ENVIRONMENTAL AND SOCIAL REVIEW SUMMARY (ESRS)
                            Navoi Scaling Solar
                            IFC Project #42525

                                               Disclaimer

This Environmental and Social Review Summary (ESRS) is prepared and distributed in advance
of the IFC Board of Directors' consideration of the proposed transaction. Its purpose is to enhance
the transparency of IFC's activities, and this document should not be construed as presuming the
outcome of the Board of Director's decision. Board dates are estimates only. Any documentation
which is attached to this ESRS has been prepared by the project sponsor and authorization has
been given for public release. IFC has reviewed this documentation and considers that it is of
adequate quality to be released to the public but does not endorse the content.

Project Description
The proposed comprises the development, design, financing, construction, ownership, operation and
maintenance of a 100MWac/130MWp solar photovoltaic (PV) plant in Navoi region of Uzbekistan (the
“Project”) under the Scaling Solar (“SS”) programmatic approach. “Nur Navoi Solar” Foreign Enterprise
LLC (the “Borrower” or the “Company”) has been established to implement the Project. The Project is
being developed by Abu Dhabi Future Energy Company PJSC (“Masdar”), a renewable energy and
sustainable urban development company wholly owned by Mubadala Investment Company PJSC
(“Mubadala”). The Project is also being supported by a US$5 million Guarantee from the International
Bank for Reconstruction and Development (“IBRD”). The Project is expected to be completed within 12
months under a turnkey EPC Contract, with construction activities commencing in Q3/Q4 2020. The EPC
contractor will also provide Operations & Maintenance (“O&M”) services for the first 2 years following
COD, subsequently to be replaced by an affiliate of Masdar. The plant is anticipated to be operational for
25 years.
The Project is located in the Navoi region, and the site is situated approximately 450 km southwest of
Tashkent, 35 km east of Navoi City 3.2 kilometers away from the small village of Uzumzor within a 268-
hectare plot of land. The proposed plant is a medium size utility grade grid-connected solar-PV power
system consisting of approximately 300,000 PV panels, string inverters, power conditioning units, 220 kV
step-up power transformers and grid connection equipment. Any interconnections to the grid will be
constructed within the proposed boundary of the site. The plant will feed power directly into the grid with
no batteries employed. Access to the site is via a short length of existing secondary road connecting to the
national highway (“M37”).
Two livestock farms are located in the northern and southern boundaries of the site. The closest identified
residential areas are the village of Uzumzor (~600 inhabitants), located approximately 2.6 km east from the
boundary of the site, and a small village-sized cluster (~100 inhabitants) of residential properties
approximately 2.2 km south.
IFC has existing investments with Masdar (200 MW solar Baynouna Masdar Jordan #39339, disclosed in
2017 and 158MW Dolovo Wind Serbia #33839, disclosed in 2014) which are both currently under
supervision. The Company’s environmental and social (“E&S”) performance to date has been satisfactory.



                                                     1
The Project is expected to employ approximately 140 workers at the construction start, 900 workers during
peak construction and up to 117 workers at the end of construction; during operation, there is expected to
be 22 workers in site working in shifts. The EPC site management team is expected around 30 individuals
across the construction period.

Identified Applicable Performance Standards
While all Performance Standards are applicable to this investment, IFCs environmental and social due
diligence indicates that the investment will have impacts which must be managed in a manner consistent
with the following Performance Standards.
PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 – Labor and Working Conditions
PS 3 – Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity and Sustainable Management of Living Natural Resources


Based on IFC’s review of the project PS7: Indigenous People is not applicable as there are no indigenous
peoples in the project area; and PS8: Cultural Heritage is not applicable as the project is not located in the
area of known historical or cultural significance and does not impact any known cultural heritage. However,
the project will develop a chance finds procedure in case of the identification of cultural/archeological
resources in the area.
If IFCs investment proceeds, IFC will periodically review the project’s ongoing compliance with the
Performance Standards

Overview of IFC’s scope of review
As a result of the travel restrictions arising from the COVID-19 pandemic, appraisal of the company and
the project was conducted through a desktop and virtual appraisal (conducted via a series of video / phone
conferences). The appraisal was conducted on the 7th July 2020 and consisted of a desktop review of
available information, including an Environmental Social Due Diligence (ESDD) Report developed during
the IFC Scaling Solar Uzbekistan advisory Project, the preliminary ESIA for the project, the Company’s
Stakeholder Engagement Plan, the ESDD developed by the Lender’s Technical Advisor (LTA) following
a 2-day site visit as well as the company’s responses to a series of ESHS questionnaires. IFC’s appraisal
focused on the company’s capacity to manage ESHS risks and compliance with the Uzbek regulatory
requirements and IFC’s Performance Standards and WBG’s EHS Guidelines. Specific items reviewed
included: (i) the company’s and contractor’s capacity to manage ESHS risks of the project; (ii) HR policies
and procedures especially on working conditions, terms of employment; (iii) construction related
occupational health and safety for its staff, contractors and any primary labor supply chain issues associated
with migrant and/or seasonal workers i.e. forced and child labor; (iv) water resource availability; (v)
community health and safety and security; (vi) ensuring previous land users are provided adequate alternate
land; (vii) early engagement with surrounding communities and other stakeholders.


It should be noted that a local representative of the LTA did carry out a site visit, on the Lender’s behalf,
to verify site conditions. The company’s ESIA consultant also participated in the virtual appraisal and
provided an update related to the ESIA and stakeholder engagement activities.

                                                      2
Environmental and Social Categorization and rationale
This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability as the
E&S impacts associated with the project are limited, generally project-specific and can be addressed
through the implementation of good international industry practices. Further, it is possible to design and
implement engineering and management measures to mitigate adverse impacts during construction and
operation. The environmental and social risks are rated as moderate (as per IBRD classification) and for
those that have been identified, the client’s E&S management system and the agreed E&S Action Plan
(ESAP) provides appropriate mitigation.
PS1 - Assessment and Management of Environmental and Social Risks and Impacts

Environmental and Social Policy and Management System

At a corporate level, the company has developed a QHSE Policy which outlines their commitment to
quality, the prevention of injury, ill-health, limiting pollution of the environment and to complying with
applicable statutory and regulatory requirements at all times. At a project level, the company, as a part of
their ESHS management systems, will develop a project level ESHS policy building upon their corporate
level policy, defining their ESHS objectives and principles aligned with applicable laws and regulations
and consistent with the objectives of the IFC Performance Standards (IFC PSs). This policy will indicate
who within the company will be responsible for its implementation. The company will communicate the
policy to all project employees and will require their contractors to develop their own ESHS policy aligned
to this policy.

At a corporate level, the company has developed a QHSE Management System (MS), detailed within a
QHSE MS Manual, which is aligned with the general requirements of ISO14001, ISO 9001 and ISO 45001.
The company is yet to establish mechanisms to align project level and corporate level management systems.

As per ESAP 2, the company will develop and implement an Environmental and Social Management
System (ESMS) in accordance with the general requirements of PS1 and in line with the objectives of
ISO14001 (certification is not required) specific for this project. The company’s ESMS will detail
processes to be implemented to provide adequate management & supervision of their contractors including
the engagement of a Project Management Consultant (PMC).

The ESMS will outline process developed by the company to identify environmental and social risks and
impacts and detail the specific measures to be implemented to manage these. Company will require its EPC
and O&M contractors to develop an ESMS needed to identify, manage and control risks related to their
activities and that of their sub-contractors.

Identification of Risks & Impacts

During the inception phase of the project i.e. Scaling Solar advisory Project, IFC commissioned a ‘Site
Suitability Report’ and an ‘Environmental and Social Scoping Report’ with the aim to provide project



                                                     3
bidders with a basic understanding of environmental and social conditions in the project area and ensure
the general suitability of the site.

Following project award, the company developed a preliminary Environmental & Social Impact
Assessment (ESIA) report in accordance with good international practice. The purpose of the preliminary
ESIA was to conduct an initial assessment of impacts based on existing information, supplemented with
additional surveys. The preliminary ESIA also identifies the type and extent of further studies required. As
per ESAP 1, a full ESIA will be further developed, prior to construction and as a condition of disbursement,
following the same structure but will also include an assessment of residual impacts. Further site surveys
will be carried out when circumstances allow as part of the full ESIA. The full ESIA, mitigation protocols
and Environmental & Social Management & Monitoring Plan’ (ESMMP) will be prepared following the
completion of additional studies.

In addition to the above, the project is required to develop an EIA in accordance with national legislation
and seek regulatory approval prior to commencement of construction activities.
The company has engaged a local consultancy to assist in the development of the national level EIA
documents. To date a Stage I – Concept Statement of Environmental Impact has been completed in
accordance with local requirements which has been submitted to the regulators.

Management Programs

As mentioned above, the project’s ESIA will include the development of an ESMMP, which will provide
a summary of the E&S management framework, monitoring requirements and mitigation measures
applicable to the construction and operation phases of the project. As per ESAP 3 and ESAP 4, the company
will develop a Construction Environmental and Social Management Plan (CESMP) and an Operation
Environmental and Social Management Plan (OESMP). The CESMP and the OESMP will be based upon
the ESMMP and will be reviewed and approved by the Project Lenders prior to use.

The CESMP will consist of a suite of sub-plans, which will include but not be limited to: waste
management; pollution prevention (including emissions, erosion, spill response etc.); water management
(including supply, treatment, disposal etc.); hazardous materials; biodiversity management (including fauna
/ flora, topsoil, ground disturbance, invasive species etc.); emergency preparedness & response; community
health, safety & security; road safety & traffic management; accommodation management; local
recruitment & labor management; influx management; cultural heritage (including chance finds);
environmental monitoring plan; stakeholder engagement (including grievance management) and contractor
management plan.

The OESMP will consist of a suite of sub-plans, which will include but not be limited to: waste
management; pollution prevention (including emissions, erosion, spill response etc.); water management;
hazardous materials; emergency preparedness & response; community health, safety & security;
biodiversity management; environmental monitoring plan and stakeholder engagement (including
grievance management).



                                                     4
The company shall require their contractors to develop, implement and maintain their own ESMPs and
associated procedures aligned with project requirements and their scope of work. These documents will be
reviewed and approved by the LTA and / or Project Lenders prior to use.

Construction and operations phase E&S management and monitoring responsibilities will be shared
between the company and its contractors. Both the EPC and O&M contractors will be contractually bound
to adhere to the requirements to which they are assigned as the responsible party in the ESMPs.

As per ESAP 5, the company will develop, and shall require their EPC & O&M contractors to develop, an
OHS Management System aligned (but not necessarily accredited) with OHSAS18001 / ISO 45001 and
elements of an ESMS to identify, assess, manage and control risks.

As part of the OHS Management system, the company will develop an over-arching Project OHS
Management Plan (ESAP 6) outlining the project’s health & safety management framework and setting
OHS minimum project requirements / standards, taking into the consideration potential COVID-19 related
infection risk to the work force.

The company will require its EPC & O&M contractors to develop a series of plans, procedures and systems
to adequately manage occupational health & safety risks associated with their scopes of work. The
contractors shall establish a comprehensive risk identification and management process & permit to work
system.

The EPC and O&M Contract is a key tool for ensuring compliance with the ESHS requirements of the
company. As per ESAP 7, the company will develop and include ESHS and labor provisions (including
complying with IFC PS) and compliance conditions in its EPC and O&M contracts which will provide
contractors and third part service providers (including security agencies) with clear guidelines on
performance requirements.

Organizational Capacity & Competency

The company has at a corporate level a QHSE and CSR Manager which will have oversight of EHS issues
on the Project. The company has demonstrated capabilities to manage a range of environmental, social and
occupational health and safety issues at other renewable energy projects in which the IFC has provided
funding.

The company’s project manager shall have overall responsibility for environmental, health, safety, social
& security management for the project. The company will develop a project level board which will include
ESHS representation and ESHS reporting requirements. The project board will provide a means for ESHS
aspects to be raised and escalated as appropriate to senior management. A mechanism to link the project
level board and the corporate level board should also be established.

The company will appoint qualified professionals to be responsible for the environment, health and safety
and social aspects of the project. The company will engage a PMC to provide additional support and project
supervision including ESHS oversight.

As per ESAP 8, the company will appoint, at a site level, a suitably qualified stakeholder liaison manager,
and through the PMC, suitably qualified project E&S and OHS manager as well as human resource

                                                    5
management support. At a corporate level, the client will appoint qualified E&S and OHS representative
to be the lenders focal point throughout the duration of the construction & operational phases of the project.

The appointed individuals will have adequate qualifications & experience including the knowledge of
international requirements & best practice. These individuals must have sufficient authority and resources
to fulfil their responsibilities as required by the Project ESMS and the SEP, Lender requirements, the ESAP
and local regulation.

As per ESAP 9, the company will require their PMC, EPC and O&M Contractors (including their sub-
contractors) to appoint a suitably qualified environmental, labor and OHS team to manage their scope of
work. These individuals must be aware of, and fully understand, the obligations and responsibilities placed
upon them by the Project ESMS.

Emergency Preparedness & Response

The Company and their contractors will develop an Emergency Preparedness and Response Plan (EPRP)
in accordance with IFC PS1 & PS4.

These plans will cover preparedness and responses to a range of potential emergency scenarios, including
but not limited to medical emergencies (including pandemic type outbreaks), fire, earthquakes, extreme
weather conditions, transport incidents & major hydrocarbon spills. Security related incidents, act of
sabotage/vandalism, terrorism etc. will be addressed with a separate Security Management Plan (ESAP 21).
The response plans will include a communication protocol to alert local authorities and communities as
appropriate and the management team in addition to specific responses and evacuation procedures.

Regular drills and emergency exercises will be conducted by the EPC & O&M Contractor covering the
different emergency scenarios.

Monitoring & Review

The company will be responsible for reviewing and formally auditing their contractors with regards to their
ESHS performance and compliance against project standards, national requirements and Lender guidelines.
As part of its management system, the company will establish procedures and allocate resources to monitor
and measure the effectiveness of their and their contractor’s management plans / programs and compliance
with relevant Uzbek legal requirements.

E&S / OHS monitoring requirements of the EPC & O&M contractors for their own activities and that of
their subcontractors will be defined within their management plans and their implementation will be closely
followed by the company.

The EPC and O&M contractors will provide as a minimum, monthly E&S / OHS reports as part of the
general reporting on the project. This report will include coverage of the contractor’s E&S / OHS
performance in accordance with reporting requirements outlined within the project ESIA & ESMPs. Clear
key performance indicators (KPIs) will be developed as part of the reporting.

                                                      6
The company will appoint an independent auditor to undertake review of the effectiveness of CESMP and
OESMP quarterly during construction phase, and annually in the first three years of power plant operation
as noted in the ESAP item 10.

PS2 – Labor & Working Conditions

The project is expected to employ approximately 140 workers at the construction start, 900 workers during
peak construction and up to 117 workers at the end of construction; during operation, there is expected to
be 22 workers in site working in shifts. The EPC site management team is expected to be around 30
individuals across the construction period.

The number and gender of local & national workers that are predicted to be employed is yet to be fully
established by the company although it is likely that approximately 400 technicians and low-skilled
personnel will be required. Potentially these workers could be sourced either locally or nationally
dependent on skill sets available.

Human Resources Policies and Procedures

At a corporate level the company has an existing Code of Conduct (Mubadala Code of Conduct) which sets
principles related to core company values and ethics. These principles will be implemented throughout
project execution.

The company will develop a Human Resources (HR) Policy and plans / procedures that are project specific
and in line with IFC’s PS2, International Labor Organization (ILO) and with national labor laws. The HR
Policy will contain an enforceable code of conduct applicable to all workers. As per ESAP Action Item 11,
the HR policy must include commitments to (i) Non-discrimination, equal rights and equal pay; (ii)
Prevention of child labor and forced labor; (iii) Freedom of association and right to collective bargaining;
(iv) Terms of employment including hours of work, overtime arrangements and overtime Compensation,
rights to refuse overtime requests; (v) Commitment to apply zero tolerance for any proven case of gender
based sexual or physical violence and workplace harassment.

This policy will be provided to all employees in their language(s). Induction training on the HR policy will
be provided to all newly hired workers.

The company will develop an additional Code of Conduct for site security personnel which will be in line
with the requirements of PS2, PS4 and the Voluntary Principles of Security & Human Rights. Further
detail concerning security is provided within the section covering PS4.

As described within PS1, the company will develop and implement a contractor management plan which
will outline mechanisms to monitor and enforce contractors’, sub-contractors’ and service providers
(including private security agencies) compliance with labor policy & human resource requirements.

Non-Discrimination & Equal Opportunity

The company is committed to avoid all forms of discrimination against its employees, based on the age,
gender, sexual orientation, health, race, nationality, political opinions or religious beliefs of its



                                                     7
counterparties. The requirements of non-discrimination and equal opportunities will be extended to all
contractors and subcontractors as part of contractual obligations.
Recruitment
As per ESAP 12, the company will supplement existing, publicly available, local workforce statistical data,
by undertaking further stakeholder engagement to determine likely local & regional workforce
availability, gender & skill levels to guide workforce planning.

As a consequence of local restrictions on face to face meetings, due to the current COVID-19 pandemic, it
will not be possible to undertake a detailed, house by house social survey to determine likely local and
regional workforce availability and skill levels. The company will engage with local communities leaders
(including, but not limited to the Deputy Khokim of Navoi region, Deputy Head of Investment Department
of Navoi Region Khokimiyat, a senior member of the local Women's Committee, and the Chairman of the
mahalla committee Malik {Uzumzor is part of the Mahalla Malik}) to establish an adequate workforce
profile. The company will discuss the skills required and will provide draft job specifications during the
engagement. All necessary measures to appropriately manage community expectations will be taken.


The engagement detailed above will assist the client to prepare a Local Recruitment & Employment Plan
(LEP) which outlines their recruitment strategy and processes, including promotion of equal opportunities.
The LEP will describe how women and Project Affected People (PAPs) will be preferentially selected,
alongside other residents from the two most affected communities, for recruitment and training in advance
of the start of construction activities. This LEP should include an analysis of local workforce skills against
required worker profiles and numbers, engagement with regional vocational training centers that could be
used (potentially with the support and technical assistance of the project) to provide vocational training,
and employment targets for women. The company will commit to maximizing the inclusion of women in
the workforce as much as reasonably practicable and will investigate different options, such as working
with local NGOs etc. to assist in achieving this aim. Roles and responsibilities associated with local
recruitment between the company and their appointed contractor(s) should be clearly defined.

The project’s recruitment strategy will include a tiered approach in which recruitment campaigns will focus
on recruiting suitably skilled employees / sub contactors from within project affected communities as a
priority. Should suitable individuals not be available within this area, the recruitment campaign will expand
to the local region and subsequently other regions of Uzbekistan should suitable employees / sub contactors
not be available. The employment of international workers will be seen as the last option.

The company will ensure that their contractors develop LEPs aligned with the requirements outlined within
their LEP.

Working Conditions and Terms of Employment

As per ESAP 13, the company will ensure that all employee contracts are consistent with local labor codes,
ILO and IFC PS2 requirements.

All employees shall be provided a copy of their contracts (in a language they understand) and these shall
stipulate the terms of employment, such as working conditions (including health & safety requirements)
wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick
leave, maternity and paternity leave, vacation and holiday etc.

                                                      8
All construction phase worker contracts shall clearly describe the short-term nature of the project and
provide an indication of likely employment duration.

The company will ensure that their contractors provide all workers, including sub-contractor workers, with
written documentation concerning the terms and conditions of their employment as per the above. This
requirement will extend to any personal engaged via labor hire companies.
The company will ensure all workers have contracts and background checks including references from most
recent employers.
Workers Grievance Mechanism

As per ESAP 14, the company will develop a confidential grievance reporting, referral and support system
for workers. This worker’s grievance mechanism (WGM) shall be consistent with local labor codes and
IFC PS2 requirements.

The WGM process shall involve an appropriate level of management (including designated staff and
accountability, and the establishment of an appeals panel) to address concerns promptly and an
understandable and transparent process that provides timely feedback to those concerned, without any
retribution. The WGM is to include specific considerations related to the harassment/gender-based violence
grievances.

The company will provide specific training to grievance officers and general awareness to employees on
harassment and bullying, engagement with women employees on their concerns regarding transportation
and safety.

The company will ensure their WGM is available to their contractors, sub-contractors and service provider’s
etc. personal as required. The PMC will be given responsibility for the operation and management of the
WGM during the construction phase of the project. It is anticipated that the PMC will identify a named
individual who will take the lead, but this individual will be supported by a panel who will consider any
appeals. Final arbitration will sit with the Company’s Project Management. During operations, the O&M
contractor will establish and operate a WGM aligned with company’s WGM (including necessary training
and awareness programs).

The existence and availability of the WGM shall be clearly communicated to all employees via. their
employment contracts, HR plans and through the site induction process.

Workers Accommodation

The company is yet to decide the accommodation arrangements for project workers, with two options
currently being considered: (i) Development of a workers camp potentially located adjacent to the project
area; or (ii) Accommodated in nearby hotels and / or guesthouses.

The ESIA currently under development will include an assessment of likely risks & impacts associated with
worker accommodation and will propose necessary mitigation measures.

As per ESAP 15, the company and the EPC contractor will prepare an Accommodation Management Plan
in line with “Worker’s accommodation: Process and Standards” Guidance note by IFC and EBRD. The



                                                    9
management plan will incorporate social risks & impacts posed to nearby communities by project workers,
including required mitigation measures.

Consideration of the need for workers’ accommodation must take account of the COVID-19 pandemic and
the potential impact of the construction workforce on the local communities. The company & contractors
management plans must assess the health risks to the workforce and put appropriate measures in place to
protect the workforce and the local communities.

Safety audits shall be conducted to identify settings affected by the project that might increase the risk of
GBVH. For example, consideration whether adequate measures have been put in place to manage
interaction points with communities such as truck stops.
Every effort shall be taken to provide safe, secure and separate living spaces for male and female
construction workers, including adequate lighting and segregated wash facilities

Workers Organizations

It is unlikely that workers’ unions will be involved in the project as the main concentration of workers will
be on site during a short-lived construction period only; as noted above, the operations staff will be small.
The company will not in any way prevent workers from seeking to join unions or other workers’
organizations; this will be specified in the labor policy and procedures.

Child and Forced Labor

No child or forced labor will be used by the project at any time. Proof of identification and age will be
required at the time of employment. The company will ensure appropriate contractual provisions are
included with their contractors / suppliers to ensure this requirement is cascaded throughout the project.

Workers Occupational Health & Safety

Key occupational health and safety (OHS) risks for a PV project include slips and falls, potential hazards
from on-site moving machinery, heavy load lifting, traffic accidents, exposure to electric shocks and burns,
and safety issues related to PV module assembly.

As mentioned under PS1, the company will develop and shall require their EPC & O&M contractors to
develop, an OHS MS aligned with OHSAS18001 / ISO 45001. The OHS MS will include project specific
OHS plans / procedures for the construction and operations phases. These procedures will cover, but not
be limited to, the following issues: hazard identification and assessment; the construction site safety
(barricades, safety nets, control of the access, clear demarcation of areas and provision of safety information
to visitors, etc.); specific procedures for hazardous works; worker’s safety and training plan; personnel
qualification, limitations and equipment needs (e.g. personal protective equipment); site supervision and
audit procedures; incident reporting system and intervention measures (first aid etc.). The procedure will
be designed to be specific to the PV solar sector (in terms of industry-specific hazards) and the project site.
The OHS procedure will also link into the project-specific Emergency Preparedness and Response
Procedures (EPRP) which will include fire risk assessment and control systems, fire alarm systems and
drills, emergency preparedness and planning, as part of OHS Procedures for both the construction and
operation phases.




                                                      10
The company in coordination with its contractors, will develop and implement a training program for the
project. As per ESAP 16, the EPC & O&M contractors shall develop and implement an ‘Training Needs
Analysis’ and ‘Training & Competency Plan’ to ensure that all workers are appropriately trained, skilled,
licensed / permitted & competent to undertake all tasks required of them within their role.

Supply Chain

As per ESAP 17, the company will develop a ‘E&S Supplier & Vendor Management Plan’ which outline
processes to be implemented to identify, manage, and monitor environmental, social, health & safety, risks
and track performance of project key suppliers and vendors.

The process will include initial screening & due diligence exercises of key potential suppliers & vendors
with a focus on OHS performance, licensing / permitting, human resource risks (child labor and forced
labor) and an assessment of gender and safety risks in bidding process for contractors.


PS3 – Resource Efficiency & Pollution Prevention

Resource Efficiency – Greenhouse Gases
Greenhouse gas emissions from the project during the construction are expected to be predominantly
associated with the use of fuels such as in generators, transport, on-site equipment, and machinery.
Although the quantities of emissions have not been calculated, these are expected to be low and significantly
less than 25,000 tones CO2 equivalent (tCO2eq/year).

The project is expected to generate approximately 270 gigawatt hours (GWh) of electricity per year,
resulting in a predicated annual GHG reduction of 142,000 tCO2eq/year.

Resource Efficiency – Water Consumption & Availability
The company is yet to fully quantify water consumption requirements for the project.

Water required for construction has been estimated as 3,600m 3 excluding accommodation requirements and
10,658m3 including accommodation requirements. The main water requirement during construction is
likely to be water for dust suppression, concrete production and domestic use. It is yet to be determined
whether concrete batching activities will be conducted on site or in Navoi, although initial calculations have
assumed 0.2 m3 of water for every 1 m3 of concrete will be required. Construction phase water consumption
requirements will be accurately quantified by the company when a decision is made concerning concrete
batching arrangements & worker accommodation requirements.

Water requirements during operation and maintenance will be largely focused on panel cleaning. The
company has stated that due to high levels of ambient dust the project design has considered wet cleaning
of the PV modules as their base case. The company has estimated that this requirement would be
approximately 4,620 m3 per annum. The company will consider the contextual risk of water scarcity in the
region as a guiding principle for selecting a water efficient cleaning technology option. The company will
refine the cleaning regime during operations to avoid unnecessary cleaning and use of water.




                                                     11
The company is currently assessing different water supply options available to the project including
groundwater abstraction, tapping into an existing water pipeline in close proximity to the project and
trucking in water from Samarkand. It was noted during stakeholder engagement sessions held with local
communities that water scarcity / availability is a primary concern of the local population. The company
stated during the project virtual appraisal exercise that it is mostly likely that water will be sourced from
Samarkand and trucked to site. If this is to occur, it is estimated that the water demand would be equivalent
to one truck per every two days.

As per ESAP 18, the company will conduct an Alternatives Analysis for water use taking into account
environmental, social and technical considerations and subsequently develop a Water Management Plan
which will quantify water requirements for the construction (including non-potable water to be used for
mixing concrete and dust control) and operational phases of the project and assess potential impact on
availability of water resources to local communities (including farmers & herders).

If ground water is planned to be used, the company shall first undertake a hydrological study to determine
the availability and suitability of groundwater for construction water and for panel washing during
operation. Groundwater shall not be used for potable water unless subject to appropriate treatment.

The company will obtain all required permits / licenses / permissions related to water abstraction,
consumption and treatment etc.

Pollution Prevention – Waste

The overall volumes of both solid and hazardous waste generated by the project during both construction
and operation are expected to be low. The company is yet to develop a comprehensive estimation of their
anticipated waste streams & volumes for the project or undertake an evaluation of waste treatment &
disposal options.

It is anticipated that the project will produce both non-hazardous wastes, such as paper, wood, plastic, scrap
metals and glass and a limited quantity of potentially hazardous materials such as transformer oils, paints,
batteries, etc. and other electronic waste.

As per ESAP 18, the company and its contractors will develop a Waste Management Plan for the project
aligned with local legal requirements, IFC PS3 and WBG EHS general guidelines. The waste management
plan will commit to the reduction of wastes to the extent possible whilst maximizing the re-use and
recycling of materials and will outline process for appropriate waste storage, segregation, transportation
and disposal / treatment.

The company will develop a waste inventory and will undertake an assessment of disposal & treatment
facilities / options. Project waste will only be disposed of and treated at appropriately licensed facilities.
The company will adhere to Principles of “duty-of-care” in waste management.
An assessment of the suitability of each licensed disposal facility will be undertaken prior to use to ensure
project waste is disposed / treated in such a manner that is safe for human health and the environment.



                                                     12
Pollution Prevention – Hazardous Materials

Hazardous materials likely to be required during construction & operation phase of the project include
hydrocarbons, oils, lubricants and paints. The company and its contractors will establish and implement a
hazardous material management plan and spill prevention and repose plan that are commensurate with the
potential risk present. These management plans will address the protection of workforce and the prevention
and control of the releases and accidents.

A limited number of waste PV modules are expected to require disposal during the construction phase, and
they will be returned to the PV manufacturer for recycling.

Pollution Prevention

During construction, a minor and insignificant amount of pollution to air, noise, water and soil is anticipated
that can be easily mitigated through standard pollution prevention and control measures which will be
outlined in the respective environmental management plans. During the operational phase, no
environmental pollution impacts are anticipated with the exception of wastewater, primarily from panel
cleaning, and regular household waste generation. The company will require its EPC contractor / O&M
operator to implement pollution prevention measures in accordance with national law, IFC’s Performance
Standards, the ESIA prepared for the project, and the ESAP for the project agreed between the company
and the IFC.

PS4 – Community Health, Safety & Security

Before the start of construction, the company will assess risks and impacts to host communities of the
project, such as the influx of workers. Based on the findings, the company and its contractors will develop
a series of Community Health and Safety plans and procedures to protect public health, safety and security
on issues that include: road safety and traffic management; potential emergencies and required responses;
security measures to prevent unauthorized access during construction; measures to prevent sexual
harassment, gender-based violence, and the sexual exploitation of children; and measures to prevent the
spread of disease including COVID-19 and HIV/AIDS.

As per ESAP 20, the company will inform local stakeholders about the construction program and any
potential associated hazards including expected increases in traffic around the site. The company must
actively consult with local stakeholders and authorities regarding the numbers of workers that will be on
site during the construction period, the potential for employment, worker accommodation, and worker
welfare and health. The company must also listen and respond to any concerns raised by local stakeholders
or authorities relating to COVID-19 and the potential impact on the health of the local community and the
capacity of local medical services.

As described under PS 2, the company will maintain a ’Code of Conduct for employees’, that will be
applicable to all employees, contractors and subcontractors. It will include references to non-discrimination,
sexual harassment and gender-based violence, and rules for interaction with the local population.




                                                      13
Road Safety & Traffic Management

The project is yet to fully quantify required traffic movements for the project. This information will be
contained with the ESIA being developed.

The company has indicated that it is likely that solar panels required by the project will be transported by
rail to the nearest rail head and trucked approximately 30 km to site.

As described within PS1, the company / contractor will develop and implement a project specific Road
Safety & Traffic Management Plan (RSTMP) which will outline traffic management and accident
prevention measures, including needed infrastructure, signage, training, to mitigate any impact on local
communities. The RSTMP will define road transport routes to be used by the project, including routes to
be used during equipment deliveries. The transport routes will be based on risk assessments undertaken to
evaluate road conditions and to minimize impacts to local communities.

Community Exposure to Disease

As described within PS1, the company / contractor will develop a ‘Community Health & Safety
Management Plan’ (CHSMP) which will include necessary mitigation measures to minimize the potential
for community exposure to water-borne, water-based, water-related, and vector-borne diseases, and
communicable diseases that could result from project activities. The CHSMP will avoid or minimize
transmission of communicable diseases that may be associated with the influx of temporary project labor.

The company and its contractors will implement stringent measures to manage risks related to COVID-19
and will ensure that adequate plans & procedures are developed to minimize, as much reasonably possible,
its transmission. The project’s workers accommodation planning will be developed considering these risks.

Community Emergency Preparedness & Response

As described within PS1, the company and its contractors will develop an emergency preparedness &
response plan (EPRP) for the construction & operational phase of the project.

The EPRP will outline the projects emergency preparedness and response activities, resources, and
responsibilities, and will disclose appropriate information to affected communities, relevant government
agencies, or other relevant parties as appropriate. The EPRP will define engagement processes and ensure
that local communities are informed of any emergency situation which may impact them.

Security Personnel

The entire perimeter of the project site will be fenced and entry to the project site will be regulated. In case
the project will benefit from public security support in ensuring safety of the workforce and construction
sites the client will assess and document risks arising from the project’s use of government security
personnel. The client will seek to ensure that security personnel will act in a manner consistent with the
PS4 and encourage the relevant public authorities to disclose the security arrangements for the client’s
facilities to the public, subject to overriding security concerns.

As per ESAP 21, if the project will additionally employ private security contractor, the company will
develop an additional Code of Conduct for site security personnel which will be in line with the
requirements of PS2, PS4 and the Voluntary Principles of Security & Human Rights and which will requests
that public security adhere to the same standards when working with the company and supporting its

                                                      14
security personnel. The company will ensure that their security contractors personal are appropriately
screened, trained and competent for their scope of work. Security personal will be made aware that the use
of force is explicitly forbidden, and the security guards must not carry arms of any kind (including batons).
Both the company and the Government security agency agree to notify each other immediately and in
writing if they suspect the other has committed a breach of human rights or the laws of the Uzbekistan.


PS5 - Land Acquisition and Involuntary Resettlement

The PV Plant will occupy approximately 268 hectares (2.6 km2) of land, which is government land. The
site of the PV Pant overlaps with land that was previously leased out to two tenants, using the land as
grazing land. In 2018, the tenants were informed by the government of the planned change in land use,
and subsequently surrendered their lease contracts and have no remaining claims under national law. One
tenant has almost half the land area left in his lease contract, while the other tenant surrendered almost all
the land of the lease contract. No physical displacement has occurred, and no complaints have been
registered from the leaseholders. One person is still using the land for grazing of animals.
Following PS5, restoration of livelihood losses for the two tenants is the responsibility of the government
and will be offered by the Regional Administration (Khokimiyiat) in the form of alternative land for lease
to the previous leaseholders and current land user, prior to the fencing off of the site. While the actual
current user of the land may not be a formal leaseholder, he should also be provided with alternative land
for lease (in his own name), since he will likely be experiencing adverse livelihood impact due to the
project.

As per ESAP 22, as the project site is pre-existing government land, and the change of lease contracts
entails only economic resettlement (i.e. livelihood impact) of two land users, the client will identify and
describe the measures that the responsible government agency plans to use to compensate affected persons.
If these measures do not meet the relevant requirements of IFC’s PS5, the client will develop an
Environmental and Social Action Plan to complement government action. This may include additional
compensation for lost assets, and additional efforts to restore lost livelihoods where applicable.

Other land impact of the project comprises the restrictions of access to a footpath crossing the project site
once the fencing is installed. According to the ESIA report, cutting off this footpath will have no economic
impact nor imply any legal aspects – but only impact on time spent on small-scale local mobility between
the connected locations.

The final ESIA will include a section on resettlement that will act as an abbreviated Resettlement Plan
Framework (RPF) to meet the World Bank requirements. This section should basically include a “Social
Audit” of the site and surroundings as well as clear explanation of the land compensation and livelihood
restoration undertaken for the Project.



PS6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources

The PV Plant will occupy approximately 268 hectares (2.6 km2) of land and will be enclosed by a 2.5-
meter-high fence. The land is currently used for rough grazing of livestock and is generally flat with few
features of interest. Previous attempts to cultivate arable crops were noted but a combination of poor soil


                                                      15
quality and lack of water made this unviable. The region is semi-arid, and the site is predominantly covered
by scrub grassland. Although the site is grazed by domestic animals, it is largely Natural Habitat, although
localized areas within the northern and eastern boundary of the site have been modified by historic
cultivation. Therefore, Natural Habitat requirements of PS6 apply to the Project.

The Project site is located close to the eastern edge of the Central Asian Southern Desert Ecoregion, with
the Alai-Western Tian Shan steppe Ecoregion beginning to the east of Navoi. Both ecoregions are
characterized by desert vegetation, which varies according to soil type. The Project is not located within an
internationally recognized areas or Protected Area. The nearest Key Biodiversity Area (KBA) is the
Tudakul and Kumazar Reservoirs Important Bird Area (IBA) located 20 km to the southwest of the project
site, which includes the Tudakul lake which is saline, and the Kuyu-Mazar freshwater reservoir.

Botanical surveys were completed in March 2020, which confirmed that the site largely supports
wormwood steppe. This relatively sparse vegetation community is dominated by wormwood species
(Artemisia spp.), frequent Isirik (Peganum harmala), frequent grasses (eg. Poa spp.) and occasional thistles
(Asteraceae). Although the site is grazed by domestic animals, it is largely Natural Habitat, although
localized areas within the northern and eastern boundary of the site have been modified by historic
cultivation. Therefore, Natural Habitat requirements of PS6 apply to the Project. During March 2020, a
single IUCN Endangered bird species, Steppe Eagle ( Aquila nipalensis) was observed migrating northwards
over the site. The Emirate Centre for the Conservation of the Houbara (ECCH) at the Uzbekistan (ECCH)
was consulted regarding Asian Houbara (Chlamydotis macqueenii), who confirmed that there is potential
for this species to occur, although it was not observed during surveys completed during March and June
2020. There are no wetlands within the Project site that might attract congregations of water birds. The only
other threatened species confirmed on-site is the IUCN Vulnerable Central Asian Tortoise ( Testudo
horsfieldii). As per ESAP 23, the company will complete additional flora and fauna surveys confirm the
extent and condition of Natural Habitat and the presence of invasive alien species within the Project site
(including construction camps, access roads and other areas impacted by the Project).

The Preliminary ESIA provides a short list of ‘likely’ biodiversity-related mitigation measures (e.g. pre-
construction survey, relocation of fauna, prohibition of hunting), as well as operational phase monitoring
of bird collisions with solar panels and overhead lines. As specified in ESAP 24, the company will develop
a construction-phase Biodiversity Management Plan (BMP) that will be designed to achieve no net loss of
Natural Habitat and associated threatened species (including the Central Asian Tortoise), with appropriate
mitigation measures to preserve the integrity of topsoil and existing natural vegetation on-site and
restoration natural vegetation in areas disturbed during construction.

As per ESAP 25 the company will develop an operational-phase BMP that includes long-term management
of Natural Habitat on-site and control of invasive alien species. The BMP will also include a biodiversity
monitoring plan for the operational phase, including monitoring of bird and tortoise fatalities and to
demonstrate no net loss of Natural Habitats.

 As per ESAP 26, if the company installs any new, or makes modifications to, existing overhead
transmission lines, they will install and maintain bird flight deflectors for the life of the project.



                                                     16
Stakeholder Engagement
Stakeholder engagement activities undertaken for the project thus far have consisted of the official first
round of stakeholder engagement activities (from an E&S perspective) which took place in Navoi (city)
and in Uzumzor on the 5th and 6th of March 2019. This engagement was undertaken by a technical
consultant retained by the IFC to provide advisory services during the IFC’s Uzbekistan Scaling Solar
project including the development of an Environmental & Social Scoping Study.

Further stakeholder engagement took place between the 2nd of 7th of March 2020 as part of the Preliminary
ESIA. This engagement was undertaken by the company’s engaged ESIA consultant.

This engagement consisted of a series of face to face meetings with a range of stakeholders including:
    -   Affected stakeholders (including land users – Farm A & B)
    -   Institutional Based Stakeholders (public agencies concerned with any of the project activities)
    -   Interest Based Stakeholders (which included national and international non-governmental
        organizations (NGOs) and others civil society organisations).

It was reported by the consultants during both rounds of engagement that ‘Farm B Land Users’ are ‘content
with the development, but they are concerned about obtaining alternative land from the Administration’.
During the visit in June, 22-25, Farmer A was contacted and met with Company consultants. He explained
that he is currently not using the land, he has another business (cattle and meet reseller). He has 30 goats
and Farmer B is currently taking care of his cattle. Further engagement activities with both Farmer are
currently envisioned as part of the completion of the project ESIA and, as required during later phases of
the project. Company understood that the Administration will be concluding the process of land
compensation by August 2020.

A Stakeholder Engagement Plan (SEP) has been developed by the project. The SEP sets out the process
for undertaking engagement and consultation with stakeholders including defining roles & responsibilities,
outlining regulatory policy framework, establish processes for stakeholder identification and analysis,
stakeholder engagement programs, information management and provides a grievance mechanism.

This SEP is a ‘live’ document, which will be periodically revised by the company in course of the project
lifecycle, when required. The current version covers engagement activities to be undertaken during the
development of the national Environmental Impact Assessment (EIA) and international Environmental and
Social Impact Assessment (ESIA) processes.

As described under PS1, subsequent to the delivery of the ESIA, the company will update and further revise
the SEP prior to commencement of the construction phase. The SEP will be fully aligned with the IFC
requirements. Due to the COVID-19 restrictions on face to face meetings, the SEP should also be in
compliance with the World Bank’s Technical Note: Public Consultations and Stakeholder Engagement in
WB-supported operations when there are constraints on conducting public meetings, dated March 20, 2020.




                                                    17
It should be noted that stakeholder engagement is to be understood as continuous process and it will be
maintained by company through the entire life cycle of the project or until the company transfers the
ownership of the project to a different party once the PPA expires. Stakeholder engagement responsibilities
will not be transferred to contractors (EPC or O&M).

Community Grievance Mechanism (CGM)

An external grievance mechanism has been developed within the existing Stakeholder Engagement Plan.
As per ESAP 20, the company will ensure that the existing grievance mechanism is updated as required
and adequate tools & resources are allocated to ensure that it is fully implemented prior to commencing
construction activities.

The CGM will be aligned with IFC PS1 and be robust, accessible, and anonymous for all nature of
complaints that may come in from the community. The CGM will be able receive and address complaints
of sexual harassment or gender-based violence between employees/contractors and members of the
community. This will include a mechanism that ensures confidentiality and, where possible, effective
referrals to support services or the provision of support services. The grievance mechanism must identify
specific response methods for any complaints involving the sexual exploitation of or sexual violence against
children.

Local Access of Project Documentation:

Mr. Elbek Gafforov
Deputy Head of Investment Department
Navoi region Khokimiyat,
Tel. +998 99 750 17 11,
gafforovelbek@gmail.com
Address: 77A Islam Karimov Street, Navoi city, Navoi region. Zip code: 210100

http://navoi.uz/




                                                    18