Environmental and Social Compliance Audit

Environmental and Social Compliance Audit

March 2020

VIE: B.Grimm Viet Nam Solar Power Project (Phu Yen Project)

This document is being disclosed to the public in accordance with ADB's Access to Information

Policy.

ABBREVIATIONS

ADB – Asian Development Bank

NOTE

(i) In this report, "$" refers to United States dollars.

This environmental and social compliance audit 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.

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.

PYTTP i www.ibisconsulting.com

Environmental and Social Due Diligence Audit Report

Phu Yen TTP Joint Stock Company – Phu Yen Branch and Asian Development Bank

06 March 2020

PYTTP ii www.ibisconsulting.com

Environmental and Social Due Diligence Audit Report Phu Yen TTP Joint Stock Company

For and on behalf of: Phu Yen TTP Joint Stock Company – Phu Yen Branch and Asian

Development Bank

Prepared by: Coby Wong and Eric Zhaoyu Ji

Reviewed by: Oliver Warner

IBIS Ref: 0346 - 1131

Signed by:

Position: Managing Director

Date: 06 March 2020

This report has been prepared by IBIS Consulting the trading name of IBIS Environment & Social

Consulting Asia Pte. Ltd., with all reasonable skill, care and diligence within the terms of the Contract

with the client, incorporating our Standard Terms and Conditions of Business and taking account of the

resources devoted to it by agreement with the client. We disclaim any responsibility to the client and

others in respect of any matters outside the scope of the above.

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CONTENTS

CONTENTS............................................................................................................................................. 3

EXECUTIVE SUMMARY ........................................................................................................................ 1

INTRODUCTION ............................................................................................................................. 1

1.1 BACKGROUND ........................................................................................................................... 1

1.2 REPORT STRUCTURE ................................................................................................................. 1

PROJECT SETTING AND DESCRIPTION .................................................................................... 2

2.1 HOA HOI SOLAR FARM ............................................................................................................... 3

2.2 A TRANSMISSION LINE AND TRANSMISSION TOWERS ................................................................... 3

2.3 RESIDUAL LAND......................................................................................................................... 5

2.4 KEY ACTIVITIES ON-SITE DURING OPERATIONAL PHASE................................................................. 9

2.5 LAND USE OF THE PROJECT SITE AND ITS SURROUNDING AREA .................................................. 10

2.5.1 Phu Hoa District and Hoa Hoi Commune ..................................................................... 11

2.6 PROJECT TIMELINE .................................................................................................................. 13

SCOPE OF WORK ....................................................................................................................... 14

3.1 OBJECTIVES ............................................................................................................................ 14

3.2 APPLICABLE STANDARDS ......................................................................................................... 14

3.2.1 Applicable Vietnamese laws and regulations ................................................................ 14

3.2.2 International treaties ...................................................................................................... 17

3.3 SCOPE .................................................................................................................................... 18

3.4 METHODOLOGY ....................................................................................................................... 18

3.4.1 Task 1 – Project Initiation and Preparation ................................................................... 18

3.4.2 Task 2: Document Review ............................................................................................ 18

3.4.3 Task 3: Site Visit............................................................................................................ 18

3.4.4 Task 4: Reporting .......................................................................................................... 19

ENVIRONMENTAL AND SOCIAL COMPLIANCE REVIEW ....................................................... 21

4.1 ADB SPS ENVIRONMENT SAFEGUARDS ................................................................................... 21

4.2 ADB SPS INVOLUNTARY RESETTLEMENT SAFEGUARDS ............................................................ 70

4.3 ADB SPS INDIGENOUS PEOPLES SAFEGUARDS........................................................................ 71

4.4 CORPORATE SOCIAL RESPONSIBILITY ACTIVITIES ..................................................................... 74

4.5 PROJECT CATEGORIZATION ..................................................................................................... 74

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CORRECTIVE ACTION PLAN ..................................................................................................... 76

ANNEX A LIST OF DOCUMENTS PROVIDED FOR REVIEW ................................................... 80

ANNEX B LIST OF INTERVIEWEES ........................................................................................... 93

ANNEX C AERIAL IMAGERY OF THE PROJECT SITE ............................................................. 94

ANNXE D PHOTOLOG ................................................................................................................. 97

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List of Abbreviations (in an Alphabetic Order)

ADB Asian Development Bank agl aboveground level AHs Affected households bgl below ground level CAP Corrective action plan CO2 Carbon dioxide COD Commercial Operations Date DMS Detailed measurement survey DoIT Department of Industry and Trade (DoIT) DoNRE Provincial Department of Natural Resources and

Environment E&S Environmental & social EHS Environmental, health & safety EIA Environmental impact assessment EPC Engineering, procurement and construction ESCA Environmental and social compliance audit ESCAR Environmental and social compliance audit report ESMP Environmental and social management plan ESMS Environmental and social management system EVN Vietnam Electricity Power Generation Corporation H&S Health & safety Ha hectare HHC Hoa Hoi Commune HR Human Resources HP horsepower IAHH Interviewed Affected Household ILO International Labour Organization km kilometre MoIT Ministry of Industry and Trade MWac Megawatt (alternating current) MWp Megawatt (peak) OHS Occupational health and safety O&M Operation and maintenance PLDC Provincial Land Development Centre PPA Power purchase agreement PPE Personal protective equipment PV Photovoltaic PY Phu Yen PYTTP Phu Yen TTP Joint Stock Company RMU Ring Main Units RoW Right of way SEP Stakeholder engagement plan SPS Safeguard Policy Statement WBG World Bank Group

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EXECUTIVE SUMMARY

Introduction

IBIS Environmental and Social Consulting Asia Pte. Ltd. (“IBIS”) was engaged to undertake an Environmental and Social (E&S) Compliance Audit (the “Audit”) of a solar project situated in Hoa Hoi Commune (HHC), Phu Hoa District, Phu Yen Province, Vietnam (the “Project”) for Phu Yen TTP Joint Stock Company – Phu Yen Branch (henceforth, the “Client”, “PYTTP” or “the Company”) and Asian Development Bank (henceforth, the “Lender” or “ADB”). IBIS understands that ADB is considering providing financing to the Project developed by PYTTP, a joint venture between B. Grimm Energy (“B. Grimm”; 80%) and Truong Thanh Viet Nam Group (20%).

The Project is situated in Hoa Hoi Commune, Phu Hoa District, Phu Yen Province, Vietnam, approximately 90 kilometres (km) northeast of Tuy Hoa Airport (13° 3'38.49"N, 109° 5'42.36"E). It involves the development and operation of a solar photovoltaic (PV) power plant with an installed capacity of 257 megawatts peak (MWp) and contracted capacity of 214 megawatts (alternating current) (MWac). The Project has the following three major components:

1. Hoa Hoi Solar Farm, including one 220kV substation;

2. A 12.2 km long 220 kV transmission line; and

3. 38 transmission towers, three of which are located inside the physical boundary of the solar plant.

Scope of Work and Approach

The objectives of the Audit were to independently review and assess the Environmental, Social and Health & Safety status and performance of the Project, as well as identify compliance gaps, issues, improvement opportunities, and develop a detailed time-bound mitigation Corrective Action Plan (CAP) to support alignment with the Applicable Standards. The work has been due diligence in nature, as such, the focus of the Audit has been on understanding any significant issues in relation to the Project (commensurate with its nature and scale) and any issues that may present a concern to ADB in terms of notable non-compliance against the Applicable Standards or E&S reputational risk (as far as can be reasonably foreseen). Key relevant national laws and regulations in Vietnam relating to environment, health and safety, relocation of affected persons, Indigenous Peoples, labour and gender issues have been included.

A staged approach was taken for the Audit which included document review, a 5-day visit to the Project site in December 2019, and preparation of this report.

Environmental & Social (E&S) Safeguards

The Audit has been carried out against the following standards and guidelines. Collectively, they are referred to as the “Applicable Standards”.

(i) Applicable Vietnamese national and local laws and regulations and international agreements on environment, land acquisition and involuntary resettlement, indigenous peoples, human resource and labour practices, gender and other social matters fully in force at the time of authorisation of the signed Proposal;

(ii) ADB Safeguard Policy Statement (SPS), 2009;

(iii) ADB Social Protection Strategy, 2001;

(iv) ADB Gender and Development Policy, 1998;


(v) ADB Access to Information Policy, 2019;

(vi) World Bank Group (WBG) General Environmental, Health & Safety (EHS) Guidelines,2007;

(vii) WBG EHS Guidelines for Electric Power Transmission and Distribution, 2007; and

(viii) International Covenant on Economic, Cultural and Social Rights and relevantInternational Labour Organization (ILO) Core Labour Standards Conventions.

Project Categorisation

As part of the Audit, there is a need to provide an opinion on the categorisation of the proposed transaction, based on the ADB SPS. Based on the work to-date, it is considered that the proposed transaction is classified as follows:

Site Environment (1) Involuntary Resettlement (2) Indigenous Peoples (3)

Phu Yen Solar Project Category B Category B Category B

Note:

(1) Category B. Based on the information provided (including from the locally completed EIAs) theimpact level is considered to be generally site-specific, few, if any of them are irreversible ifproperly managed. Thus, the proposed environmental categorisation of the Project is B.

(2) Category B. The proposed project categorization of the Project is B, due economic displacementnearly 166 households within and beyond the Project area. The resumption and transfer of landwas done in accordance with statutory requirement. The affected households were compensatedincluding enhanced benefits beyond statutory requirements and were largely aligned to ADB SPSrequirements. Additional measures will be implemented to ensure that the livelihood of theaffected households, especially the poor and vulnerable, will be enhanced or at least restored topre-project level. No physical displacement occurred as a result of the land use right acquisitionprocess.

(3) Category B. The proposed project categorization of the Project is B, due to the limited impactson indigenous people, because of the relocation of 16 graves belonging to Cham ethnic group.


Key E&S Areas of Improvement and Timeline

Below is the Corrective Action Plan (CAP) for the Project, based on the work carried out to-date.

Ref Corrective Action Deliverable Responsibility Timeline Indicative

Budget/Resources

1. The Project should develop a Project-specificoperational Environmental and Social ManagementPlan (O-ESMP), which should include:

• OHS Management procedures includingOccupational Hazard Identification Register;

• Waste Management procedures, including wasteminimisation programmes;

• Hazardous Materials Management procedures;• Contractor Management Plan - the Contractor

Management Plan should ensure that all E&Srequirements of the Project are implemented bycontractors of the Project and their subcontractors.E&S requirements of the Project should be imposedas part of the contractual obligations for contractorsand subcontractors. In addition, a monitoringmechanism should also be established to monitorthis;

• Traffic and Security measures;• Emergency Preparedness and Response Plan

(including an emergency evacuation plan,community H&S preparedness and responsemechanism, as well as response procedures for allemergency and risk scenarios identified during therisk assessment and hazard identification process,

O-ESMP,includingprocedures andsub-plans

PYTTP By Q4 2020 (The Project should

prioritise the development of the

Emergency Preparedness and Response Plan by

completing this document by Q2

2020)

<USD 50k if not undertaken by PYTTP.



Budget/Resources

e.g. fire, animal bites, electrocution, flooding,extreme weather and etc.);

• E&S Training and Capacity Management Plan;• Internal and External Grievance Redress

Mechanism.• Each management procedure/plans describe above

will include monitoring parameters and performanceindicators;

• Definition of responsibilities, which includeorganisational structures, roles, communications andreporting process required for the implementation ofthe ESMP.

2. Regulatory Compliance: The Project should conductenvironmental monitoring required by the approved EIAto fulfil the relevant environmental monitoring requiredto be submitted to local regulatory agency.

Environmental Monitoring Report

PYTTP By Q1 2020 for the first environmental monitoring round.

<USD 5k to conduct environmental monitoring programmes required by the approved EIA for each quarter.

3. Regulatory Compliance: The Project should ensure apermit to abstract is obtained for the groundwater wellinstalled on-site.

Groundwater abstraction permit

PYTTP By Q2 2020 Administrative time only and limited costs for the permit (assuming all in order)

4. Ensure appropriate housekeeping activities areconducted to clean construction wastes throughout theProject site, as well as off-site storage areas used bythe Project during the construction stage of the Project.

Evidence of construction waste cleaning from the Project Site.

PYTTP Prior to disbursement

Administrative time only

5. Resolve the unsafe conditions at the site for theremaining construction activities (e.g. working at heightand hot-work without proper equipment and safe-workprocedures) through implementation of safety protocolsand conduct independent daily safety checks.

Safety report for the remaining construction activities


Administrative time and minor costs

6. The Project should develop an external grievancemechanism for management of external grievances

GRM PYTTP By Q2 2020 Administrative time only



Budget/Resources

7. Designation of Environment, Health, Safety, andSecurity (EHSS) Officer to manage remainingconstruction and operations stage E&S issues throughimplementation of robust on-site environment andsocial management plan (ESMP). Better manage EHSSaspects on day-to-day operations and ensure thatnecessary improvement on the overall EHSSperformance of the Project is achieved.

Appointment of EHSS officer

PYTTP Immediate Dependent on skills and experience

8. The Project should update the HR policy in accordancewith the Collective Bargaining Agreement and theLabour Code of Vietnam, as well as ensure that thefollowing components are covered:• Detailed labour and working conditions, especially

requirements regarding overtime payment;• Non-discrimination;• Equal opportunity;• Equal remuneration for equal work; and• No child and forced labour.

In addition, the Project should implement a contractor management plan which includes a mechanism to ensure that contractor workers are paid fairly (including any overtime) and on-time, have the right to join a union freely and that the company HR policy is adhered to.

Updated HR Policy

PYTTP By Q4 2020 Administrative time only

9. The Project should develop a Livelihood RestorationPlan (LRP) to provide employment and incomegeneration opportunities to willing and qualified affectedhouseholds, especially those considered poor andvulnerable

Preparation and Implementation of LRP

PYTTP Immediate TBD

10. The Project should accomplish all the commitment tothe Cham ethnic group in relation to the transfer ofgraves and continuous engagement with them in aculturally appropriate manner as well as the provision of

Accomplished commitment and inclusion of Cham people in the LRP

PYTTP Immediate TBD



Budget/Resources

economically gainful opportunities to willing and qualified households of the Cham ethnic group.

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INTRODUCTION

1.1 BACKGROUND

IBIS Environmental and Social Consulting Asia Pte. Ltd. (“IBIS”) was engaged to undertake an Environmental and Social (E&S) Compliance Audit (the “Audit”) of a solar project situated in Hoa Hoi Commune (HHC), Phu Hoa District, Phu Yen Province, Vietnam (the “Project”) for Phu Yen TTP Joint Stock Company (henceforth, the “Client”, “PYTTP” or “the Company”) and Asian Development Bank (henceforth, the “Lender” or “ADB”). IBIS understands that ADB is considering providing financing to the Project developed by PYTTP, a joint venture between B. Grimm Energy (“B. Grimm”; 80%) and Truong Thanh Viet Nam Group (20%).

1.2 REPORT STRUCTURE

This report documents the implementation and findings of the Audit and is structured in the following manner:

• Chapter 1 Introduction provides a brief introduction to the Project and this Audit report structure;

• Chapter 2 Project Setting and Description provides background information of the Project, including its location, current status, and key activities at the Project site;

• Chapter 3 Scope of Work describes the objectives, scope of work, methodology, and key tasks undertaken by IBIS as well as applicable and relevant requirements for the Project, i.e., the Applicable Standards;

• Chapter 4 Environmental and Social Compliance Review details the observations and findings made during the Audit and proposed corrective actions;

• Chapter 5 Corrective Action Plan summarizes all corrective actions from the Audit in a tabular manner; and

• Four Annexes provide supplementary information collected during the Audit, including a list of documents reviewed by IBIS (Annex A), a list of interviewees (Annex B), aerial imagery of the Project site (Annex C), and photographs taken at the Project site during IBIS’ visit in December 2019 (Annex D).


PROJECT SETTING AND DESCRIPTION

The Project is situated in Hoa Hoi Commune, Phu Hoa District, Phu Yen Province, Vietnam, approximately 90 kilometres (km) northeast of Tuy Hoa Airport (13° 3'38.49"N, 109° 5'42.36"E). It involves the development and operation of a solar photovoltaic (PV) power plant with an installed capacity of 257 megawatts peak (MWp) and contracted capacity of 214 megawatts (alternating current) (MWac). Figure 2-1 below depicts the solar farm component of the Project, which is also referred to as Hoa Hoi Solar Farm.

The Project officially started construction on 15th November 2018, and the construction was completed by the end of May 2019 with a Commercial Operations Date (COD) of the 10th June 2019 as required under the Power Purchase Agreement (PPA). The Project was inaugurated on 25th June 2019 and has an operational lifespan of 20 years. Aerial imagery illustrating the history of the solar farm is provided in Annex C.

FIGURE 2-1 AERIAL IMAGERY OF PROJECT SITE, DATED 30TH APRIL 2019

The Engineering, Procurement and Construction (EPC) of the Project was carried out by China Energy Engineering Group Shanxi Electric Power Engineering Co., Ltd. (“CEEC”), with PV modules supplied by JA Solar Holding Co., Ltd. and Trina Solar Limited, inverters supplied by Sineng Electric Co., Ltd. and RMUs supplied by Siemens AG. The Project officially started construction on 15th November 2018 and was completed by the end of May 2019. The Project reached Commercial Operations Date (COD) on 10th June 2019, as required under the PPA.

The Project has the following three major components:

4. Hoa Hoi Solar Farm, including one 220kV substation;

5. A 12.2 km long 220 kV transmission line; and

6. 38 transmission towers, three of which are located inside the physical boundary of the solar plant.


Aerial imagery showing the development of the solar farm is provided in Annex C. Details of the solar farm itself, the transmission line and the residual land acquired by the Project is provided below.

2.1 HOA HOI SOLAR FARM

Hoa Hoi Solar Farm has 214 MWac contracted capacity and has a 20-year PPA. The total land area legally permitted in the Investment Decision of the Project is limited to 256 ha, and the Project has obtained a 50-year legal land use right in the form of a land use right certificate or locally referred to as the “red book”, for the 256 ha land. The Project’s (or PYTTP’s) land use right at Hoa Hoi Solar Farm expires on 11th May 2068.

In the operational phase of the Project, the Hoa Hoi Solar Farm is accessible via two main entrances located along the southern and eastern boundary. The solar farm retained the existing streams and water ponds within the Project site, which have been designed to be connected to the project stormwater drains. Based on IBIS’ observations on-site, some parts of the solar farm land area (within the boundary of the solar farm) will remain unoccupied or unused during the operational phase of the Project, and this includes areas, such as small streams and their immediate surrounding area and part of a more undulating area that are unsuitable for use. The total percentage of the unoccupied area within the 256 ha solar farm was not provided to IBIS. However, based on a rough estimation by IBIS, this is considered to be less than 5%.

Within the boundary of the solar farm, components and supporting infrastructure consists of solar panels, underground and overhead connecting cables, internal roadways and other auxiliary items, including:

• 676,312 PV Modules, each of 380W;

• 43 stations with inverters and Ring Main Units (RMUs) (5MW capacity per station,

connected to the PV modules and substations by underground cable);

• A 220kV substation with two transformers (152mVA, 22kV/220kV);

• An administration compound, which houses a two-storey administration building, a single-storey pump room and warehouse (for the solar plant’s operation, “Solar”), a single-storey canteen and two firefighting water storage tanks (one 400 cubic metres (m3) and one 8 m3);

• Two guard houses (for the solar farm); and

• Three transmission tower (please note that there are other transmission towers situated outside the boundary of the solar farm).

2.2 A TRANSMISSION LINE AND TRANSMISSION TOWERS

A 220kV TL consisting of 38 transmission towers connects the Project’s substation to the national power grid’s existing substation (Tuy Hoa Substation) in Quang Bac Commune (QBC), approximately 12 km northeast of Hoa Hoi Solar Farm. The TL is in operation and under the management of EVN, a state-owned company, although it is understood to have been developed by the Project. This TL runs in parallel with an existing 220 kV (in a new right of way; RoW) TL built for a hydro power plant (Song Ba Ha Hydropower; “Song Ba Ha Hydro”) approximately 10 years ago.

Three of the 38 transmission towers are located within the boundary of Hoa Hoi Solar Farm, whilst the remaining 35 transmission towers are located north and northeast of Hoa Hoi Solar


Farm. It was verbally reported that the spacing between every two towers averages at around 250 m, with 300 m being the widest spacing. The height of the transmission towers ranges from 38 to 64 m. The height of the TL itself ranges from the lowest point at 7 m above ground level (m agl) to the highest point at 60 m agl. The width of the transmission line corridor is 22 m, equivalent to 11 m on each side for the Project’s TL. The foundations of the transmission towers reportedly range from 180 to 400 m2 in footprint, averaging at 250 m2 each. According to verbal information provided by a representative from Provincial EVN, approximately 7,000m2 (0.7 ha) of land was acquired for the construction of the 33 transmission towers on private land , however, documents to confirm this are not available from the Project at the time of this document preparation. From the solar farm to the EVN’s substation in QBC, the TL traverses HHC, Quang Nam Commune (QNC) and then QBC. The exact number of transmission towers in each of the three communes is not known. It was reported that about 17 transmission towers were located in HHC.

PYTTP engaged a third party contractor, ACIT, to lead the land use right acquisition process and acquired the land use right for the construction of the 33 transmission towers and the land use restriction (i.e., imposing land use restriction under the 22m wide TL corridor) along the 12.17 km long transmission line (this excludes the segments within the solar farm and Tuy Hoa Substation).

According to verbal information provided by a representative from ACIT over a teleconference call and other sources, the land use right acquisition and compensation process took approximately three months to complete from May to August 2019. The construction of the TL itself took seven months from November 2018 to June 2019.

Below table (Table 2-1) presents a summary of information provided verbally by ACIT on 17th December 2019 via a teleconference call held at Cendeluxe Hotel.

TABLE 2-1 BASIC INFORMATION OF THE 12.17 KM LONG TRANSMISSION LINE

Item Description Remarks

Length of TL 12.17 km This length is only for the 220kV transmission line from the Project’s substation to 220kV Tuy Hoa substation.

Number of Transmission Towers

38 Three transmission towers are located within Hoa Hoi Solar Farm, and the remaining 35 towers are in HHC, QNC and QBC. Two of the 35 towers are located in commune land (however, no information was available on which commune). Most of the land acquired was in HHC.

Height of transmission line Lowest: 7m agl Highest: 60m agl

The minimum height requirement for a 220kV TL in Vietnam is 6 m agl according to Provincial EVN.

Corridor width of the TL 22 m 11 m on each side

Footprint of transmission towers

Average: ~250 m2 Smallest: ~180 m2 Largest: ~400 m2

A payment of ~2B VND was signed off for ~7,000 m2 for the land use right acquisition of the 33 transmission towers.


FIGURE 2-2 THE TRANSMISSION LINE FROM HOA HOI SOLAR FARM TO BA HA TL (C3) AND PROJECT TL (C4)

2.3 RESIDUAL LAND

As noted above, a collection of land parcels beyond the boundary of Hoa Hoi Solar Farm was acquired as part of the land acquisition process for the Project. Based on the available documented information, the following areas were identified as part of the Residual Land:

• As mentioned above, the 752.3 m2 (0.07523 ha) land pockets which have been accounted for in the Land Acquisition Compensation Summary as the land outside the 256 ha solar farm boundary. This land area has officially been entrusted to HHC for management.

• 1.20349 ha acquired for the construction of the Access Road along the northern and northwestern boundary of the solar farm from 33 land plots, including two Commune land plots; and

• 3.6341 ha of land acquired from 5 AHs who demanded the Project to buy the land plots in their entirety due to restricted access along location demarcations “M13” and “M14” of the boundary of the solar farm (circled in green in Figure 2-3); and

•

This land were directly purchased from the land use right owners on a willing seller-buyer basis, primarily to mitigate impacts of orphan/unviable land parcels due to purchase of other land use rights for the solar farm land. The acquisition process was completed in general accordance with the expectations of the affected land users of the solar farm. A mutual agreement was reached between the Project, HHC and District LFDC that PYTTP would maintain an informal land use right of the Residual Land area outside the 256 ha Hoa Hoi Solar Farm physical boundary and, if the Residual Land would remain unused, the land use rights of the Residual Land or parts of it would be expected to be transferred to HHC as Commune land for other uses. Based on verbal information collected during various interviews by IBIS, IBIS understands that parts of the Residual Land had already been transferred to HHC and converted for the following use:


a) Access Road – An unpaved Access Road around Hoa Hoi Solar Farm has been transferred to HHC, who is now responsible for its operation and maintenance. The length of this access road was documented to be 7.324 km in length and 4 m in width in a meeting minute, dated 27th February 2019. The Access Road is now considered a public facility for community use.

Incorporating sections of existing public roads, the Access Road was considered as a replacement road for the local community. Historically, there were several paths/tracks within the boundary of Hoa Hoi Solar Farm which were used by the local community to access their fields in the area. These access routes were no longer accessible as a result of the Project development. As a replacement, the Access Road was constructed first for use during the construction phase of the Project for transportation of materials during construction. Upon completion of the construction phase, the Access Road was then transferred to HHC as a public facility for community use.

b) New Cham Cemetery – A total of 18 graves were declared to be historically located in the solar farm land area. These 18 graves were relocated to an open area located immediately east of the solar farm and approximately 30 m west of an existing direct public access road (part of the Access Road). The newly allocated Cham cemetery is roughly at the location pointed by the red arrow in Figure 2-4. The newly allocated Cham cemetery reportedly has a total land area of 5,000 m2 and is considered as Commune land earmarked as a cemetery for Cham people only.

c) Remainder of Residual Land – Parts of Residual Land along the eastern boundary of Hoa Hoi Solar Farm appeared to have been used during the construction phase as EPC laydown areas. According to Site Representatives, after construction was completed, these land areas would be unused. These areas would either be surrendered to HHC or be utilized as part of the Project’s CSR/Livelihood Restoration program in the future.


FIGURE 2-3 A SIGHTED DOCUMENT IN DISTRICT LDFC OFFICE SHOWING POCKETS OF LAND USED BY THE

PROJECT


FIGURE 2-4 A LAND USE RIGHT ACQUISITION MAP SIGHTED IN DISTRICT LDFC OFFICE (RED ARROW POINTING TO

A NEWLY ALLOCATED CHAM CEMETERY)


FIGURE 2-5 LAND USE RIGHT ACQUISITION MAP SIGHTED IN DISTRICT LDFC OFFICE (RED ARROWS POINTING TO

EXAMPLES OF LAND USE RIGHT AREAS ACQUIRED BY THE PROJECT OUTSIDE THE SOLAR FARM BOUNDARY)

2.4 KEY ACTIVITIES ON-SITE DURING OPERATIONAL PHASE

The Project’s operational permit was issued by the Electricity Regulatory Authority of the Ministry of Industry and Trade and is valid for 10 years. According to information provided by Site representatives, a total of 14 people are directly employed by the Project for its operation, including 10 technical staff and two administrative staff.

During the operational phase, key activities expected on-site include solar panel cleaning, maintenance and repair of equipment and facilities. Solar panel cleaning will be performed using four cleaning robots and specialised vehicles equipped with water tanks. The use of cleaning robots will reduce manpower required for the operation of the solar farm.

Operation and maintenance (O&M) of the Project has been contracted to CEEC for the first two years of operations. CEEC has subcontracted O&M of the Project to Power Engineering


Consulting Joint Stock Company 2 (PECC2). Currently PECC2 has engaged a total of 15 direct employees to carry out the following responsibilities:

1. Operation and maintenance of the solar farm; and

2. Operation and maintenance of the substation.

Security services are currently subcontracted by PEEC2 to a local Vietnamese entity, Huy Hung Security. Currently a total of 40 people has been engaged by the security company for the provision of security services.

Municipal water supplies to the Project for domestic use, firefighting and solar panel cleaning. Groundwater is used as emergency water supply for firefighting and solar panel cleaning with only one groundwater abstraction well presented on-site. The depth of the groundwater abstraction wells is approximately 60 m below ground level (bgl). The groundwater is abstracted through a water pump and treated through a filtration system installed in the pump room and warehouse located within the administrative compound. Reportedly, in the case that groundwater would be required to provide emergency water supply to the Project, groundwater would be abstracted from the groundwater abstraction well and stored in two firefighting water tanks within the administrative compound. No routine groundwater abstraction was reported by the Project during the site visit.

Drainage ditches have been constructed along the perimeter fence and service roads, as well as at certain location within the solar farm to provide connections with streams flown across the site.

2.5 LAND USE OF THE PROJECT SITE AND ITS SURROUNDING AREA

The Project consists of the following three components and they are located in:

• Hoa Hoi Solar Farm in HHC;

• The 12.892 km long TL in HHC, QBC, and QNC;

• Approximately 4.9 ha of Residual Land in HHC.

For the 256ha solar farm, PYTTP entered into a 50-year land lease agreement with Phu Yen Province People’s Committee to utilise the land for the development of the Project. Prior to the establishment of the Project, the 256 ha of land and its surrounding were mainly used for agricultural purposes by private land use right owners and two private companies mainly for cultivation of crops, such as sugarcane (182.4 ha), cassava, water melons (11.8 ha) and acacia trees (52.4 ha), in addition to some commune (public) land as shown in Table 2-2. No residential homes were located within the solar farm area. Historical imagery of the Project area are presented in Annex C, which show patterns of agricultural land uses in the solar farm area and its surrounding.

Based on information provided by Governmental Authority Representatives, the solar farm land area was selected for the development of the Project due to poor soil quality, low agricultural productivity and the low economic output in the area. The Government Authority Representatives verbally indicated that since no residential homes were located within the solar farm area, the view of the authority was that the Project would boost economic output and employment opportunities in the area while minimizing impacts on livelihood.

With regards to the Project’s TL, very limited documented information was available at the time of IBIS’ site visit in December 2019. However, based on verbal information provided by Project Representatives, land area affected by land use right acquisition and affected by the TL corridor was historically used for agricultural purposes. The Project’s TL was placed in parallel with the existing Song Ba Ha Hydro TL to minimize impacts. Based on IBIS’ observations on-site, the


Project’s TL cut across various types of landscape, including flat plain, hilly slopes, and paddy fields. Based on the EIA, crops identified along the Project’s TL are presented in Table 2-2 below.

TABLE 2-2 SEGMENTS OF THE PROJECT’S TRANSMISSION LINE AND THEIR LAND USES

Segment No.

From To Types of Crops Identified along the TL

1. Substation within the Solar Farm

DD Sugarcane plantation

2. Substation within the Solar Farm

DD1 Sugarcane plantation

3. DD G1 Sugarcane plantation

4. DD1 G1 Sugarcane plantation

5. G1 G2 Sugarcane plantation



8. G4 G5 Sugarcane fields, pineapple garden, hilly eucalyptus tree plantation, and mixed timber.

9. G5 G6 Rice fields, hilly acacia and eucalyptus plantation

10. G6 G7 Rice fields

11. G7 DC Meadow

12. DC Tuy Hoa Substation

Meadow

Total length (m) The 12.17 km TL does not include Segment No. 1, 2 and 12.

Source: Environmental impact assessment of the Project

2.5.1 PHU HOA DISTRICT AND HOA HOI COMMUNE

As mentioned above, the Project is situated in Phu Hoa District, which consists of eight communes and one town. Basic socioeconomic information of Phu Hoa District is presented in Table 2-3.

TABLE 2-3 BASIC INFORMATION OF PHU HOA DISTRICT

Aspect Phu Hoa District *

Remarks

Total land area in the district (ha)

26,390.96

• Natural land (ha) 1,374.97

• Forestry land (ha) 10976.40

• Agricultural land (ha)

8654.30 Mainly paddy rice

Total population of the district

105,420 Cham, Hoa and Tay account for 12.1% of the provincial population. Cham H’roi and Tay tend to live in mountainous


areas of Hoa Hoi commune. According to District LDFC, Phu Hoa District has a population of 110,000 and 371 Cham people.

Population density in the district (people per km2)

400

Annual average yearly income (VND)

6.6 million per capita

* http://phuhoa.phuyen.gov.vn/wps/portal/Home/page2/thong-tin-chung/vi-tri-dia-ly http://phuhoa.phuyen.gov.vn/wps/portal/Home/page2/thong-tin-chung/gioi-thieu

Hoa Hoi Solar Farm is situated in HHC, one of the eight communes. According to the Environmental Impact Assessment (EIA) prepared for the Project, HHC has a total population of 4,175 people from three hamlets (Nhat Son, Phong Hau and Ho Ham) and an approximate total land area of 5,427.32 ha, of which:

• Farmland - 2101.02 ha

o 2032.22 ha under households and individuals;

o 13.73 ha managed by HHC People’s Committee; and

o 55.06 ha for use by economic organizations;

• Forested land - 2777.85 ha

o 2098.93 ha under households and individuals;

o 610.13 ha managed by HHC People’s Committee; and o 68.79 ha for use by economic organizations;

• Non-agricultural land – 357.10 ha

o 40.18 ha in rural residential land;

o 84.08 ha classified as specialized area;

o 4.38 ha as cemetery; and

o 228.45 ha as river and stream land and special water surface; and

• Unused land – 191.35 ha.

TABLE 2-4 BASIC DEMOGRAPHIC DATA AT THE COMMUNE LEVEL

HHC QBC QNC

Total population 4175 13,000 13,000

Number of households ~1,043* 3,500 3,500

* Estimated based on an average of 4 members in one household.

http://phuhoa.phuyen.gov.vn/wps/portal/Home/page2/thong-tin-chung/vi-tri-dia-ly

http://phuhoa.phuyen.gov.vn/wps/portal/Home/page2/thong-tin-chung/gioi-thieu

PYJSC 13 www.ibisconsulting.com

2.6 PROJECT TIMELINE

Below figure depicts key milestones of the Project from design phase to the current operational phase:

FIGURE 2-6 PROJECT TIMELINE


SCOPE OF WORK

The purpose of the Audit is to identify and describe key E&S risks and impacts associated with the current operations and any past legacy issues which may result in potential reputational or non-compliance risks with respect to the Applicable Standards, described further below.

3.1 OBJECTIVES

The objectives of the Audit were to independently review and assess the Environmental, Social and Health & Safety status and performance of the Project, as well as identify compliance gaps, issues, improvement opportunities, and develop a detailed time-bound mitigation Corrective Action Plan (CAP) to support alignment with the Applicable Standards.

The output of the Audit includes:

1. This Environmental and Social Due Diligence Audit Report; 2. Corresponding corrective action measures, in the form of a CAP to address any key

risks/issues identified during the Audit; and 3. Documentation of the land use rights acquisition process for the Project, which is

provided in a separate document.

3.2 APPLICABLE STANDARDS

The Audit has been carried out against the following standards and guidelines. Collectively, they are referred to as the “Applicable Standards”.

• Applicable Vietnamese national and local laws and regulations and international agreements on environment, land acquisition and involuntary resettlement, indigenous peoples, human resource and labour practices, gender and other social matters fully in force at the time of authorization of the Proposal;

• ADB Safeguard Policy Statement (SPS), 2009;

• ADB Social Protection Strategy, 2001;

• ADB Gender and Development Policy, 1998;

• ADB Access to Information Policy, 2019;

• World Bank Group (WBG) General Environmental, Health & safety (EHS) Guidelines, 2007;

• WBG EHS Guidelines for Electric Power Transmission and Distribution, 2007; and

• International Covenant on Economic, Cultural and Social Rights and relevant International Labour Organization (ILO) Core Labour Standards Conventions.

3.2.1 APPLICABLE VIETNAMESE LAWS AND REGULATIONS

Based on the nature of the Project and anticipated activities on-site, the following Vietnamese laws, regulations, standards and technical regulations are considered relevant and applicable to the Project:


3.2.1.1 ENVIRONMENT

• Law on Environmental Protection (55/2014/QH13); • Law on Water Resources (17/2012/QH13); • Law on Chemicals (06/2007/QH12); • Law on Irrigation (08/2017/QH14); • Decree 18/2015/ND-CP – Prescribing environmental protection master plan, strategic

environmental assessment, environmental impact assessment and environmental protection plan;

• Circular 27/2015/TT-BTNMT on strategic environmental assessment, environmental impact assessment, and environmental protection plans;

• Decree 40/2019/ND-CP guiding the implementation of some articles of the Law on Environmental Protection;

• Decree 19/2015/ND-CP guiding the implementation of some articles of the Law on Environmental Protection. This decree provides some general provisions for soil contamination management;

• Decree 155/2016/ND-CP on penalties for violations in environmental protection; • Decree 38/2015/ND-CP on waste management; • Circular 36/2015/TT-BTNMT on hazardous waste management; • Decree 201/2013/ND-CP guiding the implementation of the Law on Water

Resources, including the issuance of groundwater extraction, surface water extraction and wastewater discharge permits;

• Decree 33/2017/ND-CP on penalties for violations in water resources and mineral resources management;

• Decree 67/2018/NĐ-CP on guiding the implementation of some articles of the Law on Irrigation;

• QCVN1 05:2013/BTNMT National Technical Regulation on Ambient Air Quality; • QCVN 01:2009/BYT National Technical Regulation on Drinking Water Quality; • QCVN 14:2008/BTNMT National Technical Regulation on Domestic Wastewater

Discharge; • QCVN 03-MT:2015/BTNMT Vietnamese National Technical Regulation on The

Allowable Limits of Heavy Metals in The Soil (mg/kg dry soil); • QCVN 08-MT:2015/BTNMT National Technical Regulation on Surface Water Quality; • QCVN 09-MT:2015/BTNMT National Technical Regulation on Groundwater Quality; • QCVN 07:2009/BTNMT National Technical Regulation on Hazardous Waste

Thresholds; • QCVN 26:2010/BTNMT Vietnamese National Technical Regulation on Noise; and • TCVN 6707:2009 Hazardous wastes – Warning signs.

3.2.1.2 HEALTH AND SAFETY

• Law on Occupational Health and Safety (84/2015/QH13); • Law on Fire Prevention and Fire Fighting (27/2001/QH10); • Law on Chemicals (06/2007/QH12);

1 TCVN - Tieu Chuan Viet Nam (Vietnamese Standards) and QCVN - Quy Chuan Viet Nam (National Technical Regulation)


• Labour Code (10/2012/QH13); • Amendment Law on Fire Prevention and Fire Fighting (40/2013/QH13); • Decree 39/2016/NĐ-CP guiding the implementation of the Law on Occupational

Health and Safety; • Decree 44/2016/ND-CP on safety certification, health and safety training and

industrial hygiene monitoring; • Circular 19/2016/TT-BYT on industrial hygiene and workers health management; • Decree 79/2014/ND-CP guiding the implementation of the Law the Amendment Law

on Fire Prevention and Fire Fighting; • Decree 66/2014/TT-BCA on fire prevention and fire fighting; • Technical Regulation QCVN 06:2010 on fire prevention for houses and buildings; • Technical Regulation QCVN 34:2018/BLDTBXH on confined space safety; • Technical Regulation QCVN 01:2008/BCT on electrical safety; • Vietnamese Standards (TCVNs) on fire prevention and fire fighting

facilities/equipment; • Decision 3733/2002/QĐ-BYT on 33 industrial hygiene (workplace environment)

standards, principles and parameters; • Circular 04/2014/TT-BLĐTBXH on personal protective equipment (PPE); • Decree 113/2017/ND-CP guiding the implementation of the Law on Chemicals; • Circular 32/2017/TT-BCT guiding the implementation of the Law on Chemicals and

Decree 113/2017/ND-CP; • QCVN 24:2016/BYT Vietnamese National Technical Regulation on Noise-

Permissible Exposure Levels of Noise in the Workplaces; • QCVN 27:2010/BTNMT Vietnamese National Technical Regulation on Vibration; • QCVN 27:2016/BYT National Technical Regulation on Vibration – Permissible Levels

of Vibration in the Workplace; • QCVN 22:2016/BYT National Technical Regulation on Lighting – Permissible Levels

of Lighting in the Workplace; • QCVN 26:2016/BYT National Technical Regulation on Microclimate – Permissible

Value of Microclimate in the Workplace; and • QCVN 25:2016/BYT National Technical Regulation on Industrial Frequency

Electromagnetic Fields – Permissible Exposure Level of Industrial Frequency Electromagnetic Fields in the Workplace.

3.2.1.3 BIODIVERSITY

Biodiversity conservation in Vietnam is primarily regulated by the following laws:

• Forestry Law (16/2017/QH14); • Law on Biodiversity (20/2008/QH12); • Land Law (45/2013/QH13); and • Law on Water Resources (17/2012/QH13).

3.2.1.4 SOCIAL

The compensation, support and resettlement process and policies in Vietnam are currently regulated by the Land Law 2013 and its relevant by-law regulations, and these include:

• Land Law No.45/2013/QH13, dated 29/11/2013; • Decree No.43/2014/ND-CP dated 15/5/2014 of the Government guiding in detail

some articles of Land Law 2013;


• Decree No.47/2014/ND-CP dated 15/5/2014 of the Government on compensation, support, and resettlement upon land recovery by the State;

• Decree No.44/2014/ND-CP dated 15/5/2014 of the Government on Land Price; • Decree No. 45/2014/ND-CP dated 15/5/2014 of the Government on land use fee

collection; • Decree No. 84/2013/ND-CP dated 25/7/2013 of the Government on development

and management of resettlement houses; • Circular No.07/2014/TT-BXD dated May 20, 2014 of the Ministry of Construction

guiding a number of contents of the Government’s Decree No.84/2013/ND-CP of July 25, 2013, providing the development and management of resettlement houses;

• Circular No. 36/2014/TT-BTNMT dated 30/06/2014 of the Ministry of Natural Resources and Environment on land pricing method; compilation of and adjustment to land price lists; determination of specific land prices and consultancy on land pricing;

• Circular No. 37/2014/TT-BTNMT dated 30/6/2014 detailing compensation, support and resettlement upon land recovery by the State;

• Circular No.02/2015/TT-BTNMT dated 27/01/2015 on detailed regulation some contents of Decree No 43/2014/ND- CP and Decree No 44/2014/ND –CP dated on 15/05/2014 of the Government; and

• Local Decisions on Land Acquisition and compensation/support and resettlement of Phu Yen Provincial People ‘s Committee.

3.2.1.5 GRIEVANCE MECHANISM

• The Law on Complaints (02/2011/QH13), Law on Denunciations (25/2018/QH14) and Law on Administrative Procedures (93/2015/QH13).

3.2.1.6 RELEVANT GOVERNMENTAL AUTHORITIES

Key relevant governmental authorities include:

• Ministry of Natural Resources and Environment (MoNRE); • Vietnam Environment Administration (VEA); • Department of Water Resources Management (DWRM); • Provincial Department of Natural Resources and Environment (DoNRE); • Ministry of Agriculture and Rural Development (MARD); • Provincial Department of Agriculture and Rural Development (DARD); and • Ministry of Industry and Trade (MoIT).

3.2.2 INTERNATIONAL TREATIES

International treaties that have been ratified by Vietnam at the time of the Proposal authorisation are briefly listed below:

• Convention Concerning the Protection of the World Cultural and Natural Heritage, 1972;

• Vienna Convention for the Protection of the Ozone Layer, 1985: • Montreal Protocol on Substances that Deplete the Ozone Layer, 1987; • Stockholm Convention on Persistent Organic Pollutants, 2001; • The United Nations Framework Convention on Climate Change, 1992; • Convention on Biological Diversity, 1992; and • International Labour Organization (ILO):


o C029 – Forced Labour Convention, 1930 (No. 29); o C100 – Equal Remuneration Convention, 1951 (No. 100); o C111 – Discrimination (Employment and Occupation) Convention, 1958 (No.

111); o C138 – Minimum Age Convention, 1973 (No. 138) (Minimum age specified: 15

years); o C182 – Worst Forms of Child Labour Convention, 1999 (No. 182); and o C098 – Right to Organise and Collective Bargaining Convention, 1949 (No. 98) –

The Convention was ratified on 5 July 2019 and will only enter into force for Vietnam on the 5th July 2020.

3.3 SCOPE

The focus of the Audit has been on understanding any significant issues in relation to the Project (commensurate with its nature and scale) and any issues that may present a concern to ADB in terms of notable non-compliance against the Applicable Standards or a potential significant E&S-related reputational risk (as far as can be reasonably foreseen). Key relevant national laws and regulations in Vietnam relating to environment, health & safety (H&S), relocation of affected persons, Indigenous Peoples (where applicable), labour and gender issues have been considered.

The Audit was performed using the following steps that have been grouped into the key Tasks set out below and detailed in the following section.

3.4 METHODOLOGY

A staged approach was undertaken for the Audit which is further detailed below:

3.4.1 TASK 1 – PROJECT INITIATION AND PREPARATION

A kick-off call was held with the Client, ADB and IBIS on the 3rd December 2019 via teleconference. An Information Request List was provided to the Client for E&S information collection. The Client also supported the planning and arrangement of the visit to the Project and provided an initial set of documents for review.

3.4.2 TASK 2: DOCUMENT REVIEW

Under Task 2, a review of available information and publicly available resources was undertaken to assess further the components of the Project. A list of documents reviewed by IBIS is provided in Annex A. These documents included publicly available information collected by IBIS during the Audit and documents provided by PYTTP.

3.4.3 TASK 3: SITE VISIT

A five-day visit to the Project was conducted between the 15th and 19th December 2019 to understand its operations and its setting and included:

• A brief introductory meeting to understand the historical activities, current operations and known future plans and operations of the Project;


• An accompanied tour of the Project, including touring along the Project perimeter along the boundary by car;

• Interviews and discussions with knowledgeable personnel at the Site;

• Accompanied visits to local community representatives and interviews with members of Affected Households (AHs); and

• A review of documentation made available on-site.

During the site visit, IBIS was accompanied by personnel from PYTTP and ADB. Photographs were taken during the site visit and are presented in Annex D. The documents provided for IBIS’s review are listed in Annex A. During the site visit, IBIS interviewed knowledgeable persons largely in the following three groups, and they include:

• Representatives of PYTTP (“Site Representatives”);

• Representatives of the local authorities (“Government Authority Representatives”), including commune leaders; and

• Selected members of the AHs (“Interviewed Affected Households” or “IAHs”).

Collectively, they are referred to the “Project Representatives”. Further details of the interviewees, including interview notes, are provided in Annex B.

3.4.4 TASK 4: REPORTING

Following the completion of Tasks 1 to 3 above, this report was produced to document the Audit including the findings with recommendations, as appropriate, for additional work to support the Project in aligning with the Applicable Standards in the form of a CAP.

Note that the focus of the Audit has been on assessing those issues that may present the most significant areas for non-compliance or present an obvious potential E&S related reputational risk issue. To support this approach, the following sections provide information on compliance risk ratings used.

In order to assist with setting out the context of non-compliances identified, a colour-coded risk ranking has been provided for the findings. The criteria for each of these is provided in the table below. The risk rankings consider the potential risks and impacts reasonably associated with the components under review.

TABLE 3-1 COMPLIANCE RISK RANKING

Definition Compliance Risk Level

No significant issues identified with respect to alignment with Applicable Standards, or an item that appears to be not applicable and as such does not have an identified compliance risk.

None identified

Item of non-alignment with Applicable Standards, however, is unlikely to create a material E&S impact, although should be rectified as a compliance matter.

Low


Definition Compliance Risk Level

Item of non-alignment with Applicable Standards and is required to have additional documentation, improved management measures or allocation of responsibilities to reduce the risk, and if left unaddressed has the potential to escalate to a high risk issue. Item with potentially limited E&S risk/impacts that are few in number, generally site specific, largely reversible and are likely to be able to be managed through mitigation measures.

Medium

Clear significant item of non-alignment with Applicable Standards that has the potential (or has already) to lead to a significant adverse E&S impact(s). Has the potential (or has already) to lead to adverse media and/or NGO attention. Has the potential to trigger legal action, may lead to a major environmental incident, or may result in fatalities/serious injuries or have irreversible E&S impacts (e.g. clearance of natural forests). May require significant expenditure (>USD100k) to address the gap and align with the E&S Safeguards.

High


ENVIRONMENTAL AND SOCIAL COMPLIANCE REVIEW

4.1 ADB SPS ENVIRONMENT SAFEGUARDS

TABLE 4-1 COMPLIANCE REVIEW: ADB SAFEGUARD REQUIREMENT 1 – ENVIRONMENT

Ref ADB’s Safeguard Principles/Requirements

Local Regulatory Requirements and ADB Safeguard Reference

Commentary/ Findings Risk Ranking

Corrective action

1 Environmental Assessment

Use a screening process for each proposed project, as early as possible, to determine the appropriate extent and type of environmental assessment so that appropriate studies are undertaken commensurate with the significance of potential impacts and risks. Conduct an environmental assessment for each proposed project to identify potential direct, indirect, cumulative, and induced impacts and risks to physical, biological, socioeconomic (including impacts on livelihood through environmental media, health and safety, vulnerable groups, and gender issues), and physical cultural resources in the

Environmental Safeguard, Policy Principles 1, 2 and 3 Law on Environmental Protection (55/2014/QH13) Decree 18/2015/ND-CP on environmental planning, strategic environmental assessment, environmental impact assessment and environmental protection plan Circular 27/2015/TT-BTNMT on strategic environmental assessment, environmental impact assessment and

Environmental Impact Assessment An Environmental Impact Assessment (EIA) was prepared for the Project and approved in writing by Phu Yen People’s Committee on 6th July 2018 (No.: 1343/QD-UBND, dated 6th July 2018). The EIA covers assessing E&S impacts arising from the Project during the preparation stage, the construction stage and the operational stage with the primary Project site and all related facilities of the Project, which include: • A 214.16 MWp solar power plant; • A substation; • Administrative buildings; • A 12.17 km long 220kV transmission line connecting

to the Tuy Hoa substation; and • Ancillary facilities (e.g. laydown area, concrete

prefabrication area, internal roads, utility facilities). The following environmental baselines were established during the EIA exercise: • Ambient air quality (total suspended solid, sulphur

dioxide, nitrogen dioxide, and carbon monoxide).

The local EIA has largely covered impact assessment required in the SPS. Whilst biodiversity assessment was not covered in the report, independent assessment by IBIS is discussed in Item 7 below verified that the Project area is not known to be located in an ecologically sensitive area. PYTTP however should improve the management of the Project’s impact through preparation of a robust operational environmental and social management plan, which is discussed in more detail in Item 2 below.





Corrective action

context of the project’s area of influence. Assess potential transboundary and global impacts, such as emissions of Greenhouse Gases (GHG) and impacts on endangered species and habitat. Use strategic environmental assessment where appropriate. Examine alternatives to the project’s location, design, technology, and components and their potential E&S impacts and document the rationale for selecting the particular alternative proposed. Also consider the no project alternative.

environmental protection plan Decree 40/2019/ND-CP guiding the implementation of some articles of the Law on Environmental Protection Decree 19/2015/ND-CP guiding the implementation of some articles of the Law on Environmental Protection. This decree provides some general provisions for soil contamination management Irrigation Law (08/2017/QH14)

Samples were collected within the Project area and 1 km away from the Project area.

• Ambient noise – Measurements were collected within the Project area and 1 km away from the Project area;

• Ambient water quality (pH value, dissolved oxygen, total suspended solid, chemical oxygen demand, biochemical oxygen demand, total coliforms, nitrate, nitrite, ammonia, phosphate). Samples were collected from the streams flowing across the Project site;

• Soil quality (arsenic, cadmium, copper, lead and zinc). Samples were collected at one sampling location within the Project area;

• Local biological resources; and • Local social and economic conditions. The following social and economic impacts to the local community were assessed in the EIA as part of the impact assessment for the preparation stage of the Project: • Compatibility of the Project with local natural

resources and socioeconomic conditions; • Number of households potentially affected by the

Project; and • Land acquisition required for the Project. The following topics relevant to potential direct E&S impacts that could be introduced by the Project during its construction stage were assessed in the EIA: • Dust and air emissions; • Noise; • Wastewater;





Corrective action

• Solid wastes (including both hazardous wastes and non-hazardous wastes);

• Ecosystem and landscape; • Impacts to the local infrastructure system (including

impacts to regional traffic and impacts to local power supply system); and

• Worker and communities’ health and safety. The following topics relevant to potential direct E&S impacts that could be introduced by the Project during its operational stage were assessed in the EIA: • Wastewater; • Ecological impacts during the maintenance of the

220kV transmission line; • Hazardous wastes; • Impacts arising from the cleaning of PV panels; and • Electromagnetic fields. The following emergencies were covered by the EIA to assess their respective potential impacts: Construction Stage:

• Safety accident of workers; • Fire incident; and • Traffic accident. Operational Stage:

• Electric shock; • Fire incident; • Spill of hazardous materials; • Lighting; and • Natural disasters.





Corrective action

In addition, the EIA also assessed the potential impacts to regional traffic during the decommissioning stage of the Project. Control measures were proposed in the EIA to mitigate potential E&S impacts identified during each phase of the Project. An Environmental Management Plan and an Environmental Monitoring Plan, which cover both the construction and operational stages of the Project, have been developed as part of the EIA. According to the information provided by Site Representatives, the Project site was mainly used for agricultural purposes historically. Other than a graveyard constructed by the local communities (please refer to the Land Acquisition Documentation for further details), no other physical cultural resources were identified in the Project area or known to have existed by Site Representatives prior to the development of the Project. The EIA does not cover the assessment of cumulative impacts. However, it is noted that the Project is surrounded by agricultural land, no other industrial facilities are located in the surrounding area of the Project and no further development is required by the Project or known to be reasonably anticipated. The EIA was submitted to DoNRE of Phu Yen Province for review and approval. The Project obtained approvals for the EIA from the People’s Committee of Phu Yen Province on 7th June 2018.





Corrective action

No activities under the ADB Prohibited Investment Activities List have been identified at the Project, and none was reported by Site Representatives. The Project is designed to have an operational lifespan of 20 years according to its PPA. According to the approved EIA, the Project should conduct the following quarterly environmental performance monitoring: Construction Stage:

• Ambient air; and • Ambient noise.

Operational Stage:

• Electromagnetic field testing; and • Solid waste generation recording (regularly, including

solid wastes and hazardous wastes).

Please refer to Item 3 below for further details regarding stakeholder engagement and public consultation. Please refer to Item 5 below for further details regarding the environmental performance monitoring programmes under the EIA approvals. Natural Disaster and Climate Risk Assessment Flood Risks Separate to the EIA, the Project conducted a meteorology and hydrology study to assess its potential flood risks. According to the study report, the major factor that contributes to flood risk of the Project is from





Corrective action

rainfall (rather than sea level rise). The study assessed precipitation and flooding data for the past 25 years, i.e. from 1993 to 2018, and indicated that flooding would start to occur in the region when the precipitation level in the region is between 120 to 200 mm per day. The following modelling results were presented in the study.

Precipitation Level (mm/day)

Precipitation Frequency

Assessment Estimation

358 mm 30% Some low-lying area of the solar farm site will be flooded locally. However, the Project site will “not be fully flooded”.

443 mm 20% Some low-lying area of the Project site will be flooded locally due to poor drainage system. However, the Project site will “not be fully flooded”.

580 mm 10% Some low-lying area of the Project site will be flooded locally due to local topography and poor drainage system. However, the Project site will “not be fully flooded”.





Corrective action

810 mm 3% The Project area will be flooded with average flood level ranging from 0.5 m to 1.5 m, with flooding level at some locations above 2.0 m.

1,010 mm 1% The Project area will be flooded with average flood level ranging from 1.0 m to 1.2 m, with flooding level at some locations above 3.0 m.

According to information provided by CEEC, the minimum height of a solar panel’s lower edge installed on-site is 0.5 m above ground level (agl). Based on the conclusion of the flood study, the Project will be flooded during the 3% precipitation frequency scenario in accordance with the historical precipitation and the flooding data for the past 25 years. It is noted that all of this work uses historical data and does not make allowance for any future predictions in rainfall pattern changes. In addition, a separate hydrological study was conducted by PECC2 to support the overall Project design by CEEC. The hydrological study report estimated water levels at various cross sections of streams flowing across the Project area with three scenarios, i.e. 5-year return





Corrective action

period, 50-year return period and 100-year return period. According to the information presented in the report, the maximum water depths were identified at cross section 114 of stream 1 with estimated water depth estimated below:

Return Period

Level of Channel Bottom (m above mean sea level)

Water Level (m above mean sea level)

Water Depth (m)

5 Years 28.98 30.38 1.40

50 Years 28.98 30.53 1.55

100 Years 28.98 30.56 1.58

In addition, according to the information made available to IBIS during the Audit, some areas of the solar farm site were flooded and suffered damaged during the storm Nakri, a tropical storm making a landfall at approximately 32 km from Tuy Hoa, Phu Yen Province in November 2019. Further assessment on this topic has been forwarded to the Lender’s technical advisor for their review to identify any additional actions required by the Project. Earthquake





Corrective action

According to information published by the United States Geological Survey (USGS), the Project site in Vietnam is not located in an earthquake prone area. According to a review of the USGS Earth Map and List Database (https://www.usgs.gov/natural-hazards/earthquake-hazards, accessed by IBIS on 31st December 2019), the Project area is not located within a seismic zone. Based on a review of earthquake information captured by the database, no earthquake events were recorded within the Project area and 100 km radius from the Project location. Therefore, earthquake related risks are considered as low for the Project.

2 Environmental Planning and Management

Avoid, and where avoidance is not possible, minimize, mitigate, and/or offset adverse impacts and enhance positive impacts by means of environmental planning and management. Prepare an environmental management plan (EMP) that includes the proposed mitigation measures, environmental monitoring and reporting requirements, related institutional or organizational arrangements, capacity development and training measures, implementation schedule, cost estimates,

Environmental Safeguard, Policy Principle 4 Law on Environmental Protection (55/2014/QH13)

Construction Stage According to information provided by CEEC representatives, as well as a review of Project documentation, environmental (and social) performance of the Project during the construction stage was managed by the Engineering and Health, Safety & Environment (HSE) Department of the EPC contractor with a total of two engineers, i.e. one safety engineer and one quality engineer, and overseen by the EPC Construction Manager cum HSE Manager. Reportedly, the Engineering and HSE Department ceased its function after the commercial operation date (COD) of the Project in June 2019, as the majority of construction activities had been completed by CEEC. Currently, HSE related matters are managed by the Construction Manager of CEEC directly. Regarding environmental and social management plans, the Project has developed a Project Management Plan

The Project should develop a Project-specific operational Environmental and Social Management Plan (O-ESMP), which should include: • OHS Management

procedures including Occupational Hazard Identification Register (see Item 9 below);

• Waste Management procedures, including

https://www.usgs.gov/natural-hazards/earthquake-hazards

https://www.usgs.gov/natural-hazards/earthquake-hazards





Corrective action

and performance indicators. Key considerations for EMP preparation include mitigation of potential adverse impacts to the level of no significant harm to third parties, and the polluter pays principle.

Law on Water Resources (17/2012/QH13) Law on Chemicals (06/2007/QH12) Irrigation Law (08/2017/QH14) Decree 38/2015/ND-CP on waste management Circular 36/2015/TT-BTNMT on hazardous waste management Vietnamese technical regulations on environments (QCVNs) Decree 201/2013/ND-CP guiding the implementation of the Law on Water Resources, including the issuance of groundwater extraction, surface water extraction and wastewater discharge permits

and a Project Health, Safety and Environmental (HSE) Management Plan for the management of environmental (and social) performance during the construction stage, which covers the following topics: • Overall project HSE targets; • Project safety management principles; • Construction site safety requirements; • Construction worker safety requirements; • Construction machinery/tools safety requirements; • Fire prevention requirements; • Flood prevention requirements; and • Training management requirements. In addition, the following plans and assessment were developed or conducted by CEEC to support its HSE management during the construction stage of the Project: • Safety Risk Assessment; • HSE Training Plan; and • Emergency Response Plan. According to the information provided in the HSE Training Management Plan, a training matrix has been developed by CEEC to differentiate training requirements for Project-related personnel at three levels. Reportedly, HSE training was firstly provided to CEEC project management personnel, the trained CEEC project management personnel then provided training to workers engaged by CEEC and management staff of subcontractors. Thereafter, construction workers engaged by subcontractors were trained by their relevant subcontractor management staff.

waste minimisation programmes;

• Hazardous Materials Management procedures;

• Contractor Management Plan (the Contractor Management Plan should ensure that all E&S requirements of the Project are implemented by contractors of the Project and their subcontractors. E&S requirements of the Project should be imposed as part of the contractual obligations for contractors and subcontractors. In addition, a monitoring mechanism should be established to monitor this;

• Traffic and Security measures;

• Emergency Preparedness and Response Plan (including an emergency evacuation





Corrective action

The following environmental training programmes were identified in the above training matrix: • Environmental management related requirements

(for subcontractor management staff and construction workers);

• Control measures for identified environmental hazards (for construction workers);

• Emergency response (for all staff involved in Project construction);

• Environmental legal requirements in Vietnam (for CEEC’s management); and

• CEEC’s requirements and policy on energy and resource efficiency.

Additionally, according to the CEEC Project Management Plan, the following CEEC corporate management plans, procedures and standards have been adopted by the Project for the management of its environmental performance during the construction stage: • HSE Meeting Management Plan; • Emergency Response Management Plan; and • Waste Management Procedure. However, it should be noted that the above plans and procedures do not appear to have been fully implemented by the EPC contractor during the site visit according to the following observations made during the site visit: • Construction wastes were disposed of at various

locations on-site and off-site, and they were not fully

plan, community H&S preparedness and response mechanism, as well as response procedures for all emergency and risk scenarios identified during the risk assessment and hazard identification process, e.g. fire, animal bites, electrocution, flooding, extreme weather and etc.);

• E&S Training and Capacity Management Plan;

• Internal and External Grievance Redress Mechanism.

• Each management procedure/plans describe above will include monitoring parameters and performance indicators; and

• Definition of responsibilities, which includes the organisational structure, roles,


disposed of and removed by the Project upon completion of the construction;

• An environmental compliance register has been developed by one of the subcontractors to support the HSE management of the Project; however, only Chinese HSE regulations were cited in the compliance register (rather than Vietnamese);

• Dedicated HSE management resources were not available after completion of COD of the Project.

Note that a full review of the implementation of HSE management documents etc., was not undertaken given the operational nature of the Project. According to a review of E&S management documentation developed for the construction stage of the Project, environmental monitoring programmes recommended in the approved EIA report for the management of potential environmental impacts during the construction stage of the Project were not incorporated in any of the HSE documents and not implemented by the Project during its construction phase (please refer to Item 4 for further details regarding environmental monitoring). Please refer to Item 8 below for further details regarding H&S management and performance of the Project during the construction stage. Operational Stage No formal Environmental and Social Management Plans (ESMP) or Environmental & Social Management System (ESMS) has been developed by the Project for the management of its environmental (and social) performance, and none is required by law in Vietnam. Environmental performance of the Project is currently managed through the statutory environmental monitoring and reporting programmes required by under approved EIA, i.e. the Environmental Management Plan and the

communication and reporting process required for the implementation of the O-ESMP.





Corrective action

Environmental Monitoring Plan. Various high-level HSE management programmes regarding waste management, wastewater management, occupational health and safety (OHS), and fire safety for the operational phase of the Project were identified as part of the requirements in the approved EIAs, however, detailed procedures to support the implementation of the Environmental Management Plan have not been developed by the Project to-date. No compliance register has been developed by the Project to identify and document all E&S related compliance requirements (including applicable permits/licences and any corresponding renewal dates). No operational stage training and capacity building programmes regarding environmental (and social) management have been developed by the Project. Based on observations on-site, there is a need for the Project to establish formal approaches to supporting its training and capacity building for E&S management.

3 Consultation and Participation

Carry out meaningful consultation with affected people and facilitate their informed participation. Ensure women’s participation in consultation. Involve stakeholders, including affected people and concerned nongovernment organizations, early in the

Environmental Safeguard, Policy Principle 5 Environmental Protection (55/2014/QH13) Decree 18/2015/ND-CP on environmental planning, strategic environmental

The Project has conducted public consultations with both local government authorities, communities, as well as organisations affected by the Project as part of the scope under its EIA. The content of the EIA report has been communicated with the aforementioned parties. Reportedly, the EIA was disclosed at Hoa Hoi commune office in accordance with the relevant regulatory requirements. According to Site representatives, no formal stakeholder engagement plan (SEP) and external grievance

The Project should develop an external grievance mechanism for management of external grievances.





Corrective action

project preparation process and ensure that their views and concerns are made known to and understood by decision makers and taken into account. Continue consultations with stakeholders throughout project implementation as necessary to address issues related to environmental assessment. Establish a grievance redress mechanism to receive and facilitate resolution of the affected people’s concerns and grievances regarding the project’s environmental performance.

assessment, environmental impact assessment and environmental protection plan Circular 27/2015/TT-BTNMT on strategic environmental assessment, environmental impact assessment and environmental protection plan Decree 40/2019/ND-CP guiding the implementation of some articles of the Law on Environmental Protection

mechanism have been developed by PYTTP for stakeholder engagement and grievance redress. The Project should develop a SEP to map relevant stakeholders and formalise engagement measures for external stakeholders.

4 Information Disclosure

Disclose a draft environmental assessment (including the EMP) in a timely manner, before project appraisal, in an accessible place and in a form and language(s) understandable to affected people and other stakeholders. Disclose the

Environmental Safeguard, Policy Principle 6

Public consultation was completed as part of the scope of work of the EIA for the Project, as mentioned under Item 3 above. Reportedly, the EIA was disclosed at Hoa Hoi Commune office, in accordance with the relevant local regulatory requirements.

None required.





Corrective action

final environmental assessment, and its updates if any, to affected people and other stakeholders.

5 Monitoring & Reporting

Implement the EMP and monitor its effectiveness. Document monitoring results, including the development and implementation of corrective actions, and disclose monitoring reports.

Environmental Safeguard, Policy Principle 7 Law on Environmental Protection (55/2014/QH13) Circular 43/2015/TT-BTNMT on environmental monitoring Decree 44/2016/NĐ-CP on industrial hygiene monitoring Law on Water Resources (17/2012/QH13) Decree 39/2016/NĐ-CP guiding the implementation of the Law on Occupational Health and Safety

As mentioned in Item 1 above, the following environmental performance monitoring programmes are required to be implemented by the Project during its construction stage and operational stage: Construction Stage:

• Ambient air monitoring (quarterly); and • Ambient noise monitoring (quarterly).

Operational Stage:

• Electromagnetic field testing (quarterly); and • Waste generation recording (including solid waste

and hazardous wastes, regularly). According to information provided by Project representatives and EPC contractor representatives, at the time of the site visit, no construction stage or operational stage environmental monitoring programmes have been conducted by the Project or its EPC contractors in accordance with the requirements of the approved EIA. The Project should conduct environmental monitoring programmes required by the EIA as soon as possible. In addition, as part of the recommendation for the ESMS development, all regulatory E&S monitoring and reporting requirements, as well as E&S reporting and monitoring

The Project should conduct environmental monitoring programmes required by the approved EIA, i.e. electromagnetic field testing and recording of waste generation, to fulfil the relevant environmental monitoring related requirements as soon as possible. As part of the O-ESMP development recommended under Item 2, the Project should incorporate its E&S monitoring and reporting requirements in the O-ESMP , and also monitor and report other requirements which are identified in the consolidated CAP included in this report.





Corrective action

requirements from the CAP should be included in the ESMS of the Project to ensure adequate implementation.

6 Unanticipated Environmental Impacts

Where unanticipated environmental impacts become apparent during project implementation, the borrower/client will update the environmental assessment and EMP or prepare a new environmental assessment and EMP to assess the potential impacts, evaluate the alternatives, and outline mitigation measures and resources to address those impacts.


The Project was constructed in line with the activities and operations identified in its EIAs. However, as mentioned under Item 1 of Table 4-1, the current design and studies cannot eliminate and protect the solar farm from impact to its operation in the event of severe flood. The flood risk can be considered as an unanticipated environmental impact that should be further evaluated by the Project. Further assessment on this topic has been forwarded to the Lender’s technical advisor for their review to identify any additional actions required by the Project.

Further actions will be recommended by the Lender’s technical advisor to the Project.

7 Biodiversity Conservation and Sustainable Natural Resources Management

Do not implement project activities in areas of critical habitats, unless (i) there are no measurable adverse impacts on the critical habitat that could impair its ability to function, (ii) there is no reduction in the population of any recognized endangered or critically endangered species, and (iii) any lesser impacts are mitigated. If a project is


Based on information provided in the EIA report of the Project, the Project area was mainly consisted with the following categories of land use: • Agricultural land; • Access routes (tracks and paths); • Streams and waterways; • Unused land. Based on information provided in the EIA report of the Project, the Project area is not within any ecologically sensitive or biodiversity conservation area, and no

None required.





Corrective action

located within a legally protected area, implement additional programs to promote and enhance the conservation aims of the protected area. In an area of natural habitats, there must be no significant conversion or degradation, unless (i) alternatives are not available, (ii) the overall benefits from the project substantially outweigh the environmental costs, and (iii) any conversion or degradation is appropriately mitigated. Use a precautionary approach to the use, development, and management of renewable natural resources.

species with significate biodiversity conservation value were identified in the area. According to a review of the Protected Planet Database3 and the Integrated Biodiversity Assessment Tool (IBAT)4, two databases managed by the United Nations Environment World Conservation Monitoring Centre, the Project is not situated in or adjacent to any natural conservation areas.

3 https://www.protectedplanet.net/, accessed and reviewed by IBIS on 30 December 2019.

4 https://www.ibat-alliance.org/, accessed and reviewed by IBIS on 30 December 2019.

https://www.protectedplanet.net/

https://www.ibat-alliance.org/





Corrective action

8 Pollution Prevention and Abatement

a Pollution Prevention, Resource Conservation Apply pollution prevention and control technologies and practices consistent with international good practices as reflected in internationally recognized standards such as the World Bank Group’s Environmental, Health and Safety Guidelines. Adopt cleaner production processes and good energy efficiency practices. Avoid pollution, or, when avoidance is not possible, minimize or control the intensity or load of pollutant emissions and discharges, including direct and indirect greenhouse gases emissions, waste generation, and release of hazardous materials from their production, transportation, handling, and storage. Avoid the use of hazardous materials subject to international bans or phaseouts.

Environmental Safeguard, Policy Principle 9 Law on Environmental Protection (55/2014/QH13) Law on Water Resources (17/2012/QH13) Law on Chemicals (06/2007/QH12) Irrigation Law (08/2017/QH14) Decree 38/2015/ND-CP on waste management Circular 36/2015/TT-BTNMT on hazardous waste management Vietnamese technical regulations on environmental and discharge quality (QCVNs)

Air Emissions Construction Stage Air emissions during the construction stage of the Project were mainly from the following sources: • Dust emissions from construction activities; and • Air emissions from motor vehicles and equipment

operated for the construction of the Project. During the construction phase, the nearby community raised a concern on the dust generation from the activities. In response to the concern, CEEC engaged a subcontractor for the provision of dust suppression and cleaning services for access roads within the community area from the national road entrance to the solar farm gate from 13 January 2019 to 13 July 2019 (based on the information available). In addition, a total of three water tankers were engaged by CEEC and its subcontractors during the construction period to suppress dusts. According to the approved EIA, ambient air monitoring was required to be conducted during the construction stage with monitoring of the following parameters on a quarterly basis with the following parameters: • Total Suspended Particulate (TSP); • Sulphur Dioxide (SO2); • Nitrogen Dioxide (NO2); and • Carbon Monoxide (CO). However, as noted under Item 5, ambient air monitoring was not conducted by the Project or any of its contractors during the construction stage. Since the construction of the Project has been completed at the time of this report

In general, the Project’s performance regarding pollution prevention and abatement is in line with requirements from the ADB Safeguard Policy; however, to ensure its regulatory compliance status, the Project should ensure a groundwater abstraction permit is obtained for the groundwater well installed on-site.





Corrective action

Decree 201/2013/ND-CP guiding the implementation of the Law on Water Resources, including the issuance of groundwater extraction, surface water extraction and wastewater discharge permits Decree 67/2018/ND-CP guiding the implementation of the Irrigation Law

writing, environmental monitoring related obligations cannot be retrospectively applied to the Project. Operational Stage Based on observations on-site, no significate air emission sources from the Project’s operations were identified for its operational stage, and no back-up generators have been installed by the Project. Air emissions during the operational stage of the Project are mainly from the operation of motor vehicles owned by the Project. Wastewater Wastewater generated by the Project during the construction stage and operational stage mainly includes domestic and sanitary wastewater, as well as wastewater generated from solar panel cleaning. During the site visit, no other sources of wastewater were observed and identified. During the operational stage, domestic and sanitary wastewater generated on-site is first collected and treated on-site in an in-ground septic system equipped at each of the buildings and then released into the environment (into the ground) via a soak-away sump. Reportedly, solar panels will be cleaned by cleaning robots with water supplied by water tankers. Wastewater generated from solar panel cleaning will be allowed to drain to the ground directly. Reportedly, no soap or other cleaning agents will be used for the cleaning of the solar panels.


Stormwater Runoff At the time of the site visit, stormwater drainage ditches have been constructed along the perimeter fence and service roads, as well as at certain locations within the solar farm to provide connection to the existing streams flowing across the site. Where internal roads across the drainage ditches, 400 mm diameter culvert pipes were constructed to provide drainage channels. According to the drainage system layout and drawing for construction, a total of 11 km drainage ditches were built within the Project site. All drainage ditches were connected with streams within the Project area for the discharge of stormwater. Evidence of severe soil erosion was observed along drainage ditches during the site visit. Reportedly, the soil erosion was a result of the Storm Nakri in November 2019. Sandbags were provided along the drainage ditches to prevent further soil erosion. Notable sources of potential stormwater runoff contamination were not observed during the site visit. Water Supply Municipal water is supplied to the Project for domestic use, firefighting and solar panel cleaning. A groundwater abstraction well was installed on-site next to the substation with a depth of approximately 60 m bgl. Reportedly, groundwater abstracted on-site is only for the provision of emergency water supply for firefighting and solar panel cleaning. Therefore, the potential risk for the Project to compete with the local community for h groundwater resources is generally considered to be low. A filtration system was installed by the Project in the pump house for the treatment of groundwater prior to use. Reportedly, a groundwater abstraction permit has not been obtained by the Project for abstracting groundwater in accordance with Decree 201/2013/ND-CP. No





Corrective action

groundwater quality testing has been conducted by the Project since installation of the groundwater abstraction well, and none is required by the approved EIA or its environmental monitoring obligations. No groundwater data is available to IBIS for review, as no metering is undertaken on abstracted water to monitor groundwater usage. Electricity Supply Electricity is supplied from the national grid. No back-up generator has been installed by the Project to provide back-up power supply.

b Wastes

Environmental Safeguard, Policy Principle 9 Decree 38/2015/ND-CP on waste management Circular 36/2015/TT-BTNMT on hazardous waste management

At the time of the site visit, no waste management plan or inventory has been developed or prepared by the Project, and no waste data has been collected since the commencement of its operation or during its construction. Based on IBIS’ observations and information provided by Project representatives, key waste streams generated by the Project include: • Construction wastes from the construction of the

Project; • Office wastes generated from the administrative

buildings on-site; • Damaged solar panels (classified as hazardous

wastes); and • Other hazardous waste (i.e. waste oil and oil

contaminated material, used fluorescent bulbs, used printer cartridges, empty paint tins (from building maintenance) generated from operation and maintenance (O&M) and repair activities on-site.

As an immediate action, the company should dispose of the construction wastes appropriately and collect the waste that is scattered within the Project site for proper disposal. As part of the recommendation to prepare an O-ESMP for the Project (Item 2), a waste management plan should be developed to ensure that appropriate management of solid wastes (including collection, storage,





Corrective action

During the construction stage, wastes generated on-site were collected by Hoa Hoi Agricultural Service Corporation (HTX DV NN Hoa Hồi). A service agreement covering the period from 1 January 2019 to 31 May 2019 was made available to IBIS for review. According to the service agreement, the waste collector was required to collect wastes stored on-site twice a week during the aforementioned service period. During the site visit, non-hazardous wastes (domestic and office waste) were stored at the northern corner of the substation. Reportedly, all domestic wastes were stored in four waste bins at the aforementioned location that were observed in the site visit. In addition, construction wastes, including waste containers, waste construction materials, and packaging waste, were observed on-site and off-site at the following locations: • EPC laydown area along the eastern boundary of the

Project site outside of fence; • Outside of the substation; • EPC contractor temporary administration area; and • Scattered within the Project area in small quantities

including in the drainage facility. No waste receptacles were identified in areas where site personnel would frequent, operate, or be required to be stationed, e.g. security posts. Reportedly, during the operational stage, general wastes are collected by a waste collector engaged by PECC2 and disposed of at a waste dump site approximately 250 m to the southwest of the Project site. According to information provided by representatives of the

labelling and disposal) is undertaken. In addition, a robust waste minimisation programme should be developed by the Project to minimise its waste generation and environmental impacts due to waste generated on-site. The Project should also ensure appropriate housekeeping activities are conducted to remove construction waste throughout the Project site, as well as off-site storage areas used by the Project during the construction stage.





Corrective action

Department of Natural Resources and Environment of Phu Hoa District, the waste dump site was approved and managed by the Hoa Hoi commune government, however, open burning was conducted by the local Commune government for the treatment of wastes at this location. According to information provided by Project Representatives, a dedicated hazardous waste storage facility will be constructed on a piece of vacant land at the north-eastern corner of the Project site. Detailed design of this hazardous waste storage facility is not yet available. As the Project has just started its operations, no hazardous waste has reportedly been generated, and no notable presence of hazardous waste was observed on-site by IBIS during the site walkover. No damaged solar panels have reportedly been generated by the Project to-date in operations. At the time of the site visit, no solar panels had been disposed of. Given that some solid waste collection and disposal are carried out by the Project’s contractors, it is recommended that the Project should include a contractor solid waste management program as part of its Waste Management Plan to ensure that the collected solid waste is collected and disposed of in accordance to the local regulatory requirements as well as the contractor services agreements between the Project and the contractors.





Corrective action

In addition, the Project should contract a licenced hazardous waste collection vendor to collect and dispose of the waste once hazardous waste is generated in accordance with the local regulations. Depending on the volume of hazardous waste generated, the Project may be required to obtain a registration of hazardous waste generator from DoNRE. However, given the nature of the Project’s operation understood by IBIS at this point, it is unlikely that the annual volume of hazardous waste will reach the limit of 600 kg/year triggering the need for such registration with DoNRE. In addition, according to the approved EIA, the Project is required to regularly monitor domestic wastes (weight and types) and hazardous wastes (weight and types) during the operational phase. Although no hazardous waste has reportedly been generated to-date by the Project, no monitoring for domestic wastes has been conducted to-date. To fulfil waste management related requirements, a Project-specific Waste Management Plan should be developed to guide the management of solid waste including collection, storage and disposal. In addition, as noted in this report, wastes dumped at the local dump site are subject to open burning by the local government. Therefore, it is important for the Project to develop its waste minimisation and recycling programme to minimise its waste generation, to reduce its environmental impact. As an alternative solution, the Project also may consider disposing of waste at the alternative disposal facility licensed by MONRE in the Ninh Thang Commune.





Corrective action

c Hazardous Materials

Environmental Safeguard, Policy Principle 9 Law on Chemicals (06/2007/QH12) Law on Occupational Health and Safety (84/2015/QH13) Decree 39/2016/NĐ-CP guiding the implementation of the Law on Occupational Health and Safety Decree 113/2017/ND-CP guiding the implementation of the Law on Chemicals Circular 32/2017/TT-BCT guiding the implementation of the Law on Chemicals and Decree 113/2017/ND-CP

The Project has not developed a hazardous materials management plan for its operations, although limited amounts of hazardous materials are anticipated to be present in the O&M of the Project. The transformers on-site are oil-filled and are equipped with secondary containment. Reportedly, transformers installed within the solar farm were pre-filled with transformer oil during their manufacture. No transformer oils were stored on-site at the time of the site visit, as the Project has recently commenced its operations and only minimal maintenance activities are typically required. Vietnam ratified the Stockholm Convention in 2002 which includes a ban on the production and use of polychlorinated biphenyls (PCBs) which have historically been used in transformer oils. Therefore, the likelihood of PCBs being present at the Project is considered to be low. Apart from transformer oil, a minimal volume of petrol (less than 5 litres) was stored in small plastic barrels used for grass cutting on-site. The petrol was being carried by the grass cutting worker during the grass cutting operation. Reportedly, no other hazardous materials were observed or reported to be used or stored on-site.

As part of the recommendation of Item 2, the Project should develop a simple hazardous materials management plan for the management of hazardous materials on-site (with reference to Vietnamese requirements and the WBG EHS Guidelines). In addition, the Project should review and ensure that contractors operating at the Project site also adopt appropriate hazardous materials management plan(s).

d Pesticide Use and Management


Reportedly, no pesticides or herbicides are used on-site, and no observations of them being used were noted during the site visit. Project Representatives confirmed that the use of pesticides or herbicides would not be required for the operational phase of the Project.

None at this point.





Corrective action

Law on Chemicals (06/2007/QH12) Decree 113/2017/ND-CP guiding the implementation of the Law on Chemicals Circular 32/2017/TT-BCT guiding the implementation of the Law on Chemicals and Decree 113/2017/ND-CP

Vegetation within the Project site will be cut manually or using machinery, e.g. trimmers, four times a year.

e Greenhouse Gas Emissions

Environmental Safeguard, Policy Principle 9 Circular 47/2011/TTLT-BCT-BTNMT.

During the operational phase of the Project, no combustion sources are expected to be present on-site, other than from vehicles. Collectively, these GHG emissions are considered minimal. Reportedly no back-up power generator is required on-site during the operational phase. The Site has individual air conditioning units within the administrative building and the substation control building. Vietnam has ratified the Montreal Protocol. As such, the country has been implementing a road map on phasing out R22. However, this gas is still currently permissible for use in Vietnam until 2030. No significant issues were identified in relation to GHG emissions.

None at this point.





Corrective action

9 Health & Safety

a Worker Health & Safety Provide workers with safe and healthy working conditions and prevent accidents, injuries, and disease. Under the Social Protection Strategy, it recommends the project proponent to provide safe and healthy working environment for its employees as well as its contractors/ subcontractors and comply with the national labour laws and take measures to comply with the core labour standards. The ADB SPS mandate that the identified OHS issues must be identified, assessed, and addressed in an EIA for proposed projects.

Environmental Safeguard, Policy Principle 10 Social Protection Strategy

Health and Safety Construction Stage A Fire Safety, Labour Safety and Environmental Protection Management Plan for the Construction Phase was developed by the Project to set out its overarching quality and HSE requirements during the construction stage at a high level. This management plan covers the following HSE aspects during the Project construction: • Registration of equipment and machinery; • Safety signage; • Safety inspections; • Personal protective equipment; • Alcohol policy; • Electrical safety; • Work at height and scaffolding; • Firefighting equipment; • Material storage; • Welding safety; • Waste management; • Housekeeping on-site; and • Training. In addition, CEEC has developed a HSE Management Plan for the management of H&S related matters during the construction stage. The following aspects have been covered by the CEEC Project HSE Management Plan: • Overall HSE targets of the Project; • Project safety management principles; • Safety requirements for the construction site; • Safety requirements for construction workers;

As part of the O-ESMP development, the Project should develop an OHS Management Plan to ensure that potential H&S risks are assessed, and appropriate mitigation measures are identified and implemented in a programmatic and systematic manner. The OHS Management Plan should also include, but not limited to the completion of the following exercises, procedures and documentation: • Complete its

Occupational Hazard Identification Register in accordance with the relevant regulatory requirements;

• Conduct a gap analysis for the existing safe work procedures developed by the Project according to the Occupational





Corrective action

• Safety requirements for construction machineries and tools;

• Fire prevention requirements; and • Flood prevention requirements. A H&S risk assessment was completed by CEEC in accordance with construction activities carried out on-site. The risk assessment identified potential H&S hazards which might happen due to the performance of construction activities. Mitigation and control measures were proposed to each of the hazards identified during the risk assessment. In addition, the following CEEC corporate H&S management plans, procedures and standards have been adopted by the Project for its H&S management during the construction stage: • Construction Site Safety Management Plan; • HSE Meeting Management Plan; • Safety Incident Management Plan; • Emergency Response Management Plan; • Construction Machineries and Tools Safety

Management Procedure; • Firefighting Management Procedure; • Portable Electrical Equipment Management

Procedure; • Gas Cylinder Storage and Management Procedure; • Hot Work Management Procedure; • Work-at-height Management Procedure; and • Confined Space Safety Procedure. According to CEEC representatives, a HSE department was established within the CEEC project management team for the construction of the Project, a safety engineer and a quality engineer were assigned under the HSE

Hazard Identification Register prepared for the Project;

• Develop a PPE selection, use and maintenance procedure;

• Develop an incident and accident reporting and investigation procedure;

• Develop H&S audit and inspection programmes; and

• Develop a training and competency management plan.

In terms of emergency preparedness and response, given the vast area of the Project, there is a need to make provisions of snake-bite kits onsite in case of a snake bite incident. The Project operates 24 hours a day. There is a need to ensure that emergency response measures and equipment





Corrective action

department for the management of HSE related matters during the construction stage with supervision from the Construction Manger cum HSE Manager. Reportedly, due to the majority work was completed after COD of the Project, the HSE department ceased its function thereafter. At the time of the site visit, H&S performance for the reminder construction activities was overseen by the Construction Manager of CEEC. During the construction stage, H&S related requirements from CEEC were communicated through emails to its subcontractors, i.e. CEEC Anhui No.1 Electric Power Construction Co., Ltd., CEEC Anhui No.2 Electric Power Construction Co., Ltd. and PECOM Joint Stock Company. Reportedly, safety inspections were only conducted by CEEC prior to April 2019 due to the tight project completion timeline after April 2019. Reportedly, no other supervision mechanisms were established by CEEC to monitor its subcontractors’ H&S performance. In addition, according to information provided by CEEC representatives, a HSE department was required to be established by its subcontractors who engaged more than 100 workers working for the Project. Although the establishment of an HSE department was not required for those engaging less than 100 workers, a safety officer was required for these subcontractors as the minimal requirement for the management H&S related aspects. H&S related training was conducted in line with the requirement for environmental related training (see Item 2), i.e. training was provided at three different levels. According to the HSE Training Plan developed by CEEC, prior to working on-site, all workers should receive HSE

remain relatively accessible at night.





Corrective action

related training with a minimum of 72 hours, and the following H&S topics were covered by the Training Matrix of the HSE Training Plan: • Health and safety regulations of Vietnam (for the

CEEC Project management team); • CEEC Safety Management Policy (for the CEEC

Project management team); • CEEC health and safety management procedures

(for CEEC Project management team); • Key safety considerations of the Project (for the

CEEC Project management team); • Relevant safe work procedures (for subcontractors

and construction workers); • Safety hazards of the Project and control measures

(for subcontractors and construction workers); • Use of personal protective equipment (for

subcontractors and construction workers); • Emergency response plan (for all personnel involved

in the construction of the Project); • First aid (for subcontractor management staff); • Safety case studies (for all personnel involved int the

construction of the Project). Although a HSE Management Plan and a HSE Training Plan was developed by CEEC, it should be noted that the HSE related requirements were not fully implemented by CEEC and its subcontractors during the site visit made for the Audit, according to the following observations made by IBIS: • A clearly inebriated worker was allowed to enter and

work in the solar farm site; • The permit to work system required by CEEC

corporate procedures was not implemented on-site.


Construction workers were not aware of requirements regarding the permit to work system;

• Inappropriate use of personal protective equipment (PPE) during the performance of high-risk activities were observed by IBIS during the site visit, e.g. welding without wearing a welding mask, work at height without appropriate scaffolding, no permits to work were obtained for hot work, work at height and confined space entry, no gas testing and monitoring was conducted for confined space entry;

• Scaffolding for the construction of the administrative building was not erected to provide sufficient protection to workers to prevent fall ; and

• Dedicated HSE management resources were removed after COD of the Project.

In addition, apart from CEEC, one local construction company was engaged by the Project directly for the construction of an accommodation facility for O&M staff near the substation of the Project. Detailed H&S arrangement for this company was not made available to IBIS during the Audit. Operational Stage Reportedly, an Occupational Hazard Identification Register was under preparation by the Project at the time of the site visit. According to Project representatives, hazard identification for the preparation of the Hazard Identification Register was conducted by the Project in accordance with the ISO 31000 Risk Management Standard. At the time of the site visit, the Project was gathering comments and inputs from Heads of Operation of the Project, as well as management staff of O&M subcontractor and the security service provider for the finalisation of hazard identification documentation. It should be noted that as the Project has already declared commercial operation, operating without a Hazard


Identification Register is considered as a non-compliance issue against the relevant Vietnamese regulatory requirements. Although an Occupational Hazard Identification Register has not been prepared by the Project, a safety procedure, Safety Process for the Hoa Hoi Solar Power Plant (Quy Trình An Toàn Nhà Máy Điện Mặt Trời Hòa Hội), was developed by the Project for the management of safety related matters. The following aspects have been covered by the safety procedure: • General provisions of safety requirements of the

Project; • Permit to work system for activities related to

electrical equipment; • Safety requirements on the use of machine and

tools; • Safety requirements for scaffolding; • Safety requirements for work at height; • Safety requirements for the use of mobile ladders; • Safety requirements for the use of safety harness; • Safety requirements for welding works; and • Emergency response procedure for electric shock. Reportedly, during the operational stage of the Project, overall H&S performance of the Project is overseen by the Deputy Plant Manager of the Project with support from a Head of Operation of the Technical Operation Team, Mr. Doan Ngoc Thu. In addition, PECC2 is responsible for H&S performance of O&M activities carried out on-site. According to the O&M contract entered between CEEC and PECC2, PECC2 is required develop a HSE Management Plan for O&M activities on-site, as well as other activities carried out by third parties within the Project site. In addition, as part of the contractual requirements, the O&M contractor





Corrective action

was required to fulfil requirements from the IFC EHS Guidelines during the contracting period. Reportedly, the O&M H&S Management Plan is currently under development by the O&M contractor with support from the Project management team; however, a copy of the draft management plan was not made available to IBIS for review during the Audit. Regarding H&S statistics, according to information provided by Project representatives at the time of the site visit, no reportable accidents happened on-site since construction started. Monitoring and reporting of H&S performance is required by Vietnamese regulations through the submission of the statutory Labour Accident Report to the relevant local governmental authority biannually, however, the Project has not yet prepared or submitted any H&S monitoring report to any regulatory authority. In addition, the O&M contract also requires the O&M contractor to report any fatalities, lost time injuries, or property damage to CEEC during the contracting period. Regarding H&S training and capacity management, the Project has not yet established any training and capacity management plan for the operational phase to ensure Project staff and contractor staff have the relevant capacity and competency to manage H&S matters on-site. A training matrix has not yet been prepared by the Project to identify its H&S training needs. Contractor H&S Performance Management Reportedly, as part of contractor’s contractual obligations, contractors and subcontractors are required





Corrective action

to fulfil H&S requirements required by the local regulations. In addition, according to information provided by Project representatives, all contractors are required to prepare their safety measures which will need to be reviewed and approved by the Project management team. Life & Fire Safety Construction Stage Emergency Preparedness and Response An Emergency Response Plan (ERP) was developed by CEEC for the construction stage of the Project. Reportedly, this ERP was prepared in accordance with the risk assessment conducted for the Project. The following aspects have been considered in the ERP: • Principles for managing emergencies; • Roles and responsibilities; • Emergency response procedures for the following

scenarios: o Personal death and injuries, including fall from

height, fracture, electric shock, heat stroke, asphyxia in confined space;

o Fire incidents; o Electric shock incidents; o Accidents in confined space; o Structure collision; o Machinery and equipment accidents; o Environmental contamination; o Severe weather; o Traffic accidents; o Food poisoning incidents; and





Corrective action

o Acute infectious disease breakout. First Aid According to information provided in the HSE Training Management Plan developed by CEEC, first aid training was required to be completed by the management staff of its subcontractors. Reportedly, first aid facilities were provided on-site prior to COD of the Project. Subsequently all first aid facilities were abandoned at the time of the site visit, as majority of construction activities have been completed. Fire Safety As noted above, during the construction stage of the Project, firefighting equipment related overarching requirements were incorporated in the Fire Safety, Labour Safety and Environmental Protection Management Plan for the Construction Phase developed by the Project. The construction of the Project was largely completed at the time of the site visit. Reportedly, a fire drill was conducted by the Project with its EPC contractor and two subcontractors, i.e. CEEC, PECC2, and its security company, in October 2019. The fire drill covered the substation of the Project and the temporary administrative building of CEEC. According to information provided by Project representatives, the local fire department also participated the fire drill, and no areas for improvement were identified by the local fire department or by the Project.





Corrective action

In addition, according to information made available to IBIS, one fire incident happened during the construction stage of the Project. Only small amounts of damage to assets reportedly occurred, and no fatalities or injuries were involved in the accident. Operational Stage Emergency Preparedness and Response Apart from the emergency response procedure for electric shocks developed in the safety procedure of the Project, no other emergency response plans have been prepared by the Project to respond possible emergencies during its operational stage. Reportedly, an emergency communication protocol has been established between the security team and the Project management team, however, no relevant document was provided. According to the security team representatives, if an emergency is identified by a security team member on-site, the security personnel at the scene will first communicate the emergency with the security team supervisor through walkie-talkie or mobile phone. The security team supervisor will then liaise the Project head of operation and confirm adequate response measures to respond to the emergency. Emergency response procedures for potential technical failure of the Project have been documented in the Hoa Hoi Solar Power Plant and the Regional Transmission Line Operating Procedure developed by the EVN National Load Dispatch Centre. These emergency





Corrective action

response procedures are designed to support the prevention of H&S emergencies or their escalation. First Aid During the site visit, a first aid box was observed in the ground floor lobby of the administration building. Reportedly, first aid training was completed by all electricians engaged by the Project during the electrician certification process. In addition, a total of six employees have participated the labour safety training, which includes occupational first aid training, and obtained their Labour Safety Certificates. Currently, the Project site does not store or keep any anti-venom antidote or snake-bite kits for use in a snake-bite event. Although Project Representatives reported no poisonous snakes were known to be present in the Project site, the provision of a snake-bite kit is strongly recommended particularly during the grass cutting operation at the Project. Fire Safety A Fire Safety Approval dated 9th August 2019 has been obtained by the Project from the General Department of Fire Prevention and Fire Fighting. A fire safety plan has been developed by the Project for the management fire safety on-site. According to information provided in the Fire Safety Plan, a fire prevention and firefighting team has been established by the Project consisting of three


sub-teams and a total of 12 people. The firefighting team is incorporated on the three shifts per day. An automatic fire alarm system has been installed at the substation and platforms within the solar farm (platform hosting inverters and transformers). The following firefighting equipment and systems have been installed for the Project: Substation: • Automatic water mist firefighting system for two

substation transformers; • Gas-based fire suppression system for the substation

control room; • Powder-type portable fire extinguishers; and • CO2 portable fire extinguishers. Each of the platforms (inverters and transformers within the solar farm): • Automatic FM 200 gas fire suppression system; • One CO2 portable fire extinguisher; and • One powder type portable fire extinguishers. The administrative building was under construction at the time of the site visit. No firefighting equipment had been installed within the building at the time of the site visit. In addition, a total of three irrigation water ponds within the Project site were converted to firefighting water ponds to provide firefighting water supply. These water ponds are located at the following locations: • Approximate 300 m southeast of Gate A of the

Project; • Approximate 270 m east of Gate B of the Project;

and • Around the northwest corner of the Project.





Corrective action

According to Project Representatives, fire extinguishers and sprinkler systems on-site were inspected on a biannual basis; however, no documents were available to substantiate it. The fire alarm system installed for the Project and the automatic firefighting system installed for the substation will reportedly be inspected on an annual basis. Fire drills are planned to be conducted by the Project on a biannual basis. In addition, the local fire department will participate in one fire drill each year. Apart from the aforementioned fire drill conducted in October 2019 by the Project, no other fire drill or emergency drill has been conducted by the Project thereafter.

b Community Health & Safety Establish preventive and emergency preparedness and response measures to avoid, and where avoidance is not possible, to minimize, adverse impacts and risks to the health and safety of local communities.

Environmental Safeguard, Policy Principle 10 Decree No. 102/2017/ND-CP on registration of security measures

The Project site is mainly surrounded by agricultural land and some residential areas. The nearest community is located immediate east of the solar farm site near Gate #2. Although the Project is located at a relatively remote location, the Site may give rise to some community H&S issues. To-date, these have not been systematically considered by the Project. Given the context and observations on-site, a community H&S emergency response plan should be developed by the Project to provide preparedness and response measures for possible community H&S issues due to the operation of the Project. This should include identifying points of community contact in the event of an issue e.g. a fire. Security

As part of the recommendation for Item 2 and the development of O-ESMP, the Project should develop a traffic and security management plan for the access to the Project site and include community H&S preparedness and response related measures and communicate the relevant information to the community and relevant government authorities as appropriate.





Corrective action

Security services at the Project is subcontracted by the O&M contractor to a third party known as Huy Hung Security with a total of 40 people working for the Project. Security personnel in Vietnam are required to undergo mandatory training and to be registered under Decree No. 102/2017/ND-CP on Registration of Security Measures. No firearms are used or kept on-site by the security personnel. According to the Project Representatives, no security Code of Conduct has been developed or communicated to the security services contractor. It is recommended that, the Project should develop a Code of Conduct for its security contractor on-site and ensure that all security personnel adhere to the Code of Conduct. In addition, apart from the security houses at the two gates of the Project, no guard houses were constructed at other security posts for use by security personnel to perform their duties. One of the security posts along the boundary of the Project site was set up using a plastic tarpaulin tied to solar panel frames in the stormwater drainage and presented a poor place for security guard to be positioned from a welfare perspective. Security guards should be provided with appropriate resources whilst working on-site, such as drinking water and an appropriate setup as a work base.

The Project should also develop the Code of Conduct under the HR Policy In addition, the Project should ensure that adequate security posts are established along the boundary of the Project site to provide appropriate working conditions for all security personnel.

10 Physical Cultural Resources

Conserve physical cultural resources and avoid destroying or damaging them by using field-based surveys that employ qualified and experienced

Environmental Safeguard, Policy Principle 11 Law on Cultural Heritages (28/2001/QH10) and

According to information provided by Project representatives, the only physical cultural structures within the Project area was a graveyard belonging to the local communities. There were 28 graveyards relocated to two off-site locations, 18 graves of the Cham Roi ethnic group were relocated along the eastern boundary

None required.





Corrective action

experts during environmental assessment. Provide for the use of “chance find” procedures that include a pre-approved management and conservation approach for materials that may be discovered during project implementation.

Amendment (32/2009/QH12)

of the Project site and 10 graves belonging to the Kinh people were relocated in an existing Kinh cemetery. Traditions of the Cham people were reportedly upheld as part of the relocation and this was confirmed through interview with Cham people. According to information provided to IBIS, agreement for the relocation of the graveyard was obtained by the Project from 18 affected households. Please refer to the Land Acquisition Documentation for further details regarding grave relocation. No other obvious large features of tangible cultural heritage were identified during the site visit, and none was identified in historical land use related documents reviewed by IBIS. At this stage, impacts on physical cultural resources is not considered to be an issue.

TABLE 4-2 LABOUR AND WORKING CONDITIONS


Reference Commentary/ Findings Risk Ranking

Corrective action

1 Child Labour

Appropriate steps should be taken to ensure that procurement of goods and services, contractors, subcontractors, and consultants, comply with the country’s labour legislation as well as with the Core Labor Standards. The Core Labour

ADB’s Social Protection Strategy (2001)

Vietnam has ratified ILO conventions, including Minimum Age Convention, 1973 (No. 138) and Worst Forms of Child Labour Convention, 1999 (No. 182). According to information provided by Site representatives, a Child Labour Policy has not yet been established by the Project, however, relevant regulatory requirements have been followed by the Project during recruitment. In addition, the same

The Project should update the HR policy in accordance with the Collective Bargaining Agreement and the Labour Code of Vietnam, as well as ensure that the following components are covered:




Corrective action

Standards consist of (a) freedom of association and the effective recognition of the right to collective bargaining, (b) the abolition of all forms of forced or compulsory labour, (c) effective abolition of child labour, and (d) elimination of discrimination in respect of employment and occupation.

regulatory requirements have been required by the Project from its contractors through compliance related contractual obligations during their engagement. Detailed date of birth related information for employees of Project and the O&M contractor was made available to IBIS for review, no employees under the age of 18 years old at the time of signing the employment contract were identified. Given the involvement of contractors for this Project, i.e. majority of the O&M and security related activities are performed by its contractors and contractors’ subcontractors, it is recommended that a contractor management plan is put in place for manpower management.

• Detailed labour and working conditions, especially requirements regarding overtime payment;

• Non-discrimination; • Equal opportunity; • Equal remuneration

for equal work; and • No child and forced

labour. In addition, the Project should implement a contractor management plan which includes a mechanism to ensure that contractor workers are paid fairly (including any overtime) and on-time, have the right to join a union freely and that the company HR policy is adhered to.

2 Forced Labour

Appropriate steps should be taken to ensure that procurement of goods and services, contractors, subcontractors, and consultants, comply with the country’s labour legislation as well as with the Core Labor

ADB’s Social Protection Strategy (2001)

During the Site visit, no observations of the potential use of forced labour were noted. Reportedly, all technicians who received with electric technician training were required to sign a mutually agreed three-year service bond, as the training fees were reimbursed by PYTTP.

See above.




Corrective action

Standards. The Core Labour Standards consist of (a) freedom of association and the effective recognition of the right to collective bargaining, (b) the abolition of all forms of forced or compulsory labour, (c) effective abolition of child labour, and (d) elimination of discrimination in respect of employment and occupation.

Vietnam has not yet ratified ILO convention C105 - Abolition of Forced Labour Convention, 1957. Force labour related requirements are currently managed through compliance related contractual obligations during the engagement of contractors.

3 Payment of Wages

Appropriate steps should be taken to ensure that procurement of goods and services, contractors, subcontractors, and consultants, comply with the country’s labour legislation as well as with the Core Labor Standards. The Core Labour Standards consist of (a) freedom of association and the effective recognition of the right to collective bargaining, (b) the abolition of all forms of forced or compulsory labour, (c) effective abolition of child labour, and (d) elimination of discrimination in respect of employment and occupation.

Social Protection Strategy (2001)

Based on review of available documents related to wages, no evidence was identified to indicate that wages for full time staff of the Project were below the minimum wage requirements. Project representatives reported that payments of compulsory social insurances for employees are made in accordance with regulatory requirements. A mechanism to oversee the working conditions agreed between contractors and their employees has not been established by the Project. Given the involvement of contractors during the operation of the Project, it is recommended that a process is put in place to ensure that contractor workers have appropriate terms in place and there is a process to confirm that wages are being paid to contractor workers appropriately (including overtime) and contributions e.g. social and insurance, are being made as required.

See above.




Corrective action

4 Working Hours and Overtime



As noted above, the Project operates on a 24-hour basis on a two-shift pattern, except for the administrative staff. Shift patterns for different operations are summarised as below: Administrative staff:

• Monday – Friday: 08:00 to 17:00 hrs (including a one hour lunch break).

Technical staff:

• Seven days a week; • Day shift: 07:00 to 19:00 hrs; and • Night shift: 19:00 to 07:00 hrs. O&M contractor staff:

• Monday – Sunday: 08:00 to 17:00 hrs (including a one hour lunch break).

Security Team: • Seven days a week; • Day shift: 06:00 to 18:00 hrs; and • Night shift: 18:00 to 06:00 hrs. PYTTP entered into a Collective Bargaining Agreement with its employees in December 2019. According to the Collective Bargaining Agreement, all employees of the company are required to work 48 hours per week and overtime will be paid by the company in accordance with the employee’s monthly wage and the company regulations. According to information provided by Project HR representative, an employee handbook is currently under development and the company was compensating overtime

See above.




Corrective action

payment in accordance with the relevant provisions of the Labour Code. As noted above, a mechanism to oversee working hours and overtime of contractors’ employees has not been established by the Project. Given the involvement of contractors during the operation of the Project, it is recommended that there a process is put in place to ensure that contract workers’ working hours and overtime is under the supervision of the Project (and that payment is made) is also included.

5 Non-Discrimination and Equal Opportunity



Whilst the Company has not developed any formal non-discrimination policy, it is noted that Vietnam has ratified the ILO Convention relating to Non-Discrimination (C111) and Equal Remuneration (C100). Project Representatives indicated there were no issues in relation to this topic. According to information provided by Site representatives, and at the time of IBIS’ site visit, out of 14 employees contractually engaged by PYTTP, one female employees are employed by the Project to perform administrative duties. No issues regarding non-discrimination and equal opportunity were reported by Project Representatives within PYTTP. No evidence of this was identified during the Project visit. However, it is noted that non-discrimination and equal remuneration or equal opportunities are not explicitly mentioned in the company requirements. In addition, according to information obtained by IBIS during the site visit, female workers engaged by the

See above.




Corrective action

O&M contractor for grass trimming were paid with approximate USD1 per day less than male workers. Although the workers were not directly engaged by the Project, this is considered gender-based discrimination related issue, relevant to the Project under the scope of contractor management. The Project has developed a grievance mechanism for redressing grievances from internal stakeholders. The grievance mechanism documented channels and procedures for internal stakeholders to submit their grievances, as well as the timeframe for the company to investigate and redress the grievances. No grievances have been reported.

6 Freedom of Association



It is noted that Vietnam has not yet ratified the ILO Convention C087 Freedom of Association and Protection of Right to Organise Convention, 1948 (No. 87), however, the trade union and collective bargaining related requirements have been included as part of the Labour Code of Vietnam. Reportedly, a workers’ union has been established by PYTTP to fulfil regulatory requirements in Vietnam, and currently the union is under the management of the General Manager of the Project, Mr. Doan Dac Sang, with support from three employees. In addition, as noted above, a Collective Bargaining Agreement has been agreed between the workers’ union and the company on 1st December 2019. The Collective Bargaining Agreement is valid for three years and will be renewed for another three years if no modifications or new agreements are made between the employer and the trade union. The following aspects are covered by the Collective Bargaining Agreement:

None required at this stage.




Corrective action

• Performance appraisal; • Working hours; • Leave policy; • Wage policy; • Compensation adjustment; • Bonus; • Staff benefits; • Disciplinary activities; • Freedom to join social and political organization.

8 Supply Chain Management



Due to the nature of its operations, the Project is exposed to relatively limited supply chain risks during its operational phase. However, as noted above, given contractors’ extensive involvement for the operation of the Project, a contractor management plan should be developed by the Project to manage contractor’s social (and environmental) performance.

See Contractor Management Plan related requirement under Item 2 above. The Contractor Management Plan should ensure that all E&S requirements of the Project flow through to contractors of the Project and their subcontractors. In addition, a monitoring mechanism should also be established in the Contractor Management Plan to monitoring the contractors and subcontractors’ E&S performance.




Corrective action

9 Gender

The policy recognises the need to improve the status of women and to promote their potential role in development practices. The strategy of the policy is based on the consideration of social justice and gender equity that investment in women is vital to achieving economic efficiency and growth. The key elements of the policy relates to the following: Gender Sensitivity: Focuses on how the operations of the project proponent will affect women and men, and to take into account women’s needs and perspectives in planning its operations. Gender Analysis: Focuses on the systematic assessment of the impact of a project on men and women, and on the economic and social relationship between them. Gender Planning: Focuses on specific strategies that aim to bring about equal opportunities for men and women.

Gender and Development Policy (1998).

At the time of the Project visit, no gender-related assessment or plan has been made by PYTTP or the Project. No official gender-related mandates have been developed to inform gender development/initiatives at the Site. As noted above, out of 14 employees contractually engaged by PYTTP at the Project site, only one employee is female. No female workers have been engaged by the O&M contractors of the Project to conduct any O&M activities due to the nature of the work. According to the information provided by Project Representatives, an anti-sexual harassment policy has not been developed by PYTTP to provide a formal procedure for female employees to report sexual harassment related incidents, if any. Given the number of female employee working on-site, it is important that a private and confidential channel is provided to female employee for reporting any sexual harassment.

Develop, adopt and implement an anti-sexual harassment policy including an effective and accessible harassment reporting mechanism, a private and fair investigative process, a fair and transparent redress system and communicate the policy to all Project employees. Implement measures to provide employment and income opportunities for women from local communities.




Corrective action

Gender Mainstreaming: Focuses on the consideration of gender issues in all aspects of the project proponent’s operations, accompanied by efforts to encourage women’s participation in the decision-making process in development activities. Agenda Setting: Focuses on the formulation of strategies to reduce gender disparities and in developing plans and targets for women’s and girls’ education, health, legal rights, employment, and income-earning opportunities.


4.2 ADB SPS INVOLUNTARY RESETTLEMENT SAFEGUARDS

The ADB Involuntary Resettlement Safeguards are triggered for this Project. According to Paragraph 5 of the ADB Safeguard Requirements 2: Involuntary Resettlement, the involuntary resettlement requirements apply to physical displacement resulting from involuntary acquisition of land or involuntary restrictions on land use or on access to legally designated parks and protected areas. Resettlement is considered involuntary when displaced individuals or communities do not have the right to refuse land acquisition that results in displacement. In the case of this Project, the Project site is mainly situated on land use right privately owned land. Based on information collected during this Audit, land use right acquisition involving nearly 166 households (land users) within the solar farm and its associated facilities.

TABLE 4-3 SAFEGUARD REQUIREMENTS 2: INVOLUNTARY RESETTLEMENT

ADB’s Safeguard Principles/Requirements Commentary/ Findings Corrective action

Involuntary Resettlement Safeguard Requirement is triggered although the Project development had not anticipated ADB financing.

The solar farm and its associated facilities are located in an area of around 262 hectares, the solar farm itself being 256 ha has been leased to the Project for 50 years. Prior to the resumption of land rights (and prior to any involvement by ADB) by the government and thereafter transfer to the Project/company, the land was used for agricultural purposes, mostly plantation for single cropping of cassava and sugarcane. However, based on the information available, the relatively poor soil quality did not support any significant livelihood dependence of user families. Though economic dependence on the affected land was not primary, nearly 166 households were impacted by loss or disruption of livelihoods due to the land-take for the solar farm and its associated facilities. The land transfer/lease also impacted the community graves of the Cham ethnic group (16 households). It also resulted in disruption of community access to areas adjoining the solar farm. The Audit on the land transfer process and its impact on existing land users confirmed that: a) the resumption and transfer of land rights was done in

Further assessment of any vulnerabilities as a result of the Project land take should be undertaken and a Livelihood Restoration Plan (LRP) that is proportionate to the extent/severity of impact should be prepared and implemented, especially for any poor and vulnerable households. The LRP will be prepared and implemented for the benefit of affected/vulnerable willing/suitable families. It will build on the livelihood support already provided to the affected households to further address any long-term impact of land and livelihood losses. The LRP will include assessment of the socio-economic condition of the affected households and the provision of opportunities for skills building and alternative livelihood to ensure the restoration of livelihood status to at least pre-Project level.



general accordance with the statutory requirements; b) all affected households were compensated for the loss of income resulting from loss of land and other productive assets; c) there was/is no known legacy or current/ ongoing encumbrances or risks associated with the Project land; and d) the land and asset compensation process provided enhanced compensation/ benefits which beyond statutory requirements and were largely aligned to SPS requirements. In addition, the affected households (118 of 166 total affected households) were given additional allowances (in the form of compensation and optional training) to support their transition. Further detail is included in the Land Acquisition Process Documentation with respect to these aspects and is not duplicated in this report except for inclusion of relevant items in the CAP.

4.3 ADB SPS INDIGENOUS PEOPLES SAFEGUARDS

According to Paragraph 9 of the ADB Safeguard Requirements 3: Indigenous Peoples, the safeguards are triggered if a project directly or indirectly affects the dignity, human rights, livelihood systems, or culture of Indigenous Peoples or affects the territories or natural or cultural resources that Indigenous Peoples own, use, occupy, or claim as their ancestral domain. According to information obtained by IBIS during the Audit, one group of indigenous people, Cham people, was affected by the Project directly during the development of the Project, including land acquisition, impacts on their livelihoods as well as impacts to physical cultural heritage belonging to the indigenous people. Therefore, ADB SPS Indigenous People Safeguards are triggered.


TABLE 4-4 SAFEGUARD REQUIREMENTS 3: INDIGENOUS PEOPLES


Indigenous Peoples Safeguard Requirement is triggered although the Project development had anticipated ADB financing.

The land take for the establishment of the solar farm included land used as a communal graveyard of the Cham Hoi Roi ethnic group, to which they had a cultural and collective attachment. The Audit confirmed that the graves were relocated, based on the socio-cultural norms of the Cham Hoi Roi, and a compensation payment was negotiated based on the terms of the affected Cham Hoi Roi people. Evidence gathered and corroborated in the process of the Audit established that meaningful consultations were conducted, and broad consensus amongst the affected Cham Hoi Roi people was achieved before the graves were relocated. Representatives from the village level commune confirmed that great consideration was given to comply with the customary and cultural practices of the Cham Hoi Roi. The tribal chieftain, tribal mayor, and affected households confirmed that they were satisfied with the received compensation, and their cultural practices were sufficiently followed in the relocation of the graveyard. The compensation and process for relocation of graves involved extensive and culturally oriented engagement with the ethnic group, including all impacted households. It was through these engagements that negotiation on compensation rates, timelines, and the process of the relocation of graves were mutually agreed. In addition, the Project has made commitments including fencing of the new gravesite, construction of road and a bridge for easy access to these community graves. These actions are under implementation and understood to be completed in the near future.

Aside from the fulfilment of outstanding commitments related to the relocation of the graves, the Project shall a) continue to engage with the Cham Hoi Roi people in a culturally appropriate manner, and b) strive to proactively provide economically gainful opportunities, as a part of the larger livelihood restoration measures, for socio-economic development to willing and qualified households of the Cham ethnic group.



Further detail is included in the Land Acquisition Process Documentation with respect to these aspects and is not duplicated in this report except for inclusion of relevant items in the CAP.


4.4 CORPORATE SOCIAL RESPONSIBILITY ACTIVITIES

According to Project Representatives, PYTTP has supported a number of community initiatives since its initial establishment. Based on information provided by Project Representatives and information collected from review of available documents in relation to the community initiatives, IBIS understands that these initiatives have included:

1. Construction of public roads; 2. Providing scholarships to students in Phu Yen High School; 3. Provision of financial support to poor military families in the commune; 4. Provision of financial support to build new kitchen in the local primary school; and 5. Donation of 20,000 trees to reinstate a 5 ha forest land affected by forest fire in

August 2019.

In addition, the Project has planned a total of 12 corporate social responsibility (CSR) programmes in 2020 with a total estimated budget of USD 61,700 to continue its existing community initiatives, as well as the following new activities:

1. Provision of electrical safety training to local students; 2. Construction of a bridge to connect the roads along the eastern boundary of the

Project site; 3. Construction of additional classrooms for the local high school; 4. Building playground and light system for the Viet-Korea Friendship Village; 5. Building a street light system for Lac Chi Village; and 6. Donation of books to local students from poor families.

4.5 PROJECT CATEGORIZATION

Following the ADB’s SPS Categorisation System and based on the gap analysis conducted above, the proposed categorisation of the Project is presented in the below table.

TABLE 4-5 PROPOSED CATEGORISATION FOR THE PROJECT

Project Environment (1) Involuntary Resettlement (2)

Indigenous Peoples (3)

Phu Yen Solar Project Category B Category B Category B

Note:

(1) Category B. Based on the information provided (including from the locally completed EIA) the impact level is considered to be generally site-specific, few, if any of them are irreversible if properly managed. Thus, the proposed environmental categorisation of the Project is B.

(2) Category B. The proposed project categorization of the Project is B, due economic displacement nearly 166 households within and beyond the Project area. The resumption and transfer of land was done in accordance with statutory requirement. The affected households were compensated including enhanced benefits beyond statutory requirements and were largely aligned to ADB SPS requirements. Additional measures will be implemented to ensure that the livelihood of the affected households, especially the poor and vulnerable, will be enhanced or at least restored to pre-project level. No physical displacement occurred as a result of the land use right acquisition process.


(3) Category B. The proposed project categorization of the Project is B, due to the limited impacts on indigenous people, because of the relocation of 16 graves belonging to Cham ethnic group.


CORRECTIVE ACTION PLAN

This Section summarises the proposed list of corrective actions that should be undertaken by the Project to address the gaps against the Applicable Standards identified in Section 3.2 of the ESDD. The proposed CAP of the Audit is provided in the table below, along with proposed timelines and specific action items. Minor cists means under USD10k

TABLE 5-1 PROPOSED CORRECTIVE ACTION PLAN FOR THE PROJECT


Budget/Resources

1. The Project should develop a Project-specific operational Environmental and Social Management Plan (O-ESMP), which should include: • OHS Management procedures including

Occupational Hazard Identification Register; • Waste Management procedures, including waste

minimisation programmes; • Hazardous Materials Management procedures; • Contractor Management Plan - the Contractor

Management Plan should ensure that all E&S requirements of the Project are implemented by contractors of the Project and their subcontractors. E&S requirements of the Project should be imposed as part of the contractual obligations for contractors and subcontractors. In addition, a monitoring mechanism should also be established to monitor this;

• Traffic and Security measures; • Emergency Preparedness and Response Plan

(including an emergency evacuation plan, community H&S preparedness and response mechanism, as well as response procedures for all emergency and risk scenarios identified during the risk assessment and hazard identification process,

O-ESMP, including procedures and sub-plans

PYTTP By Q4 2020 (The Project should

prioritise the development of the

Emergency Preparedness and Response Plan by

completing this document by Q2

2020)

<USD 50k if not undertaken by PYTTP.



Budget/Resources

e.g. fire, animal bites, electrocution, flooding, extreme weather and etc.);

• E&S Training and Capacity Management Plan; • Internal and External Grievance Redress

Mechanism. • Each management procedure/plans describe above

will include monitoring parameters and performance indicators;

• Definition of responsibilities, which include organisational structures, roles, communications and reporting process required for the implementation of the ESMP.

2. Regulatory Compliance: The Project should conduct environmental monitoring required by the approved EIA to fulfil the relevant environmental monitoring required to be submitted to local regulatory agency.

Environmental Monitoring Report

PYTTP By Q1 2020 for the first environmental monitoring round.

<USD 5k to conduct environmental monitoring programmes required by the approved EIA for each quarter.

3. Regulatory Compliance: The Project should ensure a permit to abstract is obtained for the groundwater well installed on-site.

Groundwater abstraction permit

PYTTP By Q2 2020 Administrative time only and limited costs for the permit (assuming all in order)

4. Ensure appropriate housekeeping activities are conducted to clean construction wastes throughout the Project site, as well as off-site storage areas used by the Project during the construction stage of the Project.

Evidence of construction waste cleaning from the Project Site.



5. Resolve the unsafe conditions at the site for the remaining construction activities (e.g. working at height and hot-work without proper equipment and safe-work procedures) through implementation of safety protocols and conduct independent daily safety checks.

Safety report for the remaining construction activities


Administrative time and minor costs



Budget/Resources

6. The Project should develop an external grievance mechanism for management of external grievances

GRM PYTTP By Q2 2020


7. Designation of Environment, Health, Safety, and Security (EHSS) Officer to manage remaining construction and operations stage E&S issues through implementation of robust on-site environment and social management plan (ESMP). Better manage EHSS aspects on day-to-day operations and ensure that necessary improvement on the overall EHSS performance of the Project is achieved.

Appointment of EHSS officer

PYTTP Immediate Dependent on skills and experience

8. The Project should update the HR policy in accordance with the Collective Bargaining Agreement and the Labour Code of Vietnam, as well as ensure that the following components are covered: • Detailed labour and working conditions, especially

requirements regarding overtime payment; • Non-discrimination; • Equal opportunity; • Equal remuneration for equal work; and • No child and forced labour. In addition, the Project should implement a contractor management plan which includes a mechanism to ensure that contractor workers are paid fairly (including any overtime) and on-time, have the right to join a union freely and that the company HR policy is adhered to.

Updated HR Policy PYTTP By Q4 2020


9. The Project should develop a Livelihood Restoration Plan (LRP) to provide employment and income generation opportunities to willing and qualified affected households, especially those considered poor and vulnerable

Preparation and Implementation of LRP

PYTTP Immediate TBD



Budget/Resources

10. The Project should accomplish all the commitment to the Cham ethnic group in relation to the transfer of graves and continuous engagement with them in a culturally appropriate manner as well as the provision of economically gainful opportunities to willing and qualified households of the Cham ethnic group.

Accomplished commitment and inclusion of Cham people in the LRP

PYTTP Immediate TBD


ANNEX A LIST OF INTERVIEWEES

File Name Vietnamese Document Name English Document Name

0. Meeting

1. ADB IBIS Documents Required (Updated 12 Dec 2019).xlsx

- -

2.DDR_Data_Phu Yen_ ENG 12102019_(updated).docx

- -

3. Working Agenda (updated 14 Dec 2019).xlsx

- -

4.Master list.xlsx - -

1. Detailed site layout

2. M?t b?ng tuy?n du?ng dƒy 220kV H•a H?i - ?p m¢ng.dwg

Mặt băng tuyên đường dây 220 kV Hoa Hội

Layout of Hoa Hoi 220 kV Transmission Line

BAN DO HOA HOI 500.dwg

Map of Hoa Hoi Commune (1/500)

b?n v? ranh gi?i c c th?a DWG.dwg

Ban ve ranh giơi các thưa đât Boundary of Land-plots

HH-GR-SP-RP-001-Topographic 2.dwg

12. Emergency plan fire safety plan\1. Emergency response plan

ph?n 1.pdf Phân 1 Section 1



Ph?n 4.pdf Phân 4 Section 4

Ph?n 5.pdf Phân 5 Section 5

Quy tr• nh x? lì s? c? nh… m y di?n.pdf

Quy trình quan ly sư cô nhà máy điện (tờ bìa và phê duyệt)

Incident management process for power plants (covers and approvals)

12. Emergency plan fire safety plan\2. Fire safety plan

fire safety plan.pdf Phương án PCCC Fire prevention and fighting plan

13. Permit to work system

Decision for Head operator.pdf QĐ bô nhiệm trương ca vân hành

Decision on appointed head operators

Head operator certifcate issued by A0.pdf

Chưng chi trường ca Head Operator Certificates

14. Stormwater management plant

Stormwarter management plant.doc

Phương án phong chông bao lut

Storm and Flooding Prevention Plan

15. health and safety management plan

15. health and safety management plan\O&M management plan



Quy tr• nh V?n h…nh T? b?ng m y c?t h?p b? 22kV.doc

Quy trình vân hành và bao dương cáp trung thê 22 kV Hoa Hội

Operation and Maintenance Process of 22 kV cables

Quy tr• nh V?n h…nh v… B?o du?ng Bi?n d•ng di?n 225kV.docx

Quy trình vân hành và bao dương biên dong 225 kV

Operation and Maintenance Process of Current Transformer 225 kV

Quy tr• nh V?n h…nh v… B?o du?ng Bi?n di?n p 225kV.doc

Quy trình vân hành và bao dương biên điện áp 225 kV

Operation and Maintenance Process of

Quy tr• nh V?n h…nh v… B?o du?ng c p trung th? 22kv h•a h?i.docx



Quy tr• nh V?n h…nh v… B?o du?ng HTD t? d—ng AC.docx

Quy trình bao dương hệ thông điện tư dung AC

Operation and Maintenance Process of self-electrical power system (AC)

Quy tr• nh V?n h…nh v… B?o du?ng HTD t? d—ng DC.docx

Quy trình bao dương hệ thông điện tư dung DC

Operation and Maintenance Process of self-electrical power system (DC)

Quy tr• nh V?n h…nh v… B?o du?ng MBA 225-22kV.docx

Quy trình vân hành và bao dương máy biên áp 225-22 kV

Operation and Maintenance Process of 225- 22 kV Transformers

Quy tr• nh V?n h…nh v… B?o du?ng M y c?t 225kV.docx

Quy trình vân hành và bao dương máy căt 225 kV

Operation and Maintenance Process of breaker machine 225 kV

Quy tr• nh v?n h…nh v… b?o du?ng t? RMU.docx

Quy trình vân hành và bao dương tu RMU

Operation and Maintenance Process of RMU electrical cabinets

Quy tr• nh V?n h…nh v… X? lì s? c? h? th?ng Siemens SCADA H•a H?i.docx

Quy trình vân hành và xư ly sư cô hệ thông Siemen SCADA Hoa Hội

Operation and Troubleshooting Process of Siemen SCADA System

15. health and safety management plan\safety management for Hoa Hoi factory plan

Quy tr• nh an to…n nh… m y.doc

Quy trình an toàn nhà máy Safety processes for power plants

18. Flood study

flood study.docx Báo cáo khi tương thuy văn cho Nhà máy điện mặt trời Hoa Hội

Meteorological and hydrological report for Hoa Hoi Solar Farm

21. Annual worker examination plan

quotation for annual.pdf Báo giá goi khám sưc khoe tông quát cho Công ty

Health check packages details Quotations for Company

3. Pre-feasibility study and feasibility study

3. Pre FS and FS\01. pre FS

Emailing 1523 - K?t qu? th?m d?nh hi?u ch?nh TKCS H•a H?i.pdf

Kêt qua thâm đinh hồ sơ TKCS dư án Nhà máy điện Hoa Hội

Appraisal Results of basic design documents of Hoa Hoi Solar Power Plant

Phan 1 - Q 1 1 - TM NCKT.pdf Phân 1 - Q11 - Thuyêt minh báo cáo NCKT

Section 1 - Part 11 - The explanatory part for the options



Phan 1 Q 1 2 - TMDT.pdf Phân 1 - Q12 - Tông mưc đâu tư

Section 1 - Part 12 - Total Investment Cost

Phan 2 - Q 2 1 - TM TKCS.pdf Phân 2 - Q21 - Thuyêt minh TKCS

Section 2 - Q 21 - The explanatory part for basic design

Phan 2 Q 2 3- Phu luc.pdf Phân 2 - Q23 - Phu luc Section 2 - Part 23 - Annexes

Phan 4 Ho so phap ly Hoa Hoi.pdf

Phân 4 - Hồ sơ pháp ly Hoa Hội

Section 4 - Legal Documents of Hoa Hoi Plant

3. Pre FS and FS\01. pre FS\P2 Q2.2 Ban ve Hoa Hoi - cad

Các ban ve cua dư án Drawings of Hoa Hoi Plant

3. Pre FS and FS\01. pre FS\P2 Q2.2 Ban ve Hoa Hoi - cad\I. Phan Ban do

Các ban ve cua dư án Drawings of Hoa Hoi Plant

Bandokhuvuc HH2.jpg Ban đồ khu vưc dư án HH2 Location Map of HH Commune

bandovitri HH.jpg Ban đồ vi tri HH Location of Hoa Hoi Plant

Bien che Ho so.pdf Danh muc hồ sơ List of Documents

Ph?n 2 ph?n 3 (µ Chƒu).rar Phân 2 (A Châu) - Tram biên áp và đường dây

Section 2 (ACIT) - Substation and Transmission Line

P1 T1-1 - TM NM.pdf Báo cáo thuyêt minh - Phân Nhà máy

Explanation for technical options of the plants

P1 T1-3 - PLTT NM.pdf Báo cáo thuyêt minh - Phân Nhà máy

Explanation for technical options of the plants

P1 T1-4 - CDKT NM.pdf Điêu kiện khi tương thuy văn Meteorological and hydrological conditions

P4 T4-3 BC KTTV.pdf Báo cáo khi tương thuy văn Meteorological and hydrological Report

P5 T5-1 VB PL 1.pdf Văn ban pháp luât Legal Documents

P5 T5-2 - Nang luc tu van NM.pdf

Năng lưc cua Tư vân Consultant's qualification

P6 - Thuyet minh PCCC.pdf Thuyêt minh phong cháy chưa cháy (PCCC)

Explanation for fire prevention and fighting options (PCCC)

32.42. Land

36. Summary-Land Compensation Payment.xlsx

Tông hơp chi tra bồi thường Summary of Compensation Payment

39. Confimation land approval.pdf

Châp thuân thuê dât Approval for lease land

40. land use right certificate.pdf Giây CNQSDĐ Land using right certificate (LURC)

32.42. Land\32.35 Land Clearance Procedure land Acquisition Process

1.PA-QD d?t 1.pdf Phương án và quyêt đinh bồi thường đơt 1

Compensation Plan and Compensation Decisions - Stage 1

2.PA - QD d?t 2.pdf Phương án và quyêt đinh bồi thường đơt 2

Compensation Plan and Compensation Decisions - Stage 2



3.1 Phuong n d?t 3.docx Phương án bồi thường đơt 3 Compensation Plan - Stage 3

3.1 Phuong n d?t 3.pdf Quyêt đinh bồi thường đơt 3 Compensation Decisions - Stage 3

3.2 Quy?t d?nh d?t 3.pdf Quyêt đinh bồi thường đơt 3 Compensation Decisions - Stage 3

4.1 Phuong n 4.pdf Phương án bồi thường đơt 4 Compensation Plan - Stage 4

4.2 QD d?t 4.pdf Quyêt đinh bồi thường đơt 4 Compensation Decisions - Stage 4

5.1 Phuong n 5.pdf Phương án bồi thường đơt 5 Compensation Plan - Stage 5

5.2 QD d?t 5.pdf Quyêt đinh bồi thường đơt 5 Compensation Decisions - Stage 5

FILE_20190904_104230_20190904(2).pdf

Hồ sơ bồi thường cua hộ Đô Minh

Compensation Document of Do Minh household

FILE_20190904_110545_20190904 (1).pdf

Hồ sơ bồi thường cua hộ Y Lành

Compensation Document of Y Lanh household

Gi?y nh?n ti?n v… cam doan gi?i ph¢ng m?t b?ng thi c“ng.pdf

Biên lai nhân tiên Compensation Receipts

tranmission line land.pdf Biên lai nhân tiên Compensation Receipts

4. EIA

EIA approval letters.pdf Quyêt đinh phê duyệt ĐTM EIA approval letters

EIA report.pdf Báo cáo ĐTM EIA Report

48. CSR program

CSR 2019 implementation.pptx Thưc hiện CSR năm 2019 CSR implementation in 2019

CSR Plan in 2020.xlsx Kê hoach CSR năm 2020 Implementation Plan in 2020

49. Training Documentation

1.00.????????PPT(SEPEC??).pptx

Tài liệu đào tao cua Nhà thâu EPC

Training Meterial of EPC

10. Working+Procedure+for+EP12HAZ+Inverter.docx

Tài liệu hương dân vân hành thiêt bi

Working Procedure for EP12HAZ Inverter

2.02Accessories Training-English&Chinese1.ppt

Tài liệu hương dân vân hành máy biên áp

Training Meterial for operation of transformers

3. 20190620_Hoa Hoi_TP-CS-Presentation- Khiem_r2.ppt

Tài liệu tâp huân vân hành thiêt bi

Training Meterial for operation of equipments

4. auxiliary system training.pptx

Tài liệu tâp huân vân hành thiêt bi phu trơ

Training Meterial for operation of auxiliary systems

5. MV transformer training.pptx Tài liệu tâp huân vân hành máy biên áp

Training Meterial for operation of transformers

6. RMU training.pptx Tài liệu tâp huân vân hành và bao dương tu điện

Training Meterial for operation and maintainance of electrical cabinets



7. SIMOPRIME A4 Training IDS_070305.ppt

Tài liệu tâp huân vân hành và bao dương tu điện

Training Meterial for operation and maintainance of electrical cabinets

8. SPPC_OperatorManual_Solar Hoa Hoi_Final.pdf

Tài liệu vân hành hệ thông SPPC

SPPC Operator Manual

9. TRAINING PPT.pptx Tài liệu đào tao cua Nhà thâu EPC

Training Documents of EPC

5. Environmental, Social and Legal

environmental requirement circular of TTPPY.doc

QĐ sô 1073/QĐ-UBND ngày 30/5/2017 cua UBND Tinh Phu Yên - Kê hoach thưc hiện Chi thi sô 25/CT-TTg ngày 31/8/2016 cua Thu tương Chinh phu vê một sô nhiệm vu, giai pháp câp bách vê bao vệ môi trường trên đia bàn tinh Phu Yên.

Decision No. 1073/QĐ-UBND dated 30 May 2017 - Implementation Plan to carry out the Direction No. 25/CT-TTg dated 31 August 206 of Primer Minister on on some urgent tasks and solutions on environmental protection in Phu Yen province

PY protect environment poclicy.doc

Kê hoach Bao vệ môi trường cua tinh Phu Yên năm 2019

Environmental Protection Plan of Phu Yen Province in 2019

53. Meteorology and Hydrography Report

HH-GR-SP-RP-003 Hydrological study report C.pdf

Báo cáo khao sát khi tương thuy văn

Report on Hydro-meteorological survey

55. Topography Report

HH-GR-SP-RP-001-Topographic(rev.b) (2).pdf

Báo cáo khao sát khi tương thuy văn

Report on Hydro-meteorological survey

56. Operator Permit

Operation permit 10 years.pdf Giây phep hoat động điện lưc 10 năm

Electricity operation license in 10 years

6. E&S Permit

EIA approval letters.pdf Phê duyệt báo cáo đánh giá tác động môi trường (ĐTM)

EIA approval letters

fire approval.pdf Nghiệm thu vê phong cháy, chưa cháy cua Nhà máy

Acceptance documents of fire prevention and fighting

61. Company Policy

Di?u l?_l?n 7.pdf Điêu lệ Công ty - ban hành lân 7

7th Company Regulations

62. Environmental Heath Safety related Policy

Fire and health safety plan.pdf Phương án đam bao an toàn PCCC, an toàn lao động và vệ sinh môi trường trong quá trình thi công

Implementation Plan to ensure the safety on fire prevention and fighting, labor safety and environmental protection during construction period

65.66. Certificated First Aiders Onsite

3.2 th? an to…n LD photo.pdf The an toàn lao động cua nhân viên

Safety cards of employees



67. Firefighting Equipment List

3. Apendix 24 fire system.pdf Phu luc 24 - Danh muc thiêt bi PCCC

Appendix 24 - List of FPF equipment

68. Firefighting Inspection Records

HH-SEPEC-FFSC-19-0001 Regarding to fire equipment failure affects power generation equipment.pdf

Báo cáo vê PCCC cua Nhà thâu

Contractor's Report on fire safety

70. Incident and Accident Report

Summary incident and accident report.xlsx

Tông hơp các sư cô lơn tai Nhà máy trong quá trình thi công

Summary Report on Incidents and Acidents during construction period

70. Incident and Accident Report\Reports

bao cao nhanh su vi?c cho don v? c“ng ty.doc

Báo cáo sư cô Incident report

BµO CµO NHANH S? C? MBA T2.docx


BµO CµO S? C? CHµY WB09.(Ng…y 22.11.2019).docx


BµO CµO S? C? MBA T2.docx Báo cáo sư cô Incident report

B o c o s? c? MC432A _ MC431A ng…y 7.9.2019.docx


B o c o s? c? MC432B ng…y 6.9.2019.docx


b o c o s? c? ng…y 18.07.2019..docx


B o c o s? c? ng…y 22.11.2019( Ch y WB09, INV2.2)..pdf


B o c o s? c? nh?y MC 431A v… 432A ngay 7_9_2019.doc


B?n tu?ng tr• nh s? vi?c n? c p 22kV.doc

Báo cáo giai trình sư cô Explanation Report on Incident

HHS_ Report incidents regarding CB05, WB19 burning.pdf


HHS_Incident Report dated 20191122.pdf


Influence of storm No.06 (Nakri) .pdf

Báo cáo vê anh hương cua cơn bao sô 6 (Narki)

Report on Influence of storm No.06 (Narki)

Malfunctions Report 18.07.19.docx


Malfunctions Report.docx Báo cáo sư cô Incident report

71 Human Resources Document

Labor contract.rar Hơp đồng lao động (file nen) Labor contracts (zip files)



72. Wage and Payrolls

Quy che tai chi tieu noi bo ban hanh L01.pdf

Quy chê chi tiêu nội bộ - Ban hành lân 1

Internal spending regualtions - 1st issuance

TTP - H? so dang kì thang b?ng luong.pdf

Hồ sơ đăng ky thang bâc lương

Registration records of salary levels

74. Local Employees

01. HDLD - Le Thi Ngoc Anh.pdf

Hơp đồng lao động Labour contract

02. HDLD - Nguyen Huu Thanh.pdf


03. HDLD - Cao Nhat Tan.pdf Hơp đồng lao động Labour contract

04. HDLD - Pham Ngoc Bia.pdf Hơp đồng lao động Labour contract

05. HDLD - Dang Truong An.pdf


06. HDLD - Nguyen Van Thuat.pdf


07. HDLD - Vo Cong Khoa.pdf Hơp đồng lao động Labour contract

08. HDLD - Doan Ngoc Thu.pdf


09. HDLD - Doan Dac Sang.pdf


10. HDLD - Nguyen Tien Chinh.pdf


11. HDLD - Lam Vu Linh.pdf Hơp đồng lao động Labour contract

12. HDLD - Vo Van Duc.pdf Hơp đồng lao động Labour contract

13. HDLD - Tran Hung Duong.pdf


15. HDCTV - Truong Nguyen Ha Trang.pdf


16. HDLD - Hoang Thi Thanh Hoa.pdf


17. HDLD - Luong Thi Hoa.pdf Hơp đồng lao động Labour contract

18. HDLD - Nguyen Anh Tuan.pdf


19. HDLD - Nguyen Manh Viet.pdf


20. HDLD - Nguyen The Hung.pdf


21. HDLD - Nguyen The Quy.pdf


22. HDLD - Nguyen Thi Mai Huong.pdf


23. HDLD - Pham Quang Thanh.pdf




24. HDLD - Pham Quoc Khanh.pdf


25. HDLD - Pham Thi Lan.pdf Hơp đồng lao động Labour contract

26. HDLD - Pham Thuy Dung.pdf


27. HDLD - Tran Anh Tu.pdf Hơp đồng lao động Labour contract

28. HDLD - Vu Tung Lam.pdf Hơp đồng lao động Labour contract

HDLD - Pham Minh Dai.pdf Hơp đồng lao động Labour contract

75. Recruitment and Retrenchment policies

Quy trinh nghi viec.pdf Quy trìình nghi việc Resignation procedure

Thoa uoc lao dong tap the TTP Phu Yen.pdf

Thoa ươc lao động tâp thê Collective labour agreement

TTP. Quy trinh tuyen dung-20191213T084557Z-001.zip

Quy trình tuyên dung Recruitment Procedure

76. Property Insurance

cover note.pdf Hồ sơ bao hiêm Insurance profile

endorsement 2.pdf Hồ sơ bao hiêm Insurance profile

endorsement.pdf Hồ sơ bao hiêm Insurance profile

policy schedue 2.pdf Hồ sơ bao hiêm Insurance profile

policy schedule.pdf Hồ sơ bao hiêm Insurance profile

Recuritment Porcedure Thu tuc tuyên dung nhân sư Recruitment Procedure

Grievance Mechanism Cơ chê giai quyêt khiêu nai Grievance Mechanism

Resignation Procedure

Resignation Procedure

TTP PY List of Employees Danh sách nhân sư cua TTPPY

TTP PY List of Employees

PECC2 List of Employees Danh sách nhân sư cua PECC2

PECC2 List of Employees

TTP PY Contract Example Mâu hơp đồng cua TTPPY TTPPY's contract form

11. QT_XLSC NMDMT H•a H?i.pdf

QT_PHVH MT HOA HOI.pdf Quy trình vân hành Nhà máy điện Mặt trời

Operational Manual

Quy tr• nh An to…n di?n.rar Quy trình an toàn điện (file nen)

Electrical safety procedures (zip file)

Quy tr• nh V?n h…nh T? b?ng m y c?t h?p b? 22kV.doc

Quy trình vân hành và bao dương máy căt 22kV


Quy tr• nh V?n h…nh v… B?o du?ng Bi?n d•ng di?n 225kV.docx

Quy trình vân hành và bao dương biên dong 225 kV

Operation and Maintenance Process of Current Transformer 225 kV

Quy tr• nh V?n h…nh v… B?o du?ng Bi?n di?n p 225kV.doc



Quy tr• nh V?n h…nh v… B?o du?ng c p trung th? 22kv h•a h?i (2).docx



Quy tr• nh V?n h…nh v… B?o du?ng c p trung th? 22kv h•a h?i.docx



Quy tr• nh V?n h…nh v… B?o du?ng HTD t? d—ng AC.docx

Quy trình bao dương hệ thông điện tư dung AC

Operation and Maintenance Process of self-electrical power system (AC)

Quy tr• nh V?n h…nh v… B?o du?ng HTD t? d—ng DC.docx

Quy trình bao dương hệ thông điện tư dung DC

Operation and Maintenance Process of self-electrical power system (DC)

Quy tr• nh V?n h…nh v… B?o du?ng MBA 225-22kV.docx

Quy trình vân hành và bao dương máy biên áp 225-22 kV

Operation and Maintenance Process of 225- 22 kV Transformers

Quy tr• nh V?n h…nh v… B?o du?ng M y c?t 225kV.docx

Quy trình vân hành và bao dương máy căt 225 kV


Quy tr• nh v?n h…nh v… b?o du?ng t? RMU.docx

Quy trình vân hành và bao dương tu RMU

Operation and Maintenance Process of RMU electrical cabinets

Other Documents

Electrical safety procedure _ Quy tr• nh An to…n di?n_ H•a H?i.docx

Quy trình An toàn điện Hoa Hội Electrical safety procedure - Hoa Hoi Plant

Quy tr• nh An to…n di?n_ H•a H?i.doc

Quy trình An toàn điện Hoa Hội Electrical safety procedure - Hoa Hoi Plant

Mau 01 BB khao sat hien truong.docx

Mâu Biên ban khao sát hiện trường

Form of Site Inspection Survey

Mau 02 Giay dang ky cong tac.docx

Giây đăng ky công tác Business registration form

Mau 03 Giay ban giao.docx Mâu Biên ban bàn giao Form of handing over minutes

Mau 04 Phieu cong tac.docx Mâu Phiêu công tác Form of Working Papers

Mau 05_Lenh _cong tac.docx Mâu Lệnh công tác Form of Working Orders

Phu luc 1 _Bac_an_toan_Dien.docx

Phu luc 1 - An toàn điện Annex 1 - Electrical Safety

Phu luc 10_Tai_lieu_tham_khao.docx

Phu luc 10 - Tài liệu tham khao Annex 10 - References

Phu luc 2_Huong_dan_cuu_chua_nguoi_bi_dien_giat.docx

Phu luc 2 - Hương dân cưu chưa người bi điện giât

Annex 2 - Guidance to rescue people with electric shock

Phu luc 3_Bien_bao_an_Toan_Dien.docx

Phu luc 3 - Biên báo an toàn điện

Annex 3 - Electrical safety signs

Phu luc 4 _Tai_lieu_tham_khao.docx


Phu luc 5_ Tai_lieu_tham_khao.docx






Phu luc 7_ Tai_lieu_tham_khao.docx






A.1. Hoa Hoi - EAR Policy - 27.11.18 - copy.pdf

A1. Hoa Hội - Chinh sách ERA A1. Hoa Hoi - ERA Policy

B. Hoa Hoi - Marine Cargo Policy - 27.11.18.pdf

B. Hoa Hội - Chinh sách vân tai thuy

B. Hoa Hoi Marine Cargo Policy

C. Hoa Hoi - PI Policy - 27.11.18.pdf

C. Hoa Hội - Chinh sách PI C. Hoa Hoi - PI Policy

D.1. Hoa Hoi - WCI Policy - 27.11.18.pdf

D1. Hoa Hội - Chinh sách WCI D1. Hoa Hoi - WCI Policy

ĐƯỜNG DÂN SINH 1.pdf Đường dân sinh 1 Residential road 1

ĐƯỜNG DÂN SINH PHÍA TÂY.pdf

Đường dân sinh phia Tây Western Residential roads

5、项目安全生产管理办法（安

健环实施措施）.pdf

- CEEC EPC Project Safety Production Management Requirements

QSEPEC 221006.02-2017 总

承包项目职业健康安全管理办

法.pdf

- CEEC EPC Corporate OHS Management Measures

QSEPEC 221006.04-2017 总

承包项目安健环管理计划编制

管理办法.pdf

- CEEC EPC Corporate OHS Management Plan Preparation Requirements

QSEPEC 221006.05-2017 安

全文明工地建设管理办法.pdf

- CEEC EPC Construction Site Management Requirements

QSEPEC 221006.09-2017 总

承包项目安健环例会管理办

法.pdf

- CEEC EPC EHS Meeting Requirements

QSEPEC 221006.11-2017 总

承包项目安全事故处理管理办

法.pdf

- CEEC EPC Accident and Incident Handling Procedure

QSEPEC 221006.14-2017 总

承包项目应急预案编制管理办

法.pdf

- CECC EPC ERP Preparation Requirements



QSEPEC 221006.18-2017 施

工机械、机具安全管理实施细

则.pdf

- CECC EPC Management Procedures for Machinaries and Tools

QSEPEC 221006.20-2017 现

场消防管理实施细则.pdf

- CECC EPC Firefighting Requirements for Construction Site

QSEPEC 221006.21-2017 手

持式电动工具管理实施细则.pdf

- CECC Corporate Portable Electrical Tool Management Requirements

QSEPEC 221006.24-2017 压

缩气瓶储存、使用管理实施细

则.pdf

- CEEC Corporate Compressed Vessel Management Requirements

QSEPEC 221006.25-2017 废

物处理管理实施细则.pdf

- CEEC Corporate Waste Management Requirements

QSEPEC 221006.26-2017 用

火作业管理实施细则.pdf

- CEEC Corporate Hot Work Requirements

QSEPEC 221006.28-2017 高

处作业管理实施细则.pdf

- CEEC Corporate Work-at-height Requirements

QSEPEC 221006.30-2017 有

限空间作业管理实施细则.pdf

- CEEC Corporate Confined Space Entry Requirements

《合规管理办法》培训记录

（富安项目）.pdf

- CEEC Compliance Management Training Record for Hoa Hoi Solar Farm

越南富安 257MWp光伏项目合

规性评价.docx

- Hoa Hoi 257 MW Solar Farm Compliance Assessment Register

越南富安项目部安全月报（6月

份）.xlsx

- Hoa Hoi Solar Farm Monthly Safety Report June


份）.xlsx

- Hoa Hoi Solar Farm Monthly Safety Report July


份）.xlsx

- Hoa Hoi Solar Farm Monthly Safety Report August


份）.xlsx

- Hoa Hoi Solar Farm Monthly Safety Report September

01.洒水合同.pdf - Water spray and road cleaning service contract

05.项目安健环管理计划--越南

富安华会 257MWp光伏项

目.pdf

- EPC HSE Management Plan



06.项目实施计划--越南富安华

会 257MWp光伏项目.pdf

- EPC Project Implementation Plan

HH-GR-PP-DW-002 Road Layout And Detail Drawing.pdf

- Approved Road Layout and Detailed Drawings

HH-GR-PP-DW-003 Drainage System Layout And Detail (2).pdf

- Approved Drainage System Layout and Detailed Drawings

List of Hazard Source Identified of Phu Yen Project Dept.pdf

- Hazard Identification Register prepared for the Project by EPC

The approved document of Construction.pdf

- Approved Building Construction Drawings

安保方案.pdf - Project Security Management Plan of EPC

应急处置预案.pdf - Emergency Response Plan of EPC

越南富安光伏项目施工组织设

计 .pdf

- EPC Organisational Chart

越南富安华会 257MWp光伏项

目风险管理计划.pdf

- Hoa Hoi Solar Farm Risk Management Plan

附件 1：越南富安华会

257MWp光伏电站项目风险识

别、评估、分析和应对措施

表.xls

- Hazard Identification Register and Mitigation Measures prepared by EPC for the construction of the Project

项目管理计划--越南富安华会

257MWp光伏项目（修订

版）.pdf

- Project Management Plan (Amended)

会议纪要（安全质量月度会

2019.02.02）.docx

- Meeting Minutes of the Monthly Safety Meeting in Feb 2019

关于召开 2019年 1月安全质量

月度会议的通知.docx

- Notice for the Monthly Safety Meeting in January 2019

会议纪要（安全月度会

2018.12.28）.docx

- Meeting Minutes of the Monthly Safety Meeting in December 2018

关于召开 2018年 12月安全月

度会议的通知.docx

- Notice for the Monthly Safety Meeting in December 2018

安徽电建一公司环境保护措

施.xlsx

- Subcontractor Environmental Protection Measures Register - Anhui I

越南富安光伏发电项目安委会

成立文件（安徽二）.docx

- Notice for the establishment of EPC HSE Department from Subcontractor Anhui II



越南富安安全〔2018〕2号

（关于成立越南富安光伏电厂

项目部安委会的通知）.pdf

- Subcontractor Environmental Protection Measures Register - Anhui I

春节前安全培训.pptx - Safety training material for the safety training prior to Chinese New Year


ANNEX B LIST OF INTERVIEWEES

5.1 SITE REPRESENTATIVES

1. Ms. Nguyen Kim Hai, CFO of PYTTP; 2. Ms. Hoang Thi Thanh Hoa, Deputy Head of Project Department of PYTTP; 3. Mr. Pham Quang Thang, Assistant to General Director of PYTTP; 4. Mr. Dang Truong An, Head of Operation of PYTTP; 5. Mr. Doan Ngoc Thu, Shift in-charge of PYTTP; 6. Mr. Duong Thanh Thang, Shift Lead of PECC2; 7. Mr. Nguyen Quoc Van, Deputy Head of PECC2; 8. Mr. Dan Manl Cuong, Electrician of Poyry Switzerland Ltd; 9. Mr. Nopparat Honghia, Engineer of BGrimm; 10. Mr. Thanarat Ratchapakdee, Plant Manager of BGrimm; 11. Mr. Li Ke Jie, Civil Engineer of CEEC; 12. Mr. Li Zhi Chao, Construction Manager of CEEC; 13. Mr. Ha Van Tan, Engineer of PECOM; 14. Mr. Nguyen Van Hoa, Security Personnel on-duty from Huy Hung Security Service

Limited; and 15. Ms. Nguyen Thi Kim Toan, Security Personnel on-duty from Huy Hung Security

Service Limited; and

5.2 GOVERNMENT AUTHORITY REPRESENTATIVES

16. Mr. Nguyen Van Thu, Head of Phu Hua District DoNRE


ANNEX C AERIAL IMAGERY OF THE PROJECT SITE

FIGURE C-0-1 GOOGLE EARTH IMAGERY OF THE SITE IN APRIL 2019 DURING THE CONSTRUCTION PHASE

FIGURE C-0-2 GOOGLE EARTH IMAGERY OF THE SITE IN MARCH 2019 DURING THE CONSTRUCTION PHASE


FIGURE C-0-3 GOOGLE EARTH IMAGERY OF THE SITE IN SEPTEMBER 2017 PRIOR TO CONSTRUCTION

FIGURE C-0-4 GOOGLE EARTH IMAGERY OF THE SITE IN FEBRUARY 2015 PRIOR TO ANY PROJECT ACTIVITIES


FIGURE C-0-5 GOOGLE EARTH IMAGERY OF THE SITE IN JANUARY 2010 PRIOR TO ANY PROJECT ACTIVITIES


ANNXE C PHOTOLOG

Within Hoa Hoi Solar Farm

PHOTO 1 OVERVIEW OF THE HOA HOI SOLAR FARM

PHOTO 2 OVERVIEW OF THE SUBSTATION OF THE PROJECT


PHOTO 3 AN EXTERIOR OVERVIEW OF THE ADMINISTRATIVE BUILDING

PHOTO 4 CONSTRUCTION SITE OF GATE A


PHOTO 5 CONSTRUCTION SITE OF THE O&M CONTRACTOR DORMITORY

PHOTO 6 A SECURITY POST ON-SITE SET UP IN THE DRAINAGE DITCH


PHOTO 7 FIREFIGHTING WATER STORAGE POND WITHIN THE PROJECT SITE

PHOTO 8 GROUNDWATER ABSTRACTION WELL OF THE PROJECT


PHOTO 9 FIRST AID BOX PROVIDED IN THE ADMINISTRATIVE BUILDING

PHOTO 10 A WELDING WORKER WITHOUT APPROPRIATE PPE


PHOTO 11 WORKERS PERFORMING WORK AT HEIGHT WITHOUT APPROPRIATE SCAFFOLDING

PROTECTION

PHOTO 12 AN EXAMPLE OF SOIL EROSION ON-SITE AND A SANDBAG PROVIDED FOR THE PREVENTION OF

SOIL EROSION


PHOTO 13 DRAINAGE DITCH INSTALLED ON-SITE SILTED WITH SOIL

Outside Phu Yen Solar Farm

PHOTO 14 TEMPORARY OFFICE BUILDING OF CEEC


PHOTO 15 CONSTRUCTION SITE ALONG THE NORTHERN BOUNDARY OF THE PROJECT SITE FOR THE

REPAIR OF DAMAGED DRAINAGE CULVERTS

PHOTO 16 CONSTRUCTION WASTES STORED AT THE CONSTRUCTION LAYDOWN AREA OF THE PROJECT


PHOTO 17 WASTE DUMP SITE MANAGED BY THE LOCAL COMMUNE GOVERNMENT (OUTSIDE THE

PROJECT)

PHOTO 18 A VIEW OF THE NEWLY ALLOCATED CHAM GRAVEYARD ALONG THE EASTERN BOUNDARY OF

THE PROJECT SITE


JOHANNESBURG 1st FLOOR, ACACIA BUILDING, THE AVENUE OFFICE PARK 45 HOMESTEAD ROAD, RIVONIA JOHANNESBURG, 2191 CAPE TOWN UNIT 1, DEVONSHIRE COURT 20 DEVONSHIRE ROAD CHELSEA VILLAGE CAPE TOWN, 7708 NAIROBI 5TH FLOOR, WESTERN HEIGHT KARUNA ROAD WESTLANDS NAIROBI, 00100 DURBAN 3 WIMBLE CLOSE BALLITO DURBAN, 4420 SINGAPORE 9 RAFFLES PLACE #26 -01 REPUBLIC PLAZA, SINGAPORE 048619 www.ibisconsulting.com

Environmental and Social Compliance Audit

Documents

Transcript of Environmental and Social Compliance Audit