Executive Summary of the ESMFS

Transcription

1 Annex 4. Environmental and Social Management Framework and System (ESMFS) of the Kazakhstan Renewable Energy Framework Executive Summary of the ESMFS Kazakhstan is the largest emitter of greenhouse gases (GHG) in Central Asia. This is a combined result of high energy intensity, relatively high economic output, and a coal-dominated energy sector, with approximately 80 per cent of Kazakhstan s electricity generated by coal. The energy sector accounts for approximately 85 per cent of anthropogenic GHG emissions in Kazakhstan. GHG emissions from energy activities occur mostly in the form of CO 2 (90.9 per cent), with CH 4 making up most of the rest. Scaling up renewable energy will help Kazakhstan meet its climate change mitigation and GHG emission reduction commitments as well as diversify energy production and diminish dependence from fossil fuel. Kazakhstan has launched an ambitious programme to change its energy mix and to foster the development of renewable energy. The GCF-EBRD Kazakhstan Renewable Energy Framework (the Framework) is designed to support Kazakhstan to achieve its goals via scaling up renewable energy investments, by blending EBRD and GCF financing and leveraging additional debt financing from international financial institutions and in the future from commercial banks, as well as private sector, and via supportive regulatory reform, enhancing renewable energy integration, policies and planning through a comprehensive technical assistance programme. The Framework will focus on the financing of solar, wind, biogas and small hydro projects to be developed under the current Feed-in-Tariff (FiT) programme. In 2014, EBRD carried out the Strategic Environmental Review (SER) to assess and help mitigate potential environmental and social impacts of RES projects in Kazakhstan. The purpose of the SER process was to review the key environmental issues associated with the implementation of specific renewable energy development on a national basis. When individual projects are considered for financing under the Facility, a project-level environmental review will be required. SER findings demonstrate that the dominant majority of likely negative significant effects of the Facility s renewable energy projects can be mitigated. This mitigation will be conducted by a combination of siting constraints (avoidance and minimization); design, construction, and operational practices designed to minimize effects (minimization); and establishing practices to replace lost function and value (mitigation). EBRD has adopted a comprehensive Environmental and Social Sustainability Framework (ESSF) consisting of an Environmental and Social Policy (ESP) and a set of environmental and social Performance Requirements. The ESSF is aligned with other IFIs, such as the IFC and Equator Banks and the Green Climate Fund. EBRD also maintains Environmental and Social Procedures, which outline the process by which Bank staff process and monitor projects in accordance with the overall ESP framework. In accordance with EBRD s ESSF, all subprojects in this Framework will undergo environmental and social appraisal both to help EBRD decide if the project should be financed and, if so, the way in which environmental and social risks and impacts should be addressed in its planning, implementation and operation. The appraisal process also identifies opportunities for additional

2 environmental or social benefits. All EBRD financed projects are required to be structured to meet the EBRD s Environmental and Social Performance Requirements. EBRD seeks with its ESSF and environmental and social appraisal and monitoring processes that projects are designed, implemented, and operated in compliance with applicable regulatory requirements and good international practice. EBRD anticipates that all solar projects under the Framework will be Category B and the wind, hydropower, and potentially biogas projects will be a combination of Category A and B. On the basis of this each subproject will be individually reviewed and categorised and due diligence will be undertaken accordingly. Under GCF s Comprehensive Information Disclosure Policy of the Fund this Framework would be categorised according to the anticipated risk profile of the individual subprojects proposed under the Framework. With this in mind this Framework will, overall, be considered Category A. This ESMFS sets out: The rationale for the proposed GCF-EBRD Framework, including a description of the programme and the proposed approach. Typical environmental and social issues associated with the Framework and the details on best practice for mitigation of such issues; as well as summary of stakeholder engagement process. The E&S context of the Framework is also provided. EBRD s E&S Policies and procedures, including the Performance Requirements and the key steps for subproject appraisals. EBRD s stakeholder engagement requirements and subproject redress or grievance mechanism.

3 Background and Description Background Kazakhstan generates 80% of its electricity from coal. In fact, since 2006, the level of GHG emissions has increased by 40% due to the economy s overdependence on fossil fuels. According to the UNFCCC, Kazakhstan emitted 338 million tonnes CO 2 equivalent (tco2e) in 2012, of which 76% is generated by the energy sector. Kazakhstan has been a member of the UNFCCC since 1995 and has pledged to voluntarily reduce its GHG emissions by 7% by 2020 (compared to 1990 levels). The share of renewables in total electricity production in Kazakhstan in 2016 was less than 1% with the total installed capacity being 252 MW. Even though the country is richly endowed with renewable energy sources, the majority of the country s power generation comes from coal-fired power plants and the rest from gas and oil. There are currently five small hydropower plants that make up most of the non-fossil fuel share of energy supply. The Government has so far set a target to increase its renewable energy supply to 3% by 2020, but competing with cheap and abundant carbon-intensive energy sources continues to be greatly challenging for private project developers. Kazakhstan s economic development has led it to rapid rise in energy demand, resulting in increasing shortage of energy supply. With most of the country s power generation capacity concentrated in the north, the southern region of the country suffers from power deficiency. Recognizing the need for diversification of energy sources, the Government of Kazakhstan launched a strategic initiative called the Transition to a Green Economy under which a number of actions have been planned including the development of renewable energy sources (RES). This was further supported during the most recent UNFCCC Conference of Parties in Paris as was communicated by the Kazakh Government in its Intended Nationally Determined Contribution (INDC) to reduce greenhouse gas emissions. Kazakhstan s INDC calls for an economy-wide target of a minimum of 15% reduction in greenhouse gas emissions by 2030 compared to 1990 reflecting reduction of at least 22% below projected business as usual emissions. The Kazakh Government has set an indicative target of increasing RES generation volume from existing 1% to 3% in the total energy mix to be reached by The current renewable energy policy framework which is intended to support the achievement of this goal was introduced in Kazakhstan, with the support of the EBRD technical assistance, in June 2013 and offers support to renewable projects through fixed feed-in tariffs differentiated by technology. Due to the introduction of this RES support mechanism, Kazakhstan s RES market sees continued growth of the overall generation volume coming from wind, solar and small hydropower plants. Power generated from these sources increased by 56% in Q1/16 as compared to Q1/15, though in absolute terms it continues to remain insignificant at less than 1% of overall power generation. EBRD proposes to scale up investment in RES in Kazakhstan by establishing the Kazakhstan Renewables Framework with support from the GCF. Framework Description Building on EBRD s experience in implementing the Ukraine Sustainable Energy Lending Facility, the already signed investments in Kazakhstan such as the 50MW Burnoye SPP; and the 8 years of EBRD experience in working with the Government of Kazakhstan on renewable energy legislation, the EBRD proposes to the GCF to implement an investment framework operation of 5 years duration, which is expected to lead to EUR 477 million in investment including private sector investors, donor

4 co-financing from other donors, and EBRD s contribution, to provide loans to RES developers to finance the construction, connection to the grid, commissioning and launch of RES projects (solar, wind, small hydropower and biogas). The Framework will be supported by a donor co-financed regulatory reform support program. The benefit of the Framework for Kazakhstan is to kick-start the market of independent developers of RES projects, accelerating the move towards sustainability of the RES market by creating a large pool of projects and project sponsor interest; and increasing the international integration of RES market development and enabling carbon market access, thus ensuring longer term sustainability. It will also facilitate achievement of the target on the share of renewable power generation at a country level (3% of total generation by 2020), and substitute carbon intensive power generation in the north by reducing the power deficit in the southern regions of Kazakhstan. The Framework will contribute considerably to Kazakhstan s climate mitigation efforts. Kazakhstan is a country with very high emissions of CO2 from power generation, and the renewable energy financed by the Framework will therefore have a substantial impact on Kazakhstan s emissions, by adding clean energy into the mix. Based on the experience with the current portfolio, the expected direct CO2 emissions reductions by new and additional RES generation are about 0.6 million tons CO2 equivalent per year once all projects are operational, with an estimated lifetime of 20 years. Framework Objectives The main objectives of the Framework are: to facilitate competitive entry of low carbon investors into a market currently dominated by higher-carbon traditional power generation competitors; to kick-start the renewable energy sources sector development in Kazakhstan by facilitating investments in RES projects in the scale of EUR 477 million including donor co-financing over the next 5 years; to support further regulatory reforms required to fully implement new legislation and address other market barriers; to support the construction of at least 330 MW of new and additional RES capacity; to contribute at least 18% of the government s RES target by 2020; to support financing of power network modernisation including smart grid projects that are needed in certain areas in order to remove technical/technological barriers that hinder the higher penetration of renewables in the grid and to reduce network losses; and to provide support to RES clients to promote equal opportunities policies and practices within their operations to enhance women s representation in high-value technical positions in the energy sector through, inter alia, vocational technical training for young women. The Framework will be supported by a technical assistance (TA) program aiming to further unlock the renewable energy market potential in Kazakhstan. TA projects will mainly focus on the investment side, and only add technical assistance above project level in line with clearly identified needs and requests from the relevant authorities. Specific areas of regulatory reform have already been identified in consultation with Kazakh authorities and other donors and these will help to conduct systemic change in the sector, achieve critical mass of private RES projects, and enable high-level development of RES.

5 Overall, the Framework will catalyse the development of a competitive, efficient renewable energy market that will allow Kazakhstan to achieve its renewable energy and GHGs emission reduction targets, while increasing the share of privately owned generation capacity. The Framework will assist with the reduction of Kazakhstan s carbon intensity; additionally, projects under the Framework will address barriers to women s participation in the high-growth, future-oriented renewables and electrical sectors by strengthening women s access to skills and employment. Strategic Environmental review (SER) In 2014, EBRD, in close co-operation with the national authorities in Kazakhstan, commissioned a Strategic Environmental Review (SER) focusing on renewable energy development in Kazakhstan. In identifying the types of renewable energy resources and technologies to be assessed through the SER, projects that fall within the scope of assessment were defined as those that are technically and economically viable. Factors considered include: Small and medium size; Primary energy production must be electricity, rather than as thermal energy (space heating, hot water, etc.); Projects should be qualified for the feed-in tariff FIT that guarantees revenue stream to support the project; More likely to use available technologies with proven performance records in commercial application; and Projects are owned or primarily owned by private companies. The purpose of the SER process was to review the key environmental issues associated with the implementation of specific renewable energy development on a national basis. When individual projects are considered for financing under the Facility, a project-level environmental review will be required. SER findings demonstrate that the dominant majority of likely negative significant effects of the Facility s renewable energy projects can be mitigated. This mitigation will be conducted by a combination of siting constraints (avoidance and minimization); design, construction, and operational practices designed to minimize effects (minimization); and establishing practices to replace lost function and value (mitigation). For minor adverse effects, mitigation strategies have been developed to eliminate or minimize the effect. For the wind, SSH and solar PV renewable energy projects, there remain a small number of potential significant negative environmental impacts; specifically for effects upon landscape (wind) and cultural heritage (wind, SSH, and solar PV). The reason for the anticipated significant negative impact on landscape for the wind scenario is largely due to the fact that the scale is considerably larger in terms of footprint and height. Therefore the viewshed of wind farms is also larger and more far-reaching. There is uncertain performance of the projects in avoiding adverse effects on cultural heritage sites due to the likelihood presence of presently unknown cultural finds, resulting in possible significant negative performance for all projects, except biogas. Therefore, effects on cultural heritage sites would need to be determined at the project level. Positive performance is expected for climate receptors due to ability of renewable energy scenarios to avoid adverse effect on this receptor. In addition, projects will potentially have several positive performances for community & socioeconomics and material assets. The biogas projects offers high positive performance, particularly for

6 climate and human health, largely because this scenario requires capping existing landfills site to capture emitted gas from the landfill; therefore, a significant reduction of GHG gas as well as improvement in the surrounding environment is anticipated. An additional benefit of capping these landfills is a general local improvement in sanitation and odours. Details of most potentially significant environmental impacts per environmental receptors are summarized below. It is important to note that the specific characteristics of projects funded under the Facility may vary from the overall compliance of scenarios identified in SER and will require more detailed appraisal through project level environmental assessments. This will be required by the Facility as well as Kazakhstan regulations concerning EIA. Recommendations on the scope of the project level assessments are included in the SER report. Overall, SER resulted in: Assessment instruments for specific investment projects and their appraisal and permitting. This has two components: the first one is an annotated list of areas/locations most suitable for development of mini-hydro, wind, solar, biogas and geothermal facilities (to provide an indication for future development). The second one is a recommendation for a focused environmental and social due diligence process for individual projects which takes account of the findings and recommendations of the SER and the requirements of the Bank s Environmental and Social Policy and associated Performance Requirements, as well as the type of specific project-oriented environmental studies that should be conducted for review of a renewable energy project to be in compliance with the IFI requirements. Identification and (where possible, determined in consultation with the Bank) quantification of environmental, social or technical obstacles to be encountered or benefits arising when developing the indicated facilities. Capacity building for consultants and developers in environmental and social compliance with the Bank Environmental, Social, and Public Information Policy; and for regulators in SEA procedures and processes. The outcomes of the SER help to focus the scope and provide relevant guidance for subsequent environmental reviews of renewable energy projects within Kazakhstan. A subsequent project-level environmental review conducted for each specific project proposal will use the information in the SER report to identify mitigation strategies and adapt them for implementation at the project level. Environmental and Social Context Kazakhstan faces serious problems of air pollution, particularly in it s the cities. Other environmental issues in Kazakhstan include soil pollution from the overuse of pesticides in agriculture, increasingly polluted waters of the Caspian Sea; desertification; and overgrazing. The Framework components directly respond to the environmental and social challenges of the country. RES development will help decrease air emissions, promote sustainable land use planning, and improve employment choices in less developed regions of Kazakhstan. Likely significant impacts on the Environment of RES Sub-Projects Each subproject to be considered under the EBRD-GCF Framework will be subject to full project and sponsor-specific environmental and social due diligence with the support of an independent

7 consultant. EBRD anticipates that all solar projects under the Framework will have an E&S categorisation of B and the wind project, small hydropower projects and, possibly, biogas projects will be a combination of Category A and B. As a result each subproject will be individually reviewed and categorised and due diligence will be undertaken accordingly. Under GCF s Comprehensive Information Disclosure Policy of the Fund it is understood that the Framework would be categorised according to the anticipated risk profile of the individual subprojects. With this in mind it has been agreed with GCF that this Framework will overall be considered Category A. Under the SER study, likely significant impacts on the environment by RES technologies were identified and are summarized below. Air quality During the construction phase of all types of the RES projects, there may be an impact on local air quality from construction vehicle exhaust and dust generation; however, these effects will be localised and temporary and could be mitigated by implementing best practice for construction such as dust control. Projects utilising biogas from municipal landfills will have a positive impact on the climate during operation. It is assumed that the landfill already emits methane during operation, so changes in air quality are not anticipated. The landfill combustion plants being considered by Facility are much smaller than large fossil fuel fired plants and emission effects, which will occur during normal operations, are therefore expected to be permanent, but local in nature. (Average emission for existing stationary sources was 6.0 ton / unit in 2012.) Surface water and groundwater Two types of effects on this topic can be expected based on the Facility renewable energy projects: degradation of surface water quality and change in availability of surface water resources. For each of the projects, there are common effects on surface water quality due to the footprint of development, erosion runoff and sedimentation during construction and operation. In addition, small scale hydro may affect flow patterns, river dynamics and river morphology from construction through operation. The Facility wind, solar and hydropower projects have potential for significant environmental effects on surface water quality receptors should they be located in proximity to these. There would be reversible and temporal impact on surface water from run-off of precipitation or excess construction related flows over disturbed soils on roads, construction of lay down areas, turbine foundation areas, transmission lines and ancillary facilities. Such effects are likely to be significant during construction and decommissioning, but temporal and contained locally. During operation, the effect on surface water is much smaller than in construction stage and therefore not significant. The effects of the Facility solar photovoltaic projects upon surface water and, due to the larger uptake of land required for solar potentially are more significant as it may be harder to avoid surface water when developing larger sites. The Facility small scale hydropower projects have potential for significant effects on surface water receptors and surface water quality during operation, when surface water resources and quality both upstream and downstream are potentially impacted by small scale hydropower systems that alter surface water flow, however the extent of the effect is dependent on the type of small scale hydropower facility used: a water storage or run-of-river system.

8 The effect of the Facility biogas projects upon surface water is similar to those of the wind and solar photovoltaic projects, although the effect of these projects would have an impact on groundwater from leachate seepage during the operation stage. Geology and soils Three types of effects on geology and soils can be expected based on the Facility renewable energy projects: loss of high value soils, change in soil characteristics, and increased potential of occurrence of mudflow hazard. For each of the projects, there are common effects on the general soil characteristics due to the change in soil properties caused by project activities such as land alternation, compaction from construction through decommissioning. Where they are present, high value soils may be affected by the construction activities for each of the projects except biogas. Small scale hydro may also affect mudflow hazard areas in areas where they may contribute to the failure of dams and reservoirs. Solar photovoltaic projects presents effects of higher magnitude than for the other renewable projects, through the removal of high value soils from agricultural productivity if sited in areas of high value soils; the need to continually wash the photovoltaic panels during operations presents the potential for additional effects from wash water and chemicals percolating into the soils and affecting its structure and condition. For biogas projects, combustion of municipal landfill gas presents an additional risk of potential acidification from deposition of air pollutant emissions (i.e. SO2, NOx and CO2), which has potential for significant effects. Landscape and biodiversity For all of the projects there are number of potential common effects on landscape and biodiversity that must be considered prior to selection of sites and projects. These common potential effects are: Habitat loss, fragmentation and or simplification associated with the development footprint of the renewable power development and consequentially potential adverse effects on protected species that utilise those habitats; Potential increase in bird and bat mortality, due to an increased risk of collision/electrocution where new wind turbines and ancillary power lines are located within bird migration corridors or bird and bat foraging areas. The adverse effect of new above ground structures associated with power generation devices, power houses and ancillary developments such a new linear new power lines and access roads on landscape character, setting and visual amenity. Such adverse effects may be exacerbated if viewed from elevated locations or if structures are sited on ridgelines. Such effects may be reduced if obscured by intervening features such as variations in landform, existing buildings or trees/forest; Land take from wind farm arrays has the potential to lead to significant environmental effects due to habitat loss. Wind farm development within or adjacent to protected wetland sites has the potential to adversely affect important wetland and associated terrestrial habitats that provide support to nationally and international (Ramsar) important populations of migratory birds, including those along the Western Asia Africa and the Central Asia India flyways. In addition to the effects of habitat loss, the siting of wind turbines within or adjacent to habitats which provide important nesting, roosting or feeding sites for bird and bat populations may increase the risk of direct mortality through bird and bat strike; either through collision with the turbine blades or new connecting transmission lines. Birds of prey, passerines and other endemic species of bird are also vulnerable to similar affects associated

9 with habitat loss and risk of turbine strike within in-country migration routes. The most significant effects are likely in areas of particular importance for bat populations in southern Kazakhstan. Wind farm development in steppe zones has the potential to reduce available habitat within the range of herding species such as the Saiga antelope. Broader scale habitat loss within the steppe zone in northern Kazakhstan will also potentially affect other wide ranging protected species. However, habitat areas can still be used by terrestrial species because of the spacing of wind turbines within an array and the very limited land take for each turbine. If forested areas essential for important terrestrial species are converted to open terrain, there might be a significant negative effect. The introduction of wind farms will have significant negative effects on both landscape character and visual amenity. Individual turbines, 100m in height, will be visible up to a distance of 30 km, with potential effects on bordering countries. While the extent of the effect will depend on the sensitivity of the landscape character, wind farms will generally be out of character for most landscapes. In landscapes where there are intervening features (built, landform or forest) views may be reduced, however in flat, steppe/arable landscapes they will be particularly noticeable. Protected and high quality landscapes and their setting may be particularly vulnerable to these effects. Land take from solar photovoltaic arrays has the potential to lead to significant environmental effects due to habitat loss. Developments within or adjacent to protected areas has the potential to adversely affect important habitats in protected areas. Shading may contribute to changes in the microclimate and may change vegetation patterns. Land take also has the potential to lead to the direct loss of forest, grassland and savannah habitats and associated reduction in ecosystem function, leading to direct loss of habitat for important terrestrial species. Additional above ground transmission infrastructure would lead to a reduction in bird and bat species. The introduction of photovoltaic arrays and ancillary development over a wide area will affect landscape character by replacing existing scenic landscape with areas of dark panels which will register as expansive unnatural features. However, solar developments would most likely be low lying; therefore, the effect on visual amenity will be most apparent when viewed from an elevated positions or close locations. The effects on protected and high quality landscapes and their setting can be expected to be negative and significant. Protected and high quality landscapes and their setting may be particularly vulnerable to these effects. The damming of water courses may affect water-dependent protected areas due to either reduced availability of water, modification of the flooding regime or permanent flooding and inundation of protected areas upstream of the dam. The clearance of vegetation and construction works for additional access to hydropower development may also lead to direct footprint losses within or adjacent to protected. Outside of the protected areas the development of new hydropower facilities has the potential to lead to direct footprint losses. These can be within the newly impounded areas or through the development of new access roads that may lead to the loss of forest, steppe and desert and semi-desert. Key effects on aquatic ecology are associated with changes in erosion and sediment deposition processes, changes in habitat conditions and blockage of upstream/downstream migration pathways. The introduction of new small scale hydropower developments within sections of watercourse not previously exploited has the potential to adversely affect a number of protected fish species within the main river catchments of including the lli, Ural and Chu Rivers and their tributaries. New dams may introduce new barriers to migration of such fish species and other aquatic organisms making river reaches important for functions such as reproduction, feeding, and seasonal movement inaccessible.

10 In cases where several dams are located within the same basin or range of an affected species, significant cumulative effects can result. Changes in erosion and sediment deposition can result from two sources: runoff from precipitation (most prevalent during construction), and fluctuations in water levels in the reservoir and in downstream river reaches during operation. Erosion and sediment deposition can degrade water quality by increasing turbidity and impeding the life cycles of affected organisms. Sediment deposition can suffocate fish eggs or immobilise organisms that cannot escape the vicinity. The development of a hydroelectric facility can result in significant changes in local aquatic habitat due to modifications in flow conditions, water quality, and physical habitat. These changes can occur upstream and downstream of the hydroelectric dam, as well as in the bypass reach. Impoundment converts upstream reaches of river from natural lotic (riverine) to lentic (lake) conditions resulting in decreased flow velocities, increased water depths, and overall changes in flow patterns. Water temperatures in the impoundment may increase over natural stream temperatures; concentrations of nutrients and pollutants may increase as the impoundment acts as a "sink" where constituents collect. As a result anoxic conditions may develop in the impoundment's lower depths, particularly during the summer months. Physical habitat in the reservoir basin can be modified as sediments, gravel, and other debris accumulate in the reservoir. Effects on community and socio-economics For all renewable energy projects, there are common potential effects that must be considered. There is the potential dislocation of communities and households as a result of the facilities, roadways, and power transmission lines, which should be avoided. Forced or involuntary resettlement will have an extremely high effect which would be negative and long-lasting, starting prior to construction and last through operation. Resettlement will not only present a change in living conditions, but also may affect means of livelihood, social identity, and social effects. Efforts to minimize this impact should be made at the design stage. If resettlement is unavoidable, proper consultation and compensation would be required. Effects on health may include increased noise and dust displacement due to material transport and construction, which may impact workers and communities near the site and along transportation routes. The possibility of workers being injured is significant, especially during the construction of facilities and transmission lines, maintenance, and decommissioning. Although the proximity of communities to transmission lines was considered, the voltage used for connection to the grid would be far too low to generate any field of a magnitude which could have adverse human health effects. Positive economic, though minor, benefits of increased employment would arise during construction, maintenance and decommissioning. Secondary employment opportunities would also be presented from supporting economic activities such as lodging, food supply and support to infrastructure. Manufacturing of the required construction materials may also present economic benefits. There is the potential loss of land for other economic activities such as agricultural use, especially during construction. However, once construction is complete, land below transmission lines and wind turbines would be suitable for use. Tourism may be positively affected by providing power to remote areas and through the promotion of eco-tourism; however the landscape may be negatively affected in the process. Cultural heritage Two types of effects can be expected based on the Facility renewable energy projects:

11 Damage to cultural heritage which may occur due to the footprint of physical structures and the construction of the main facility or auxiliary facilities such as transmission lines. These effects during construction would result in permanent irreversible loss or damage to the receptor. The magnitude of the effect is difficult to determine at this stage; however, the spatial extent would depend on the importance and extent of the receptor (whether it crosses national boundaries). The effect is typically negative; however, there would be a positive effect if new cultural heritage sites would be discovered as part of the EIA process. This impact is likely significant. A visual impact may occur due to the physical presence of the facility and associated infrastructure. The effect would occur during operation; however, the impact may be reversible upon decommissioning. The magnitude of the effect is difficult to determine at this stage; however, the greatest effect would occur where the site is set within a historical or cultural landscape. For other cases, it would depend on existing visual intrusion and the scale of the renewable project. The spatial extent would depend on the importance of the heritage resource and location of the site. The effect is negative and likely to be significant, depending on the receptor. In addition, there could be a loss of intangible cultural heritage, if the heritage characteristic is localized enough to be impacted by construction or operation. This is unlikely to be reversible upon decommissioning. The magnitude would depend on the presence and effect of the intangible cultural heritage. The spatial extent is mostly local and the effect is likely to be negative and significant, if it occurs. Unregistered and unknown sites could adversely impact the resource itself and the viewshed of these sites if present. Potential artefacts could be destroyed or damaged during construction since excavation for foundations, power lines, and other structured can be extensive. Site preparation such as grading or preparing auxiliary infrastructure may also damage or destroy unknown remains. Equipment required for the project, such as biogas collectors, gas turbines, and transmission lines are relatively small and any effects would fall within the landfill site or immediately adjacent to the landfill site. Areas suitable for biogas projects are likely to consist of previously disturbed ground; therefore, there is a lower potential for viewshed impacts since the viewshed is already impacted. Impact to the intangible heritage is considered unlikely for the same reason. However, landfills sites may have very long histories as, once established, landfills and waste areas tend to be used repeatedly over time. In many cases, refuse from history can be considered a cultural resource at the present time. Therefore, there is always a potential for biogas projects to be located near unknown cultural resources. Summary of stakeholder engagement process under SER Below Table describes the key elements of the KazREFF SER stakeholder engagement and consultation programme. Stakeholder consultation has been ongoing throughout the main SER.

12 Table. Stakeholder engagement process under SER Events/Activities Tasks Information for disclosure Stage 1 Project Introduction and Stakeholder Identification (April through July 2013) Individual consultations with identified key stakeholders Gathering baseline information; presenting SER process Initial SER flyer (in English and Russian) Stage 2 Scoping and Capacity Building (July 2013 through March 2014) Posting SEP on the designated website Posting draft SER Scoping Report on the designated website SER Scoping meetings in Astana and Almaty On-going phone/ /mail correspondence with key stakeholders Scoping and capacity building workshops Presenting the document to public for discussion and comments Presenting the document to public for discussion and comments Gathering feedback on SER Scoping Report from the stakeholders and identification of capacity building needs Gathering feedback on SER Scoping Report from the stakeholders Building dialogue capacity for the Framework and its applicants and local experts; introduction of SER approach SEP (in English and Russian) Draft SER Scoping Report (in English and Russian) Presentation of key topics from the SER Scoping Report (in Russian) Draft SER Scoping Report (in English and Russian) Draft SER Scoping Report; hand-out materials (in Russian) Stage 3 Public Consultation and Implementation (September 2014 through March 2015) Notify stakeholders of availability of Draft SER for 120-day public consultation communication with all identified stakeholders Availability of SER for public consultation. Revised SER Leaflet (from Stage 1) Posting Draft SER Report and Non-Technical summary on the designated website SER workshops in Astana and Almaty Collecting feedback and comments on Draft SER report Presenting the document to public for discussion and comments Presentation of key conclusions of the SER (in Russian) Discussion of the SER results Draft SER Report (in English and Russian) and Non-Technical Summary (in English, Russian, and Kazakh) Draft SER Report in English and Russian; SER Non-Technical Summary in English, Russian, and Kazakh Draft SER documents Mitigation Measures following Best Practice Relevant EBRD environmental and social safeguards standards will be applied in accordance with the Accreditation Master Agreement and/or such other related arrangements. Each project under the EBRD-GCF Framework will be required to develop an Environmental Impact Assessment (EIA) in accordance with international standards, which will include mitigation measures that draw from the results of the impact assessment and good international industry practice.

13 SER identified mitigation measures for each of the above described potential negative environmental impacts under the specific conditions of Kazakhstan. SER also resulted in templates for project-level ESIAs that include a tool kit of mitigation measures that are based on the SER findings. Projects considered for financing under the EBRD-GCF Framework will undergo the appraisal process detailed in the following sections of this ESMSF and will be evaluated against the standards of EBRD s Environmental and Social Policy, as well as best practice such as the IFC Performance Standards. The WBG EHS General Guidelines and Guidelines for Wind Energy and Electric Transmission and Distribution will be used as a reference together with other guidelines and standards developed by the EBRD, the EU and other international institutions. Internationally accepted guidance on environmental, social, health and safety mitigation measures for renewable energy projects can be found in relevant EU Directives and Guidance Notes as well as the WBG EHS Guidelines. Such guidelines are applicable for the construction and decommissioning phases of renewable energy projects and provide guidance on mitigation measures and monitoring standards for projects. The WBG EHS General Guidelines are technical reference documents with general industry-specific examples of good international industry practice. The guidelines contain performance levels and measures that are generally considered to be achievable in new facilities by existing technology at reasonable cost. The applicability of the EHS Guidelines should be tailored to the hazards and risks of each project on the basis of the results of the impact assessment in which site-specific variables, host country regulations, assimilative capacity of the environment and other factors should be taken into consideration. The WBG General EHS Guidelines address mitigation measures associated with: Environmental Air emissions and ambient air quality Energy Conservation Wastewater and Ambient Water Quality Water Conservation Hazardous Materials Management Waste Management Noise Contaminated Land Occupational Health and Safety General Facility Design and Operation Communication and Training Physical Hazards Chemical Hazards Biological Hazards Radiological Hazards Personal Protective Equipment (PPE) Special Hazard Environments Monitoring Community Health and Safety

14 Water Quality and Availability Structural Safety of Project Infrastructure Life and Fire Safety (L&FS) Traffic Safety Transport of Hazardous Materials Disease Prevention Emergency Preparedness and Response For wind power projects specifically, the WBG EHS Guidelines for Wind Energy (2015) provide the specific guidance and the WBG EHS Guidelines for Electric Power Transmission and Distribution (2007) apply for projects involving transmission lines. In general, many ESHS impacts from renewable energy projects and its associated facilities can be avoided by careful site selection and alternatives analysis. Avoiding projects located within protected areas or Important Bird Areas (IBAs) can significantly reduce the level of impacts and risks of a project. Similarly, avoiding resettlement, cultural heritage sites and indigenous territories can highly improve the sustainability of a project. Due to the nature of renewable energy projects, which are located in resource rich areas, cumulative environmental and social impacts are particularly important to consider. If no relevant country-specific guidance is available in relation to cumulative impacts assessment, international sources of good practice guidance on this topic should serve as references. Cumulative impacts assessments are especially warranted when multiple wind energy facilities are sited in close proximity to sensitive receptors such as areas of high biodiversity value. The following main mitigation measures are considered from the WBG EHS Guidelines for wind power projects: Landscape and visual impacts: Consider turbine proximity, layout, size, and scale in relation to the surrounding landscape and surrounding visual receptors such as residential areas Incorporate community input into the layout and siting Maintain uniform size and design of turbines Minimize ancillary structures on site Noise during operations: Engineering design standards and turbine siting. Modern turbines have lower mechanical noise. Operating turbines in reduced noise mode. Building walls/appropriate noise barriers around potentially affected buildings Curtailing turbine operations above the wind speed at which turbine noise becomes unacceptable in the project-specific circumstances. Biodiversity: Careful site selection and layout should reduce adverse impacts on biodiversity. Any significant residual adverse impacts will need appropriate mitigation, which could include the following: Modify the number and size of turbines and their layout in accordance with site-, species-, and season-specific risks and impacts. Fewer taller towers may reduce the collision risk for most birds

15 and reduce vegetation clearing for construction. The location of associated infrastructure such as transmission lines, substations, and access roads should also be accordingly informed by biodiversity risk and impact assessments. If the wind energy facility is located close to areas of high biodiversity value, active turbine management such as curtailment and shut-down on-demand procedures should be considered as part of the mitigation strategy, and factored into financial modeling and sensitivities at an early stage. This method of mitigation should be adaptive and guided by a well-developed postconstruction monitoring program. Curtailment and shut-down on-demand measures should be first conducted as an experiment, with control turbines that are not curtailed and with both sets carefully monitored, to determine whether or not the curtailment is producing the desired fatality reduction. Technology-led turbine shut-down should be considered in certain cases, although any such system should be subject to a period of observer-led ground truthing and evaluation through a process of adaptive management. Avoid artificially creating features in the environment that could attract birds and bats to the wind energy facility, such as water bodies, perching or nesting areas, novel feeding areas, and staging or roosting habitats. Capping or fixing any cavities in walls or buildings helps to remove potential bat roosting sites. Avoid attracting birds to predictable food sources, such as on-site or off-site waste disposal areas, or landfills; this is especially relevant when vultures or other carrion-eating birds are present. These types of mitigation measures may also need to be carried out in the surroundings of the wind energy facility in order to be effective. Consider adjustments of cut-in wind speeds to reduce potential bat collisions. The feasibility of this measure should be informed by species- and site-specific data. A slight increase in cut-in wind speed may have the potential to achieve significant reductions in bat fatalities, with minimal reduction in generation or financial returns. Eliminate free-wheeling (free spinning of rotors under low wind conditions when turbines are not generating power). Avoid artificial light sources where possible. White, steady lights in particular attract prey (e.g., insects), which in turn attracts predators. If lights are used, red or white blinking or pulsing lights are best. Steady or slow blinking lights are to be avoided. Timers, motion sensors, or downwardhooded lights help to reduce light pollution. Bury on-site transmission lines. Install bird flight diverters on transmission lines and guy wires from meteorological masts to reduce bird collisions when located in or near areas of high biodiversity value and/or where birds of high biodiversity value are at risk of collision. Use raptor safe designs for power line poles to reduce electrocution risk. Assess the current state of the art of bird and bat deterrence technology, and consider implementing any proven effective technologies where appropriate. Shadow flicker: Site wind turbines appropriately to avoid shadow flicker being experienced or to meet limits placed on the duration of shadow flicker occurrence, as set out in the paragraph above. Wind turbines can be programmed to shut down at times when shadow flicker limits are exceeded. Occupational health and safety: The following occupational risks will be considered and the mitigation measures described in the WBH EHS Guideline for Wind Power will be used as a reference: Working at Height

16 Working over Water Working in Remote Locations Lifting Operations Community Health and Safety: Electrocution Electromagnetic interference Visual amenity Noise and Ozone Aircraft Navigation Safety Involuntary Resettlement Projects that involve significant physical displacement and resettlement actions will not be eligible under this Framework. Projects under the FiT programme are required to have obtained legal rights on the property where the project will be developed (i.e., direct purchase, rent or easement). It is expected that projects financed under the EBRD-GCF Framework will have negotiated agreements for land tenure with agreed compensation for land and economic displacement. EBRD Environmental and Social Management System (ESMS) Environmental and Social Sustainability Framework EBRD will apply its comprehensive Environmental and Social Sustainability Framework (ESSF) for the Facility. EBRD ESSF is based on the environmental and sustainability mandate in the Articles establishing the EBRD, the Environmental and Social Policy (ESP) and Performance Requirements, updated from time to time, and a dedicated Environmental and Sustainability Department (ESD) discharged with the responsibility of its implementation, and dedicated Gender and Energy Efficiency and Climate Change (E2C2) teams mandated to systematically identify environmental, social and gender-related opportunities. EBRD was accredited by GCF Board in September The latest version of the ESP and its Performance Requirements was approved by EBRD s Board of Directors on 7 May The ESP was revised to ensure EBRD remains aligned with other IFIs, such as the IFC and Equator Banks, to address issues that had arisen during implementation of the previous 2008 ESP, and to recognise a number of emerging sustainability issues. The revisions to the ESP followed an extensive consultation with stakeholders, including civil society organisations, industry associations, clients, other international financial institutions, and international organisations, and ensuring that all consultations are gender-sensitive. The ESMS is described in more detail in the Environmental and Social Procedures, which were updated in and which outline the process by which Bank staff process and monitor projects in accordance with the overall ESP framework. In accordance with EBRD s ESSF, all projects undergo environmental and social appraisal both to help EBRD decide if the project should be financed and, if so, the way in which environmental and social issues should be addressed in its planning, implementation and operation. The appraisal process also identifies opportunities for additional environmental or social benefits. EBRD seeks within its mandate to ensure through its environmental and social appraisal and monitoring processes that projects are designed, implemented, and operated in compliance with applicable regulatory requirements and good international practice.