“NTS” - Total Eren · 2020. 11. 20. · “NTS” Our ref.: P.016410.2004 AA 93004 TS:...

TRACTEBEL ENGINEERING S.r.l. Viale Avignone, 12 – 00144 Rome – ITALY tel. +39 06 203990 - fax +39 06 203990 16 [email protected] tractebel-engie.com

“NTS”

Our ref.: P.016410.2004 AA 93004

TS:

Imputation:

Client : Lenders: EBRD, EIB, PROPARCO; Sponsor: TOTAL EREN

Project : 131,35 MWp Solar Tracking Bi-Facial PV project – Tutly Uzbekistan

Subject : NON-TECHNICAL SUMMARY

Comments:

01 2020/11/06 A A.JANAS G.MANCINI M.BALDINI

00 2020/09/28 I A.JANAS G.MANCINI M.BALDINI

REV. YY/MM/DD STAT. WRITTEN VERIFIED APPROVED VALIDATED

TRACTEBEL ENGINEERING S.r.l. – Company with a Sole Shareholder, Share Capital Euros 276.836,00 entirely paid up Tax Code, VAT No., Register of Companies (Chamber of Commerce of Rome) 10248651001, R.E.A 1220672. Company subject to Management and Coordination by Tractebel Engineering S.A. under article 2497 and following of the Civil Code

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P.016410.2004 RE 82001 00 2/12 CONFIDENTIAL

P.016410.2004 AA 93004 01 2/12 CONFIDENTIAL

Index

1. PROJECT DESCRIPTION ....................................................................................................... 3

Project Benefits .......................................................................................................... 4

Project cumulative impacts ....................................................................................... 4

2. IMPACTS, MITIGATION MEASURES AND SOCIAL BENEFITS ........................................... 6

Water resources ......................................................................................................... 8

Landscape and Visual Impact ................................................................................... 8

Local traffic, road safety, noise and vibration ......................................................... 8

Impacts to existing infrastructure and Public Services ......................................... 9

Consistency with Policy, Law and other plans ....................................................... 9

Social Management Plans, mitigation and compensatory measures ................. 10

Public consultations, Stakeholder Engagement Plan and Grievance Redress Mechanism ................................................................................................................ 10

3. IMPACTS MONITORING ....................................................................................................... 12



1. PROJECT DESCRIPTION

The European Bank for Reconstruction and Development (“EBRD”), The European

Investment Bank (“EIB”) and Proparco are considering providing financing to Total

Eren (“The Sponsor”) /Tutly Solar LLC (“The Project Owner”) for the construction

and operation of a 100 MW solar photovoltaic power plant (“the Plant”) in Tutly,

Uzbekistan. The construction phase is estimated to be completed within 12 months.

The Plant will operate for at least 25 years after which it will be either transferred to

the Government or decommissioned and the land will be returned to its original

state.

Construction of the Plant is expected to start in Q1 2021, with Commissioning of

the plant expected in Q4 2021.

The Plant will be constructed upon a piece of land (the “Project Land”) extending

over approximately 350 Ha comprised of flat arid steppe currently used by the local

population for livestock grazing. The Land is owned by the State of Uzbekistan and

has been leased to the Project Owner for the duration of the Plant’s operation.

According to Uzbek National legislation (“National legislation”) the project has been

categorised as a “Category II”, which corresponds to “medium risk of environmental

impact”. According to EBRD rating criteria, the project is classified as category B

(ESP, 2014).

The Project Owner has been granted a positive State Environmental Appraisal has

following its submission to the authorities of the first stage Environmental Social

Impact Assessment (ESIA). Prior to Commissioning of the Plant an updated version

of the ESIA will have to be filed and approved by the Authorities. Construction works

can begin without further permitting being obtained.

The precise breakdown of workers needed for the construction phase had not been

defined at the time of writing this NTS, however it is estimated that a maximum of

300 people will be engaged during the peak of construction. The operational phase

of the Project it is expected to employ 24 people of which 18 workers, and 6

administrative management staff and engineers. As part of the ESIA, the

Sponsor has developed an outline of the Environmental and Social Management

and Monitoring Plan (ESMMP) to provide the Project Owner and the EPC

Contractor with the appropriate framework. Under the ESMMP the Project Owner

will be responsible for approving appointments and contracts as well as the

appointment and supervision of the HSE Supervision Consultant.



Project Benefits

The Studies conducted on renewable energy in Uzbekistan show that solar energy

offers a very large potential (2058 Terawatt TW). The Project will contribute to the

Uzbek Government’s Goal to increase the Solar power to 2.3 % by 2025.

The Project will contribute to improve local power supply and reliability and will

promote economic development in the region as a result.

Further, as the Government is actively attracting the private sector to invest in

renewable energy, the success of the Project might create a precedent that will

encourage further private investment in the sector and in the Country.

The project alternatives considered include the “Do-Nothing” option and a

comparative analysis of anticipated impacts in terms of pollution from the

construction of a 100 MW fuel firing power plant.

From a socio-economic point of view, the project benefits will be evident in the

region when the additional energy availability will allow for further economic

development. The job creation will be limited to unskilled labor (temporary);

however, the local population may be incentivized to train in skilled professions

which may become useful during the lifetime of the project and beyond. Training

has been included amongst the requirements of the Environmental Social

Management Plan (ESAP) to be implemented as part of the implementation of the

Employment Management Plan.

Indirect benefits, depending on what will be defined as final plans by the Project

Owner and the Sponsor, may include access to a phreatic well providing drinking

water to the population, which currently has to rely on imported drinking water. The

Development of a Corporate Social Responsibility Programme (CSRP) would

include both financial as well as other forms of support.

Project cumulative impacts

The Project’s impacts on the environment from construction, operation and

decommissioning of the Plant have been evaluated in the ESIA, and, provided all

mitigation and monitoring measures are appropriately implemented, the majority of

identified impacts have been estimated to be of low magnitude and minor or

negligible significance.

The magnitude and significance of the Project impact on the local fauna has been

estimated to be of moderate magnitude and significance due to the presence within

the Project area of an endangered specie of Steppe Tortoise, (discussed in chapiter

2 hereunder). The Sponsor has committed to commissioning a detailed Specie

Management Plan (SMP) and a more overarching Biodiversity Management Plan

(BMP) that show a credible path to No Net Loss (NNL) to the satisfaction of the

Lenders.



The magnitude and significance of the impact from temporary workers

accommodation during construction and decommissioning were both estimated in

the ESIA to be Moderate. Provided that there is an implementation of a Workers

Accommodation Management Plan (WAMP) developed in line with EBRD and IFC

“Workers accommodation Process and Standard Guidance Note”, the residual

impact from temporary workers accommodation is considered minor.

The 350 Ha allocated to the Project (the Project Land) have been leased from the

State and represent 0.7% of the 52,000 Ha of available pasture land in the Tutly.

Unofficial uses comprise cattle farmers using the land for grazing. Alternative land

of equal convenience and quality has been provided for the unofficial users to

compensate for the loss of the Project Land.

Fig. 1 : Site location and distances identification

Road

Tutly 1.7 km

PV Plant area



2. IMPACTS, MITIGATION MEASURES AND SOCIAL BENEFITS

The impacts associated with this project are considered to be site specific and are

relatively easily assessed and mitigated. The technology that the Sponsor intends

to use is state of the art and in line with international Best Practice. The EPC

Contractor selected (soon to be appointed formally) has proven, during previous

and recent projects for the Sponsor, to have the required capacity to implement the

Lenders Performance Requirements.

Fig. 2 : Typical low vegetation and cattle grazing in the project area

The Project land is located within one of 52 existing Important Bird and Biodiversity

Areas (IBAs) in Uzbekistan, named Karnabchul Steppe (UZ018). IBAs were

created by the BirdLife, an International non-profit organization devoted to bird

conservation. An evaluation of possible negative impacts to the Karnabchul IBA

resulting from the implementation of the Project was undertaken in May 2019, the

conclusions of which are as follows:

• None of the mainbreeding avifauna species in the area are endangered;

• The project area maybe used occasionally by dispersedor migrant

houbaras;

• The solar project area is comparatively small when considered within the

project steppe area interested by birds migration;

• The impacts to migrant birds (such as houbaras) is considered very low or

negligible.

• An important population of Steppe Tortoises (Testudo horsfieldii) is

established within the Project area. This species is considered Vulnerable

A2d by IUCN.

The estimated total number of tortoises currently within the Project area site could

reach 7,830 individuals (assuming a density of 22.37 individuals per 1 ha).



The Karnabchul steppe extends over approximately 171,000 ha, with a density of

tortoises which varies from 7.9 to 11.5 individuals/ha (D.A.Bondarenko and others,

2017). The overall population is therefore estimated to be between 1,350,900.0 and

1,966,500 individuals.

Earth works to be undertaken between November and March 2021 will impact a

total of around 5.5 % (19ha) of the Project area. During this period the hibernated

tortoises will therefore be affected leading to an estimated loss of 123 individuals.

This represents approximately 1.6% of total population of the Project area, and less

than 0.006% of tortoises population in the Karnabchul steppe.

Assuming a 100% mortality rate (the worst-case scenario) for tortoises within the

350 ha of the Project area, the impact on a landscape-level basis is calculated at

0.58-0.4% of the tortoises population in the Karnabchul steppe.

Assuming the worse scenario, the overall loss of tortoises accounting for the total

number of Uzbek tortoises (10 mln), is considered to be negligible.

A detailed Species Management Plan (SMP) from a qualified biologist for the

tortoise that show a credible path to No Net Loss (NNL) is to be developed and

implemented by the Sponsor in collaboration with the Project Owner. This needs

to cover population estimates/modelling, loss accounting for project impacts, all

avoidance, management and mitigation measures to be implemented and show a

credible plan to achieve NNL. The Sponsor has also committed to developing a

robust biodiversity management plan (BMP), with the clear objective of NNL, and

where there is that an off-set programme to be implemented. The Sponsor has

committed to commissioning the Biodiversity Management Plan (BMP) to the

Lender’s satisfaction.

The local population (cattle farmers and other unofficial users of the Project Land)

has been provided with access to pasture-land of equal quality, distance and

accessibility compared to the Project area, which means that the residual impact

on the local population in Tutly is negligible.

Local residents and services providers might benefit from the Project as demand

for employment of unskilled workers and requirement for services associated with

the Project’s implementation are expected to arise as a consequence of the Project.

The EPC contractor will be required to implement a Labour and Employment

Management Plan (LEMP) in line with EBRD PRs in order to maximise bringing

project benefits to the local community. Although many skilled workers will have to

be brought from abroad or outside the local area, there will be a transfer of

knowledge to local contractors, and local population might be encouraged to train

in areas relevant to the project (e.g. electricians and operators). A number of

villages located within approximately 17 km radius from Tutly will benefit from the

positive impacts of the Project as a result of increased employment and business

(supply of goods and services) opportunities.

A more reliable supply of power and decrease in the power deficit in the region may

stimulate growth and investment.



Water resources

Within the Tutly settlement there are no available sources of drinking water for the

population and/or livestock. Drinking water is delivered by water trucks from the

Tim settlement, 40 km from Tutly. Each household is usually provided with concrete

water tanks, and abstracts water for livestock watering from the superficial aquifer

(approximately 20 m depth), which can be saline.

The superficial geology comprises sandy loams, which are relatively permeable.

There is an uneven distribution of precipitation throughout the year.

According to the residents of the Tutly settlement, the Project Land is located on

the path of mudflows that occur mainly from March to April. Mudflows 10-50 cm

high flow through the natural lowland from the mountains on the western side of the

project area and reach the village of Tutly. There is a risk that, if inappropriate

drainage is implemented, the mudflow diverted from the Project area, could impact

the residential areas of Tutly. Therefore, particular care must be taken to design an

adequate drainage system.

A small risk of localised ground contamination might arise as a result of the

construction works as a result of machinery refuelling or maintenance, as well as

possible water treatment activities and waste-water storage. However, this can be

minimised by appropriate use of adequate secondary bunding to relevant storage

tanks.

Landscape and Visual Impact

The topography of the project land and surrounding is flat with no neighbouring

sensitive uses including no aircraft landing strips in the immediate vicinity. The

potential issues associated with glare and glint caused by sunlight reflected off the

PV panels are considered low due to the design of the panels and the intended use

of antiglare coating.

Local traffic, road safety, noise and vibration

Accidents as a result of the increased traffic might increase on the roads near the

Project Area and to and from the Tutly settlement and the city of Navoi. However,

the project land is flat and visibility, except during dust storms (during which it is not

envisaged to carry on construction activities), is good. The development and

implementation of a Construction Traffic Management Plant (CTMP) by the EPC

contractor will contribute to mitigating all risks from traffic generated during the

construction phase.

The implementation of measures specified in the CEMP to be developed by the

EPC contractor as well as implementing best practice for the use and storage of

hazardous chemicals, management of waste from construction activities as well as

waste and wastewater from the workers accommodation compounds should

mitigate the risks of contamination.



The relative permeability of the superficial geology and the presence of superficial

groundwater means that frequent spillages might have an impact in the Project

Ares, which can be minimised by the implementation of the above.

Impacts to existing infrastructure and Public Services

The Settlement of Tutly and the neighbouring settlements do not have health

centres and the residents have limited access to trained medical staff. The

implementation of the Project, particularly in light of the COVID pandemic,

would require addressing the issue of sanitary conditions and availability of

medical staff for the project Workers. The implementation of an appropriate

Corporate Social Responsibility Plan (CSRP) which includes a programme for

enhancing the health infrastructure in the Tutly settlement might result in a

positive impact and provide the residents with increased access to trained

health workers. It should be noted that the SCRP is a developer initiative not an

EBRD requirement and EBRD will not provide any input nor funding towards it

and will not manage nor monitor its output.

The poor state of the roads represents one of the major issues in the Project

area. The implementation of the Project might result in a positive impact as a

result of roads maintenance associated with the construction works (prior to and

after completion) providing newly-paved roads and improved infrastructure to the

Project Area. Villages considered likely to benefit from such positive impacts

include: Gubdin-Obdun, Zhiydalik Sahkoba and Kurgancha.

Consistency with Policy, Law and other plans

The Studies conducted on the potential of renewable energy in Uzbekistan show

that the solar energy potential offers a very large potential (2058 Terawatt TW).

Accordingly, the Presidential Decree No. PP-3012 of the 26th May 2017 on the

Measures for Further Development of Renewables and Energy Efficiency and the

Social Sphere for 2017-2021 has been adopted. The Project will contribute to the

Uzbek Government’s Goal to increase the Solar power to 2.3% by 2025.

The Project will contribute to improve local power supply and reliability and will

promote economic development in the region as a result.

Further, as the Government is actively attracting the private sector to invest in

renewable energy, the success of the Project might create a precedent that will

encourage further private investment in the sector and in the Country.



Social Management Plans, mitigation and compensatory measures

Amongst the measures that the Sponsor is considering there is drilling a phreatic

well for the population of Tutly which would provide drinking water from the deeper

aquifer (200 m depth). This would allow the population to have access to better

quality water and would be a positive impact of the project.

An Environmental and Social Management and Monitoring Plan (ESMMP) will be

developed by the Sponsor (in collaboration with Tutly Solar LLC) and provide the

framework for the EPC Contractor’s development of a clearly defined

Environmental and Social Management System (ESMS). Tutly Solar LLC will be

responsible, amongst others, for obtaining all relevant permits for construction,

development and implementation of relevant E&S plans, review and monitor the

compliance of the EPC’s ESMS and all associated Management plans.

A CSRP shall be developed and agreed with Sakhoba MRG with a view to help the

local community. This will have to fit within the allocated CSRP budget, avoid

overlap with State programmes, and be sustainable or lead to job creation. For

example, as stated above, the CSRP could support the creation of a rural health

centre accessible to the local residents, help in providing drinking water for the

population, maintain roads. The female members of the public consulted requested

the construction of a public bakery. The degree of support and the budget allocation

must be proportionate to the Project and the financial standing of the Project Owner.

Public consultations, Stakeholder Engagement Plan and Grievance Redress Mechanism

A Stakeholder Engagement Plan (SEP) has been provided by the Sponsor and

disclosed to the Lenders. The SEP provides an organisational structure to support

Tutly Solar LLC (the project owner) who will be the executing agency in delivering

all stakeholder engagement activities.

Tutly Solar LLC undertook official consultations with stakeholders in May, August

and December 2019, and in February and August 2020. Consultations with the

population of the Tutly settlement were undertaken on the 21st December 2019 (for

which 39 participants signed the registration list) and another one on the 21st of

August 2020 (to which 9 households representatives attended). Questions

regarding the impacts on pasture land availability were raised during the meetings.

A formal complaint regarding the land allocation was lodged with the authorities;

the issue was resolved by granting the local population additional area for grazing

their livestock 1 km far from the settlement, at the lands owned by Tutly Korakul

Zamini LLC (who did not object to this decision).



A Grievance Redress Mechanism (GRM) has been established for the Project

taking into account the Uzbek national legislation, the specificity of the project

sites, and the results of public consultations. In addition, the Sponsor

undertakes to ensure that the GRM is developed and implemented accordance

with related policies of IFIs such as EIB, EBRD, WB.

The formal complaint filed by the local residents has been redressed by relying on

the existing GRM, and, according to interviews with local herders, the grievances

have been resolved to the satisfaction of the interested parties. The Sponsor has

undertaken to seek obtaining a formal agreement documenting the resolution

of the issues raised in the complaint.

The ESAP requires the Sponsor and the Project owner to implement a range of

management plans to be developed and implemented for, amongst others,

Environmental, Social, Occupational Health and Safety, Construction, Safety and

Bio-diversity Management plans. The EPC Contractor is required to develop and

implements EHS / OHS management plans in line with the Sponsor’s and the

Lenders requirements and, the Sponsor is required to Monitor and report on the

EPC Contractor’s performance against the set Policies and KPIs. The Sponsor is

required to develop and implement a specific Specie Management Plan with the

objective of achieving No Net Loss of the tortoises in the Project Area. The ESAP

sets requirements for reporting to EBRD and publish information regarding the

Project’s progress, as well as the results of surveys and monitoring programmes.

In addition, the Sponsor is required to Develop a Community Development Strategy

and Corporate Social Responsibility (CSR) Programme, establish a budget for it,

and report its implementation to stakeholders and Lenders.



3. IMPACTS MONITORING

Tutly Solar LLC (and the EPC Contractor) will have to develop and implement a

Construction Environmental and Social Management Plan (CESMP) which will

provide for workers awareness and training sessions in relation to the protection of

the local fauna.

Construction will be monitored weekly through the implementation of the above

plans and mechanisms. During the Operation phase, monitoring will be undertaken

monthly. Annual reports on the environmental and social performance as well as

grievances will provide the ongoing view of the performance of the implementation

of the Project against the plans. The reports will be checked against the Lenders

requirements and monitoring will be undertaken throughout the lifespan of the

Project.

This Non-Technical Summary and the Stakeholder Engagement Plan (SEP) will be

published prior to approval of the Lenders. The SEP provides a mechanism for

engaging with all stakeholders as well as the disclosure mechanisms for all relevant

information regarding the Project.

The Community Liaison Officer (CLO, which will be appointed in due time) will

manage communications amongst all stakeholders and ensure that an appropriate

grievances mechanism provides an efficient method of redress.

The GRM has been designed and will be disclosed as soon as possible and remain

available for review at the Project site, on the information boards in the Tutly

settlement as well as on the Project Owner’s website.

Further information can be obtained from the Project Owner’s Manager Ms. Ayzada

Seitniyazova, who is currently acting as CLO, until a separate appointment to this

role is made by the Sponsor/Project Owner.

“NTS” - Total Eren · 2020. 11. 20. · “NTS” Our ref.: P.016410.2004 AA 93004 TS:...

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