working at
project site as well as to Tricon Boston neighborhood community.
• Major Challenges and Issues for the company
o Cost Effective waste management as due to absence of Sindh Environmental Protection
Agency (SEPA) authorized /approved Waste Management Company in the local vicinity,
the cost of waste disposal through urban center based SEPA approved waste
management companies is high.
o Inclusion of O&M Contractor w.r.t. E&S implementation and their willingness to offer
compliance records for third party/independent verification
Project Status
Select the current status of the project and provide a brief description of the developments in relation to
the project over the reporting period. For example, has construction been started or completed, has new
equipment been installed, has production capacity increased, or is the investment in new projects
considered?
❑Design ❑Construction ❑ Expansion ❑Operation❑ Closure ❑ Other (specify)
Currently project is in Operation Phase since August / September 2018
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Please provide details on the status of the following voluntary Management systems certification schemes
at your facility, provide details below?
Not being
considered
Future
consideration
Planning to
Implement
Currently
implementing
Successfully
implemented
Date of
certification/
re-certification
ISO 9001-Quality Management
System
❑ ❑ ❑ ❑ ❑ ❑
ISO 14001-Environment
Management System
❑ ❑ ❑ ❑ ❑ ❑
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OHSAS 18001-Occupational
Health & Safety Management
System
❑ ❑ ❑ ❑ ❑ ❑
ISO 50001-Energy
Management System
❑ ❑ ❑ ❑ ❑ ❑
SA 8000-Social Accountability
Management System
❑ ❑ ❑ ❑ ❑ ❑
ISO 55001-Asset Management
System
❑ ❑ ❑ ❑ ❑ ❑
Other
• Identification of Risks and Impacts: Based on the actual operation of the Company during the
reporting year, please provide a summary of the key risks and impacts that the Company was
faced with and the actions taken.
o Formal implementation of the CSR initiatives
o Improvement in Local Labor Laws compliance level by O & M Contractor and Sub
Contractors including Security Contractor
• Describe any changes in the organizational structure to manage environment, health and safety,
labor and social aspects during the reporting period. Describe number of personnel in charge of
E&S issues.
o For the Operational Phase, organizational structure of TBC has been revised mainly
w.r.t. HSE Manager. HSE Manager has now been re-desig ated as Co plia e Ma ager ith ajor respo si ilit of H“E I plementation and Monitoring and
Monitoring of Social aspects compliance. Compliance Manager and Administration
Manager of Tricon Boston and HSE Manager of O&M Contractor are in charge of E&S
issues.
• Describe the level of environmental, social and health and safety training provided to staff.
Provide annex with list of topics, hours of training and number of participants.
o Annex-3 provides List of Trainings during the period July 2018-Jun2019, Attendance
Sheets and Training Records.
• During the reporting period, are you aware of any events that may have caused damage; brought
about injuries or fatalities or other health problems; attracted the attention of outside parties;
affected project labor or adjacent populations; affected cultural property; or created liabilities for
your company?
❑Yes ❑No
Provide details Not Applicable
• Stakeholders Engagement---Describe any ongoing public consultation and disclosure, liaison with
non-governmental organizations (NGOs), civil society, local communities or public relations
efforts on environmental and social aspects.
Environmental & Social Performance Annual Monitoring Report-2018-19
3 x 49.735 MW Wind Power Projects
o Currently regular engagement with local communities is in place. This engagement is
done formally as well as informally. During informal engagements done by Community
Liaison Officer (CLO) of Tricon Boston Consulting, feedback including grievances are
seeked a d do u e ted. For for al e gage e ts, stakeholder’s e gage e t eeti gs are planned, community is informed and meeting conducted either at project site or at
neighboring village. Two (02) Stakeholders Engagement meetings have been conducted
till Jun 2019. Annex-6 has record of Stakeholders meetings.
• Briefly describe new initiatives implemented during the reporting period or additional managerial
efforts on E&S aspects (e.g. Energy/water savings, sustainability report, waste minimization, etc)
o Commissioning of 100 kW Solar Pant during the construction phase was one major
energy saving initiative.
o Implementation of ISO 50001 Standard under UNIDO EnMS/REEE program and with the
objective of reducing Energy Losses (reducing plant auxiliary load) identified through
Energy Audit
• Briefly describe the number and type of comments and/or grievances received by the Company
in relation to E&S Issues? How many have been resolved and how many are pending? (Please
attach a table with grievance redress registry)
o During the reporting period of July 2018-June 2019, total eight (8) grievances were
recorded out of which three (03) were internal grievances. All the grievances have been
closed during the reporting phase. During the period May 2019 to June 2019, no
grievance was recorded by O and M Contractor nor by TBC Admin/HR. (Annexure -07)
o Formal recording of grievances has been identified by IMC as area for improvement and
advised TBC Admin to play active role in the resolution of external as well as internal
grievances.
• Provide an update on consultation, if any, with IUCN, WWF, Sindh Wildlife Department, Sindh
Environmental Protection Agency (SEPA) and Sindh Forestry Department.
o No consultation with IUCN, WWF, Sindh Wildlife Department, Sindh Environmental
Protection Agency (SEPA) and Sindh Forestry Department was done during the
reporting period.
• Provide a summary of complaints, if applicable, from the Social Compliant Register (SCR) that you
have committed to develop to document all complaints received from the local communities or
any other stakeholder and to take action and implement the mitigation measure.
Annex-7 includes records related to grievances received from local communities and workers
and their resolution
Environmental & Social Performance Annual Monitoring Report-2018-19
3 x 49.735 MW Wind Power Projects
PS2. Labour and Working Conditions
• Have you changed your Human Resources (HR) policies, procedures or working conditions during
the reporting period?
❑Yes ❑No Provide details
o During audit of HR/Admin and based on the external grievances received, need for
additional procedures was identified in order to document the processes mainly related to
Workers Interview, Skill Assessment and Worker Termination.
• Provide the following information regarding your workforce:
Site # of direct
employees
# female direct
employees
# employees
terminated*
# employees
hired*
# Contractor
employees2
Project Site
(Total) 161 0
Project Owner 34
EPC Contractor
(HydroChina) 38 0
GE,AEPL & Descon etc) 54 0
Retrenchment: If the Company undertook any involuntary retrenchment during the reporting year, please
provide retrenchment data including a copy of the retrenchment plan.
o Tricon Boston Consulting EPC Contractor and its Sub Contractors clearly communicated
to the employees the temporary nature of their job and this was covered in the
Employment Contracts with workers. EPC Contractor prepared a retrenchment plan to
manage the laying off of workers near the end of civil construction phase. Subsequently,
following the completion of installation of WTGs and Sub Station equipments, , the
layoff process has been initiated as per the retrenchment plan and more than 90% of
the workers have left project site. Annex-11 contains the Retrenchment Plan and
sample of Daily Strength Report which records the employees released.
Grievance Mechanism: Please provide a summary of the latest grievance mechanism in effect for workers
to raise workplace concerns (also indicate nature of EHS and social issues raised by workers, communities
and other stakeholders during the reporting period, and the nature of corrective actions taken, its
outcome and status).
o For Internal Grievance Mechanism, following methods are used by workers.
▪ Verbal and / or written complain to Admin & HR of HydroChina & GE
▪ Verbal and / or Written complain to Admin & HR of Tricon Boston Consulting, if
there is no action by the Admin & HR of HydroChina
2 Contractors performing core functions for the Company in the premises of the Company or in the name of
the Company
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3 x 49.735 MW Wind Power Projects
▪ Verbal complaints during Stakeholders Meetings
▪ Complaint Boxes provided at different locations within project area but workers
prefer to use verbal means.
Child Labor / Forced Labor: Please state whether the Company remained compliant with the Child Labor
and Forced Labor requirements of the Performance Standards.
o Tricon Boston Consulting, its EPC Contractor HydroChina and EPC Contractor Chinese
and Local sub-contractors remain complaint with the IFC Child Labor and Forced Labor
requirements during the reporting period.
o Tricon Boston Consulting as placed Child Labor Prohibition sign boards in local language
at different locations for information of local communities and sub-contractors.
Occupational Health and Safety
• Describe the main changes implemented in terms of Occupational Health and Safety (OHS) during
the reporting period, e.g. identification of hazards, substitution of chemicals, new controls, etc.
o Since this is the first operational year of project, therefore no changes have been in the
systems and plans developed/upgraded for operational phase e.g. Environment and
Social Management Plan (ESMP), Stakeholders Engagement Plan (SEP) etc. However
internal audit observations will help in identification of changes in systems and plans in
order to improve effectiveness of compliance.
• Please provide details (description, pictures,) on the accommodation standards if the construction
camp is to be established for the workforce on the site
o Currently Project is in Operational Phase and construction camp for workers
accommodation is not in use.
Occupational Health and Safety Indicators
Report Total numbers for each
parameter This reporting period Reporting period – Previous
year
Direct
employees
Contractor
employees
Direct employees Contractor
employees
Total number of Workers 35
Male Workers 35
Female Workers 0 0
Total Number of Direct Workers 35
Total Number of workers who are
members of workers organization
34 0
Name of Workers Organization
Total man-hours worked – Annual
Total number of lost time occupational
injuries
0
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3 x 49.735 MW Wind Power Projects
Total number of lost workdays due to
injuries
0
Number of fatalities 0
Occupational Health and Safety Performance (Construction / Operation Phase) (IFC E&S DOTS Indicator)
Item Number Target
Employees Contractors Total
A: Fatalities:3
0 0 0 0
B: Total Lost Time Accidents
(including vehicular):4
0 0 0 N.A.
C: Total number of lost workdays
resulting from incidents: 5
0 0 0 N.A.
D: Total man-hours worked this
reporting period:
0 0 0 N.A.
E: Incidence during this reporting
period:
(Note: Incidence = total lost
workdays / total hours worked)
0 0 0 N.A.
F: Lost Time Injury Frequency
Rate
(Number of lost time accidents x
1,000,000 hours / total man-
hours worked = injuries per
million hours worked)
0 0 0 11.0 or less
(construction phase)
4.5 or less (operational
phase)
G: Lost Time Severity Rate
(Total Lost workdays x 1,000,000
hours / total man-hours worked
= lost workdays per million hours
worked)
0 0 0 N.A.
• Provide details for the non-fatal injuries during this reporting period
None to report
3 Please attach separate reports detailing the circumstances of each fatality.
4 In capacity to work for at least one full workday beyond the day on which the accident or illness occurred.
Environmental & Social Performance Annual Monitoring Report-2018-19
3 x 49.735 MW Wind Power Projects
Company or
contractor
employee?
Total
workdays
lost
Description of injury5 Cause of accident Corrective measures
to prevent
reoccurrence
Project Owner 0
EPC & O&M
Contractor 0
EPC & O&M
Contractor Sub-Contractor
0
• Describe in detail fatalities and vehicle accidents, including corrective measures (provide copies
of OHS investigation and respective corrective plan).n
None to report
Date of
Incident
Type of Incident
(drop down list)
Brief Description
of Incident
Fatalities?
(Y/N)
# of
Fatalities
Preventive measures
taken after the incident
Note: Choose the Type of Incident from the drop down list.
Improvement Trend of Occupational Health and Safety Performance
Item 2017 2018 2019 2020
A: Fatalities:
[Employees] [Contractors] [Total]
0 0 0
B: Total Lost Time Accidents (including vehicular):
[Employees] [Contractors] [Total]
0 0 0
C: Total number of lost workdays resulting from incidents:
[Employees] [Contractors] [Total]
0 0 0
D: Total man-hours worked this reporting period:
[Employees] [Contractors] [Total]
0 0 0
E: Incidence during this reporting period:
[Employees] [Contractors] [Total]
0 0 0
F: Lost Time Injury Frequency Rate
[Employees] [Contractors] [Total]
0 0 0
G: Lost Time Severity Rate
[Employees] [Contractors] [Total]
0 0 0
5 Injury: Incapacity to work for at least one full workday beyond the day on which the accident or illness
occurred.
Lost workdays are the number of workdays (consecutive or not) beyond the date of injury or onset of illness
that the employee was away from work or limited to restricted work activity because of an occupational
injury or illness.
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3 x 49.735 MW Wind Power Projects
Workers Engaged by Third Parties: Please provide a summary of how the Company is managing and
monitoring the performance of third party employees in relation to the requirements of the Performance
Standards.
• TBC performs through IMC Quarterly audit of EPC/O and M Contractor (HydroChina)/GE for HSE
and Social Accountability (HR & Admin) systems implementation. Similarly TBC binds HC to
performs audits of its sub-contractors and report the audit results and performance ratings.
PS3. Resource Efficiency and Pollution Prevention
• Provide the following environmental monitoring data for this reporting period. If you already have
all the data requested available in another format, this can be submitted instead. Please provide
a scaled facility map showing the precise locations of all monitoring points.
o IMC advised EPC/O and M Contractor to perform Noise Monitoring on weekly basis and
report the results in the HSE Performance Reports. Annex-14 includes Noise Monitoring
Reports for the period July 2018-June2019.
Ambient Noise Residential, Institutional or Educational Monitoring Point Location6:
Ambient Noise Industrial or Commercial Monitoring Point Location8:
Ambient Noise Parameters Collection
Frequency
WBG/IFC
Maximum
Levels
(WBG/IFC Units)
TBCC Performance
(WBG/IFC Units)
Annual average of
quarterly samples
Pakistani
Maximum Levels
(Pakistani Units)
TBCC Performance
(Pakistani Units)
Annual average of
quarterly samples
Nearest Residential,
Institutional or Educational
Receptors
Daytime (07:00-22:00 hours) Quarterly 55 dB(A) dB(A)
Nearest Residential,
Institutional or Educational
Receptors
Nighttime (22:00-07:00 hours) Quarterly 45 dB(A) dB(A)
Nearest Industrial or
Commercial Receptors
Daytime (07:00-22:00 hours) Quarterly 70 dB(A) dB(A)
Nearest Industrial or
Commercial Receptors
Nighttime (22:00-07:00 hours) Quarterly 70 dB(A) dB(A)
Distance from the site
boundary to the closest noise
receptors m 20-30 m
Greenhouse Gases
6 Provide latitude, longitude of ambient noise monitoring points. Alternatively provide a scaled map showing
the precise location of the monitoring points.
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3 x 49.735 MW Wind Power Projects
• Whilst this is a carbon friendly project that may generate carbon credits, please provide an
approximate measurement of total GHG emissions from the project (e.g., vehicles, generators
etc.)
• GHG emissions avoidance of the Project (IFC E&S DOTS Indicator)
As the project is not opting for carbon credits at this moment, therefore GHG emissions due to
diesel and other fuel consumed at the project site during O&M phase are not calculated.
However fossil fuel consumption data for backup generator and vehicles is recorded by O&M
team
Year Gross
electricity
generation
(MWh /
year)
Auxiliary
electricity
consumption
(MWh / year)
Net
electricity
generation
(MWh / year)
Grid emission
factor
(tonCO2 /
MWh)
GHG
emissions
avoidance
(tonCO2 /
year)
A B C = A – B D E = C x D
PDD for
CDM
Actual
[2016]
2017
2018
• Note: PDD for CDM (Project Design Document, completed [date])
• Estimated CO2 Emissions from Mobile Sources (Gasoline Vehicles)
Total
number
of
vehicles
Total
length of
distance
travelled
(km)
Gasoline
consumed
Gasoline
vehicle
efficiency
(litre /
km)
CO2
emissions
factor
(kgCO2/TJ-
LHV)
CO2
emissions
(tonCO2) (litre) (TJ -
LHV)
A B C D=B/A D=69300 E=BxD/1000
2016 69300
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3 x 49.735 MW Wind Power Projects
[2017]
[2018]
[2019]
-----
• Note: CO2 emissions factor (gasoline) 69300 kgCO2/TJ-LHV from 2006 IPCC Guidelines.
• Estimated CO2 Emissions from Mobile Sources (Diesel Vehicles)
Total
number
of
vehicles
Total
length of
distance
travelled
(km)
Diesel
consumed
Diesel
vehicle
efficiency
(litre /
km)
CO2
emissions
factor
(kgCO2/TJ-
LHV)
CO2
emissions
(tonCO2) (litre) (TJ -
LHV)
A B C D=B/A D=74100 E=BxD/1000
2017 74100
2018
2019
2020
2021
Resource Efficiency – Wate Co se atio Measu es: Du i g app aisal of the P oje t, a out [●] 3 pe day of water was estimated to be required during the operational phase of the Project, and considering
the general scarcity of water in the region, the Company was planning to adopt water conservation
measures including using recycled water as much as possible. Please provide a summary of the water
conservation measures implemented during the reporting year.
Compared to construction phase, water consumption quantity in operational phase is not significant.
Plant operations and maintenance activities do not require water and all the water requirement is
limited to accommodation building. As water is purchased to meet the accommodation building
requirements, therefore water consumption data is recorded, however as this is the first operational
year, therefore water conservation and efficiency opportunities cannot be identified unless second
operational year water consumption data is compared with the first year.
Pollution Prevention – Waste: Please provide a summary of non-hazardous and hazardous waste
generation and minimization activities using the table below. Please add a summary description of major
recycling activities conducted.
Environmental & Social Performance Annual Monitoring Report-2018-19
3 x 49.735 MW Wind Power Projects
Waste and Hazardous Materials
• Tricon Boston ESMP has ensured that O and M Contractor collects and quantifies the disposed
waste. Since Jan 2019 O and M Contractor has started quantification of waste
6.11. Solid Waste Management
Solid Waste refers to non-liquid, non-soluble materials that contain complex substances. Examples of
solid waste include sewage sludge, agricultural refuse, demolition wastes, and mining residues, some
which are applicable only to specific sectors.7
TBCC is required to monitor methods of collection, storage, handling, recycling, reuse and/or disposal of
solid waste, and report these methods and measured quantities to IFC. Please complete the information
below.
Solid Waste Management Summary
IMC as a result of formal audits of Waste Management Plan, proposed number of practical actions for
improving the current state of hazardous and non-hazardous handling and solid and liquid waste
collection, quantification and disposal of waste including monitoring of waste disposal activities
performed by Waste Management Company.
Solid Waste Type
Includes description
Annual
Quantity
TBCC Method of Storage, Handling and/or Treatment
Waste from Kitchen
and accommodation
building including
offices
60,000 kg
from Project
A, B & C
All the waste (paper, plastic, metal etc) are collected from the
source by sweepers. In the waste yard, paper, plastic and
metal waste are stored in separate large size drums. No
treatment of any waste is performed. Similarly any waste if
generated at the WTG locations is collected and stored in the
waste yard.
Solid Waste Type
(Same as Above,
Description not
Included)
TBCC Method of Recycling, Reuse or Disposal8
Waste from Kitchen
and accommodation
building including
offices
Presently TBCC is not using any option of Reuse or Disposal and all the waste
collected at the project site is sold to Waste Disposal company who further
sells the plastic and metal waste to contractors/middle men collecting waste
for the recycled industry. Oil and Grease waste generated at WTG during
maintenance activity has not been sold to any contractor and presently
stored at the site. This waste is under the administrative control of O&M
Contractor and in future it will be sold to contractor/middlemen who further
sells to Lubricating plant for extraction of baseline from these waste.
7 Pollution Prevention and Abatement Handbook, Glossary of Environmental Terms
8 Describe disposal method (e.g. landfill, incineration, land farming, reuse, etc.) Provide name and location of
disposal facility used; state if waste is sold as byproduct, scrap or a material to be used by others; state name
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6.12. Hazardous Materials Management
• Hazardous materials are those materials that represent an excessive risk to property, the
environment or human health because of their physical and/or chemical characteristics.
Examples include explosives, toxic or flammable gases, flammable liquids and solids, oxidizing
substances, radioactive materials and corrosive substances.
Presently no Hazardous and Hazardous waste is recycled at the project site and sold to
Waste Management Company
• Non-hazardous and Hazardous Waste Minimization Activities
Item Non-hazardous waste Hazardous waste
Generated
(ton)
Re-
cycled
(ton)
Disposed
(ton)
Recycling
ratio (%)
Generated
(ton)
Re-
cycled
(ton)
Disposed
(ton)
Recycling
ratio (%)
A B C=A-B D=B/A E F G=E-F H=F/E
• Please add a summary description of major recycling activities conducted.
No recycling activity done at the project site during the review period
• TBCC is required to monitor methods of collection, storage and disposal of hazardous materials9,
and report these methods and measured quantities to IFC. Please refer to the Hazardous
Materials Management guideline for additional information.
1. Please update us on your Hazardous Materials Management Program. You should include your
Emergency Preparedness and Response Plans, and if available, your Hazardous Materials Risk
Management Plan, Hazardous Materials Transportation Plan and/or Hazardous Waste
Management Plan.
Hazardous Material Management Plan is included in the annexure of Environment and Social
Action Plan
and business of purchaser. Provide additional sheets as needed to fully describe disposal, organizations
involved in waste management, facility permits, and agency authorizations.
9 Hazardous materials include ignitable, reactive, flammable, radioactive, corrosive and toxic substances.
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Pollution Prevention – Liquid Effluent Monitoring Results: For the diesel generators installed for
emergency power supply to be operated only as back-up, please provide a summary of how the
small quantity of oil/oily water was treated by oil/water separator during the reporting year.
• Oil/Grease from the generator is collected but not drained but stored separately.
Pollution Prevention – Noise: Please provide a summary of the noise monitoring results showing
that the monitored ambient noise levels at Project affected communities were in compliance
with Pakistan noise standards and IFC EHS Guideline noise limits of 45 dBA nighttime and 55 dBA
daytime.
During the operational phase, Noise Monitoring w.r.t. WTGs is performed for Tricon A,
B & C and data attached in Annex-14
Pollution Prevention – Shadow flicker: Please provide a summary of the shadow flicker
monitoring results and evaluation of the accumulated exposure on residential
properties/hamlets against recommended criteria of 30 hours per year, and whether additional
mitigation measures were determined to be necessary, and if so, how they were implemented.
• Shadow Flickering data –Annexure -14
PS4 - Community Health, Safety and Security
• Using the table below list and briefly describe any new initiatives implemented in relation to
community health and safety during the reporting period. Include risk assessments, new
infrastructure and equipment; hazardous materials and safety management, transportation and
exposure to disease.
o Fully equipped Clinic has been established at Tricon Boston to manage the emergencies
related to project employees and to neighborhood villages.
Mitigation Measure Expected or actual date
of Implementation Planned future
mitigation efforts?
• During the reporting period any emergency drills have been conducted with community
participation? Are the communities aware of the emergency response plans?
o Fire Drills were conducted but No emergency evacuation drill conducted during the
reporting period. Emergency Drill is planned for last quarter of 2019
• Please des i e a y ha ges i the Co pa y’s e gage e t ith p i ate/public security forces
during the reporting period and any corresponding agreements.
o No change in TBC engagement with private / public security forces.
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• Implementation of key actions for community health and safety: Please provide a summary of the planned
key mitigation measures of the following during the reporting year:
• Cordoning off the construction site from free public access;
o No physical barrier is erected to prevent access of local villagers. Only work sites
are e.g. WTG, Sub-Station etc. are properly barricaded to prevent free public
access due to safety of the public and the people working at the site.
o Security Guards and watchmen have been trained to prevent movement of
public /non-related persons to the construction site. Refer Annex-3 for records
• Placing information boards about public safety hazards and emergency contact information in
the Project area in the local language;
o Safety sign boards are placed at the work sites. Contact Numbers are
displayed at the TSF entrance / reception.
• Ensuring that construction phase workers are housed in labor accommodation facilities built
at least 1km from any communities;
o Workers accommodation is constructed within the TSF boundary and
away from the neighboring villages
• Providing health and safety training to raise awareness about STDs and HIV;
o Not yet conducted.
• Maintaining worker behavior standards;
o Admin Officer of HC and TBCC ensure discipline within the project boundary.
• Requiring each contractor to ensure that communities be advised in advance of project
progress and near term activities where transport issues have the potential to impact local
communities.
o Community Liaison Officer of TBC and HC and GE informs to the local villagers
duri g i for al i tera tio s. This is also do e through stakeholder’s engagement meetings.
b) Implementation of key actions for security personnel management: Please provide a summary of
the planned key mitigation measures of the following during the reporting year:
• Providing necessary trainings to the security staff about the appropriate use of force where
applicable toward workers and affected communities in line with IFC PS4.
• TriconBoston Consulting has developed Security Management Plan (SMP)
based on IFC PS 4. Security Consultants conducted first monitoring visit in Sep
2017 followed by training sessions of Security Company and local watchmen
trainings on SMP protocols. Third implementation monitoring of SMP was
conducted in March 2019 and Monitoring reports and training records are
included
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PS6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
Birds Monitoring and Turbine Shutdown System
(i) Please provide detailed summaries of all birds monitoring data, bird strikes, shutdown
orders as per the requirements of the ESAP and the EMP (as appropriate use the template below
to report this information).
• Collision Risk Analysis is provided in Annexure-1
(ii) Please provide summary of monitoring undertaken (name of consultants (if used), hours
and frequency of monitoring techniques and survey methodologies used for birds.
• Arch Associates is performing the Ornithological studies. An Ex-WWF Ornithologist
and three surveyors perform the monitoring activities based on the Birds Monitoring
Plan. Birds Monitoring Plan is developed using the Scottish Natural Heritage guideline
(referred by IFC in EHS Guideline for Wind farms Aug 2015). Currently during
construction phase, Vantage Point methodology is used. Three Vantage Points have
been identified across Project A, B & C and monitoring is done on daily basis during
morning and evening hours. Refer to Annex-1 for Birds Monitoring Report..
Biodiversity Value Key Performance Indicator Comment
Collision Risk Analysis summary Bird mortality (wintering,
migratory, breeding species).
List species killed and
conservation status
Annexure-1
Turbine shutdown System
TBCC will retain an
Independent Ornithological
Expert (IOE) to establish a
monitoring program that would
contain an agreed protocol for
mitigation measures, including
the reduction of the speed of
the turbines or, potentially, for
the turbines to be temporarily
turned off should a migrant
flock be observed to be
approaching either site.
Date and duration
Specify whether species are
resident, migratory, breeding or
over-wintering in the area
• Please attach monitoring reports and data as necessary
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Implementation status of the key actions: Please provide the implementation status / key
findings and follow-up actions of the following: • [Bird monitoring activities by a bird monitoring consultant ([name]) retained by the Company];
o TriconBoston Consulting Corporation (TBCC) has retained Arch Associates (AA) as consultant for
performing the ornithological studies. An Ex.WWF Ornithologist and three surveyors perform
the birds monitoring using the Vantage Point methodology as per Scottish Natural Heritage
protocols.
• Detailed and prolonged studies on the impacts on birds to be conducted during the migratory season of
birds (October – March) and the bird monitoring report issued by [name];
o Birds monitoring studies were conducted initially during the period of September 2015-March
2016. The second Birds monitoring study under ESAP commenced from October 2016 and
continued to date. Five reports covering the migratory season have been developed and issued
for the period October 2016-December 2016, January 2017 to June 2017, Jul-Sep 2017 and Oct-
Dec 2017 and Jan-Jun 2018 and July 2018 to June 2019. Refer to Annex-1 for reports for the
period July 2018-Jun 2019
• Bird mortality count in the immediate vicinity to establish any links between the wind turbines and birds
mortality for two years starting from the commissioning of the wind farm;
o Ground Search Method
• Review of the results and recommendations of the [bird monitoring study], and the need for additional
mitigation measures beyond what were described in the [Final Initial Environmental Examination Update].
o The fi al itigatio easures a ’t e deter i ed at this stage as the proje t area has undergone major change w.r.t. food availability due to last rainfall (July-Aug 2017) which has led
to increase in number of birds (birds count) and number of species. The winter migratory season
under the changed environment i.e. with high food availability witnessed high population in Oct
2017 however in Nov-Dec 2017 population decreased most likely due to the construction
activities (Noise). However the population observed and reported in Birds Monitoring Report for
the period upto June 2019 confirmed that Jhimpir is the migratory birds fly path /route. The area
continued to experience birds movement till the period April 2019 however with the increase in
temperature in May-till June 2019, birds population decreased. As per the weather forecast,
Jhimpir area is expected to receive high rainfall in coming months Jul-Sep 2019 which will impact
the birds population as well as birds species in positive manner
(iii) What changes, if any are being proposed to the ESMP based on this monitoring?
• Yes, monitoring of area rehabilitation needs to be included in the ESMP based on the
Ecological Assessment
• As the project has completed its construction phase, ESMP and other related has been
amended w.r.t. Operational Phase activities
(iv) Summary of any coordination or engagement with any local or international bird NGOs/
conservation organizations.
• Formal engagement with any local or international NGO regarding conservation is planned for
2020. For this TBC will arrange consultation workshop in March 2020 at project site with SEPA,
WWF, IUCN, Wild Life, District Government, Wind Farm Association and Local NGO
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(vi) Please summarize any changes in Pakistani law relating to any Environmental Matter
concerning the Project
• Recent No Objection Certificates (NOC) issued by Sindh Environmental Protection Agency
(SEPA) to wind farms, explicitly mention the IFC Performance Standards as the criteria for
compliance w.r.t. EHS.
• Sindh Government has issued Occupational Safety & Health Bill 2017 which requires
consideration of psychosocial factors in the Risk Assessment Process. Therefore TBC HSE in
coordination with EPC Contractor HSE and O&M Contractor HSE will perform the Job based
Risk Assessment considering all parameters e.g. ergonomic, psychosocial etc as required by
the law
(vii) Please provide a summary of any changes to the Jhimpir wind corridor area and any new
regulatory action associated with the area including management requirements or restrictions.
• Atleast ten new wind farms will be constructed in the area adjacent to Tricon Boston during
the period Dec 2019-April 2021
• Since some of the wind farm projects comes under China-Pakistan Economic Corridor (CPEC),
therefore Government of Pakistan has increased the security of the area.
(viii) Please provide a summary of any agricultural crop management restrictions or controls that
TBCC has required/ implemented to control or mitigate risks to biodiversity
• Except for the required excavation as per the approved drawings for the construction of access
roads, WTG foundations, TSF and Sub-Station and cabling trench, no other area (within the
project boundary) has been excavated by EPC Contractor or their sub-contractor and TBC HSE
and IMC HSE team monitoring the area for compliance. EPC Contractor has excavated some
land within the buffer zone area for the purpose of backfilling at WTG foundation. These
excavated lands have been backfilled with top layer and surface restored to original. Few
excavated lands have been left on the request of villagers as they want to use those excavated
lands as the water storage tanks during rainfall. Local neighborhood will use these water
storage ponds to manage their water requirements for agriculture produce.
Using the table below describe any new activities or expansions that have increased the project footprint
into new areas of habitat during the reporting period.
New activity/expansion Total area covered Habitat type
No new activity Same as per original
plan/layout
Using the table below provide details of (deforestation i.e. removing the plantation) conducted during
the reporting period.
Site Total area
cleared of
mangroves/
plantation
Type of species
lost Total area
replanted Type of
species
planted
Replanted
mangroves for
commercial
use Y/N
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Tricon Boston
Consulting Corp
Ecological Assessment was conducted and report submitted to TBC. If the project area experiences
heaving rain in coming months Jul-Sep 2019, then Ecological Assessment report validation will be
performed
Corporate sustainability activities: Please provide a summary of the Co pa y’s o po ate sustainability activities (e.g. corporate social responsibility activities, corporate community
support activities, corporate sustainability reporting activities), if conducted during the reporting
year.
o Since the Micro level household survey is now completed, TBC Admin/HR department will now
finalize CSR Activities and develop implementation plans for the Operational phase
o CSR Activities under implementation by EPC Contractor (HydroChina)
• Provision of Drinking water to all seventeen neighboring villages
• Access to Medical Clinic facility to local villagers
2. Implementation status of the Environmental and Social Action Plan (ESAP): Please provide a summary of the
implementation status of the ESAP using the table below. Please add relevant supporting documents / reports
as necessary.
E“AP (i luded i IFC’s E i o e tal a d “o ial Re ie “u a y, dis losed o [date])
Task Title & Description Anticipated
Completion
Date
Implementation
Status
No. 1: The Company will get the Social Environment
Health & Safety Policy signed by its management, and
will display at its corporate office, the project
operation site and at the Co pa y’s e site.
Policies related to
Environment,
Occupational Health
& Safety and Social
Responsibility are
displayed at
different locations
within project site.
No. 2: The Company will monitor the CPPA-G’s [a d National Transmission and Despatch Company (NTDC)
Li ited’s] p og ess of thei E i o e tal I pa t Assessments for associated transmission lines and a
NTDC Environmental
Study conducted and
copy will be seeked
from NTDC or Sindh
Environmental
Protection Agency
(SEPA) office or
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Task Title & Description Anticipated
Completion
Date
Implementation
Status
substation that are needed for successful
implementation of the Project.
confirmation from
SEPA will be seeked
No. 3: The Company will update the Corporate Social
Responsibility (CSR) program to meet the requirement
of the Sindh EPA IEE approval of [date].
DEC 2019 Community
Development Plan /
Corporate Social
Responsibility (CSR)
Plan has been
developed with
different short and
long term action
items. The plan is
yet to be presented
to Sapphire Group
board for approval
and budget
allocation.
No. 4: The Company will appoint (i) EHS Manager and
Community Relationship Officer prior to start of the
construction, and (ii) Engineering and EHS Manager,
prior to start of the operation.
Appointed and
deputed at the
project site. EHS
Manager and
Community
Relationship Officer
submitted in last
report
No. 5: The Company will establish its HR policy and
procedures in line with IFC Performance Standard 2.
Developed and
Implemented.
No. 6: The Company will develop an Employment Plan
which defines requirements and procedures on
identifying and developing employment
opportunities, managing employees, recording and
reporting employment data, terminating work
contracts, and other labor-related issues, with an aim
to enhance local employment. The Plan will include a
skill development program to help enhance
employability of the local population, and a local hiring
program to ensure that unskilled and semi-skilled
labor be hired from the local communities.
Employment Plan is
covered as one of
the action item
under the
Community
Development Plan /
CSR Plan.
No. 7: The Company will prepare the storm water
diversion plan that will help to increase irrigation of
the surrounding open area for the local villagers.
Storm Water
Diversion Plan has
been developed and
its implementation
will be monitored
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Task Title & Description Anticipated
Completion
Date
Implementation
Status
by IMC. Also
effectiveness of
these plans will be
verified if the
project area
experiences heavy
monsoon rains in
coming months of
Jul-Sep 2019
No. 8: The Company will review the results and
recommendations of the bird monitoring study to be
conducted by [name to be provided], and determine
the need for additional mitigation measures beyond
what were described in the [date] IEE Update (e.g.
operational turbine shut-off).
Birds Monitoring
Reports for period
from Jul 2018 till Jun
2019 are attached in
Annex-1. Monitored
data indicated
increased birds
population at
Project C as the area
has thick vegetation
and food
availability.
However the birds
population
decreased in the
project area as the
temperature
increased in May-
Jun 2019
No. 9: The Company will re-engage with the IUCN /
WWF-Pakistan and other wind farm developers in the
Jhimpir Wind Corridor to initiate discussion about
benefit of sharing bird monitoring data and expertise
so far accumulated and feasibility for a joint
evaluation of cumulative impacts of wind farms on the
birds and bats. Based on this discussion, the Company
will prepare an action plan way forward and start
implementation.
Currently no
progress has been
made as not all
wind farms mainly
those having local
lenders are not
performing formal
birds monitoring.
3. Implementation status of the Environmental and Social Management Plan:
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Please provide a summary of the implementation status of the following:
3.1 I ple e tatio status of the [ P oposed E i o e tal a d “o ial Ma age e t Pla fo the TBCCL Wind
Energy Proje t ]. (Please atta h opies o ele a t audit epo ts a d o o itoring results).
o Refer to Annex-4 (HSE Inspection Records) ,5 (HSE Audits) ,12 (HR/Admin Audits), 15 (EPC/O&M
Contractor and Sub-Contractor HSE Performance Reports)
3.2 Implementation status of [(Mitigation Measures) of the Shadow Flicker Study Report of 150 MW Wind
Power Project of TBCCL].
o Since the project has completed its construction phase in September, WTG Noise Monitoring
and Shadow Flicker Study has been initiated and reports attached in Annex-14
3.3 Implementation status of [Stakeholder Engagement Plan, Tricon Boston Consulting Corporation (Private)
Limited].
o As per the Stakeholders Engagement Plan, 2 meetings have been conducted since the Operation
phase started. Evidences of stakeholder meetings are attached in Annex-6.
4. Conclusion/Recommendation (Please p o ide su a y assess e t of Co pa y’s pe fo a e a d suggested
next steps)
o The project is in overall compliance with most of the applicable IFC Performance
Standards at the maximum w.r.t. Environment, Occupational Safety and Social
Accountability standards compliance at work
o TBC HR/Admin will identify CSR activities which TBC and O&M Contractor will
undertake after EPC Contractor warranty period ends and include these in Community
Development /CSR Plan
o It is suggested that from July 2019, TBC HSE and Admin/HR heads conduct regular in-
depth audits of EPC Contractor and Sub-Contractor against IFC Performance Standards
and compile the observations as data and track E&S compliance performance through
data analysis.
o The Operational Phase Stakeholders Engagement Plan requires quarterly formal
eeti gs/e gage e ts duri g i itial ears of Operatio al. It’s ad isa le that TBC HR/Admin follows the meeting frequency as recommended in the Stakeholders
Engagement Plan and reports to senior management of TBC value component derived
through these engagements which should be meaning full for both TBC and neighboring
community
o Security Management Plan needs to be updated in the context of Operational Phase
requirements and should be supported by specific security related standard operating
procedures related to access control, CCTV surveillance, theft and pilferage control etc
o Occupational Safety and Health Hazards related to armed Security Guard activities e.g.
weapon cleaning, weapon issuance and storage, needs to be identified and
incorporated formally in the HSE System
o As TBC has the advantage of having strong IT infrastructure and human resource
available at site, this resource can be used for digitalization of HSE and HR/Admin
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related activities e.g. tracking of HSE violations, Tracking of Grievances, tracking of audit
non-conformities, data analysis etc