Hydropower Sustainability Assessment Protocol Section III Trail ESKOM. Ingula Pumped Storage Scheme. November 2009

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Hydropower Sustainability Assessment Protocol Section III Trail ESKOM Ingula Pumped Storage Scheme November 2009 Assessor: Rob Griffin Date: 2009-11-25

Table of Contents 1 Introductory Information... 3 1.1 Company...3 1.2 Project...3 1.3 Status of Project, and Protocol Section Applied...5 1.4 Disclaimers and Confidentiality Agreements, if any...5 1.5 Schedule of the Assessment...5 2 Assessment Results from the Draft Protocol Trial General... 6 2.1 Objectivity and Replicability...6 2.2 Understandability...6 2.3 Scope and Comprehensiveness...6 2.4 Ease of Use...7 2.5 Impact and Effectiveness...8 2.6 Applicability to Range of Scale and Regions...8 2.7 Adequacy of Implementation Guidance...8 2.8 Presentation of Results...9 3 Assesment Result from the Draft Protocol Trial Aspect by Aspect... 9 3.1 River Basin & Transboundary Issues...9 3.2 Economic Viability Including Additional Benefits...9 3.3 Financial Viability...10 3.4 Public Sector Governance...10 3.5 Corporate Governance...10 3.6 Regulatory Approvals...10 3.7 Integrated Project Management & Communications...10 3.8 Construction Management...10 3.9 Procurement...10 3.10 Social Management Plan...10 3.11 Project Affected Communities...10 3.12 Indigenous People...10 3.13 Resettlement & Land Acquisition...11 3.14 Benefit Sharing...11 3.15 Labour & Working Conditions...11 3.16 Cultural Heritage...11 3.17 Public Health...11 3.18 Asset & Community Safety...11 3.19 Environmental Management Plan...11 3.20 Catchment Management...11 3.21 Reservoir Management...11 3.22 Environmental Flows & Downstream Sustainability...11 3.23 Biodiversity & Invasive Species...11 3.24 Erosion & Sedimentation...12 3.25 Water Quality...12 3.26 Waste, Noise & Air Quality...12 3.27 Hydrological Resource Availability & Management...12

1 INTRODUCTORY INFORMATION 1.1 Company Eskom is a South African company and is the single largest supplier of electricity in Africa, providing approximately 45% of the continent s power needs. It is also one of the top 10 utilities in the world by generation capacity and supplies 95% of electricity consumed in South Africa. The Generation Division has 24 power stations with a nominal capacity of over 44 000 megawatts. The division operates the largest dry-cooled coalfired power station in the world as well as Africa s only nuclear power station. The nuclear and coal-fired power stations provide base-load capacity for the national grid. The conventional hydroelectric, pumped storage, wind and gas turbine stations provide additional electricity during peak demand periods and when unforeseen shortages of capacity occur. Eskom s current hydropower has a capacity of 2061MW and consists of two pumped storage power stations and six hydroelectric power stations 1.2 Project Eskom's R16,6-billion Ingula power station, which is a pumped storage scheme situated on the border between the Free State and KwaZulu-Natal (KZN) provinces, is currently on schedule to commission its first unit in September 2012. The pumped storage scheme consists of an upper and a lower dam, each with a water capacity of approximately 22-million cubic metres. The dams, situated 4,6 km apart, are connected by underground waterways, through an underground powerhouse which will house four 333-MW pump turbines. During times of peak energy consumption, water will be released from the upper dam through the pump turbines to the lower dam to generate electricity, while during low energy demand periods, the pump turbines are used to pump the water from the lower dam back to the upper dam. Construction activities at Ingula started in February 2005 and after the first unit is commissioned, the remaining three units will be completed by November 2013. Upcoming project milestones include the completion of 57 km of new tarred road on-site, and hydropower generation joint venture Voith Hydro and Voith Fuji beginning work on the turbines and generators for the project. Local Development Ingula has provided direct and indirect employment to about 4 000 local Page 3 of 12

people. Eskom through the Eskom Development Foundation has refurbished three schools in the KZN community and is currently refurbishing the Hamilberg Primary School in the Free State. As part of the social development initiatives in the surrounding communities, Eskom will install electricity as well as provide access to water and roads for all the families who will be relocated. Ingula has managed to formulate effective stakeholder forums in KZN and the Free State. Stakeholder Forums are used as interaction and engagement platforms, thus building mutually beneficial relations with all their stakeholders. A skills development centre has been opened, where 1 000 locals were trained in different aspects of construction and basic life skills. The qualifications are certified by the relevant sector education and training authority. Several local companies and small-, medium- and micro-enterprises have benefited from subcontract work with all the main contractors on-site. The local taxi association has signed contracts with all main-contractors onsite for providing labourer transport. Environment Environmental education forms an integral part of the project. Local people are constantly given information about their effects on the environment and about the fauna and flora on site as work is in progress. An environmental monitoring committee has been involved in the constant monitoring of the project. A team of full-time professional environmentalists monitor all activities on site, ensuring all legal requirements are met, and that the project operates within the terms of the government authorisation. Eskom has taken a decision to manage the area surrounding the dam and the construction sites as a conservation area, and with the cooperation of landowners in the district, may form the core of a larger conservancy including the moist high grasslands of the eastern Free State and northern KZN. The region is of significant value as a source of water for the Highveld, and serves as a habitat for a variety of species of flora and fauna. A partnership launched in March 2004 between Eskom and conservation groups Birdlife South Africa and Middlepunt Wetland Trust is aimed at generating benefits at international, national, regional and local levels to offset the negative effects of the construction and operation of the pumped storage scheme. More than 220 species of birds have already been sighted at Ingula, one of these being the Wattled Crane which is among the top five endangered birds Page 4 of 12

in terms of the National Biodiversity Act. Also recorded are the threatened Oribi, as well as grey Rhebok and Steenbok. Historically, the site has been heavily used by livestock and large tracts of erosion can be seen. Livestock numbers have been reduced and eroded areas are being rehabilitated. The area has also been subject to high intensity poaching and illegal plant harvesting. Through the development of a protected area, it is hoped to increase numbers of animals and establish viable populations in a secure environment. A reduction in unsustainable activities will improve general conditions. Wetlands on the property serve as a continual water supply to the Wilge River, and springs flow throughout the year. The wetland system is host to a variety of species of flora and fauna, and is in need of protection following years of overgrazing and inappropriate burning. The formal conservation of the Wilge and associated wetlands will be explored in conjunction with the Free State Department of Tourism, Environmental and Economic Affairs. Rehabilitation begun in the past will be continued and the sustainable functioning of the wetlands ensured. 1.3 Status of Project, and Protocol Section Applied Ingula is in the project implementation stage thus Section III of the Hydropower Sustainability Protocol has been applied. 1.4 Disclaimers and Confidentiality Agreements, if any None 1.5 Schedule of the Assessment Date Time Description 11 Nov 08h30 Initial meeting 09h00 Assessment (6) 12h30 Lunch 13h00 Assessment (6) 16h00 End of day one 12 Nov 08h00 Assessment (8) 12h30 Lunch 13h00 Assessment (6) 15h30 Close out Meeting 16h00 End Representation: Eskom Peaking Inula Power Station Eskom Divisional Client Office - Ingula Middelpunt Wetland Trust Page 5 of 12

2 ASSESSMENT RESULTS FROM THE DRAFT PROTOCOL TRIAL GENERAL 2.1 Objectivity and Replicability Pumped Storage Schemes are not necessarily located in a river basin, and their Reservoirs are relatively small compared to other Hydropower Stations. Therefore some aspects could be considered as not relevant. It was felt that the rating descriptions and Guidance Notes need to be updated and expanded, once practically tested in a number of assessments to ensure some degree of replicability 2.2 Understandability The legal terminology of the document may make it more difficult to understand for those whose first language is not English and for supervisory technical staff to interpret and understand the protocol. However at the conclusion of the assessment the staff, having been assisted through the document, had a much better understanding. The aspect Social Management Plan is named Social Impact Assessment & Management on page 6 of the Guidance notes. The aspect Environmental Management Plan is named Environmental Impact Assessment & Management. The word plan in the aspect names caused confusion and it gave the impression that a formal plan is necessary in order to be effective for that particular aspect. It is recommended to rather use the descriptions on page 6 of the Guidance notes. While some hydropower facilities are independent entities, others are part of large corporates and assessment of certain aspects e.g. Financial Viability or Governance will need to be based on corporate policies, procedures and standards. This may impact the ability to use the protocol as a benchmarking / comparison tool for Hydropower Projects. E.g. Hydropower only makes up approximately 4,6% of Eskom s installed capacity. The terminology used is not consistent through out the Protocol; the aspects refer to four different terms namely Project, Hydropower Station, Hydropower Facility and Hydropower Project. This could lead to interpretation and therefore replicability issues. 2.3 Scope and Comprehensiveness It is suggested that stakeholder management and communication covered as aspects in their own right. Stakeholder management and internal and external communication have their own procedures, strategies and processes that can be assessed. Communication could be seen as a subset of Page 6 of 12

Stakeholder Management and assessed as such or could be seen as an aspect on its own. The management of specific issues, with specific stakeholders begins with the identification of a hydropower project, right to the end of its operating life. A data base and participation in local forums could be evidence of involvement with communities. There should be a smooth transition of stakeholder management from planning to operational phases. Commitments made in the early phases are often not carried over to construction and operating phases. 2.4 Ease of Use It will be very difficult to provide all the evidence to an auditor and a lot of timely preparation will be required prior to the assessment. It would also require considerable effort from the auditor(s) to give a fair rating. On page 6 in the guidance notes, the aspects are all grouped in logical order according to different perspectives, but the aspects in the assessment itself are in a different order. It will be easier if the aspects in the assessment are also grouped per perspective. The assessment can then be scheduled according to the perspectives and only the relevant people have to attend the assessment when the specific perspective is addressed. The attributes Level of Compliance and Level of Conformance with Plans are not consistent through out the document in the same sequence. The Aspect Assessment Score Cards (e.g. Table 1) at the back of the Protocol refer regularly to the Attribute guidance notes that are at the front end of the Protocol. This causes a lot of paging through while doing the assessment. A recommendation will be to separate the assessment part from the guidance notes (pages 1 through 20) to enable users to have the two documents open at the relevant areas simultaneously. Several approaches were tested and discussed on how to give one score for attributes with more than one sub-attribute (e.g. Table 1 first attribute). A decision was made to take the lowest sub-attribute score. For example, if a score of 2 and 4 are attained for an attribute with two sub-attributes then 2 was taken as the attribute score. If the average score of 3 is used as the final score, it will mean that there are no critical gaps, but critical gaps have already been identified for one of the sub-attributes. Therefore the lowest score has to be taken. The same will apply when the two sub-attribute scores are 4 and 5, some non critical gaps have been identified which mean the final score can not be higher than 4. The format of the Aspect Score Cards were found to be very busy table with too much duplication, a recommendation is made to simplify it (e.g. as in table 1). Page 7 of 12

Process Attributes Performance Attributes Attribute Assessment Management Planning Consultation Process Stakeholder Support Compliance Conformance with Plans Effectiveness 5 4 3 2 1 Excellent Very Good Good Poor Very Poor Quality of the process leading to understanding of the existing regional socio-economic baseline, regional economic activity and infrastructure, and related constraints and opportunities Quality of the Process leading to an Understanding of the opportunities to leverage regional development through the project to support broader economic development objectives Analysis of economic viability of the project through cost-benefit analysis which includes social, environmental and economic aspects Quality of the planning process to optimize delivery of project benefits [see management guidance note] Quality of the consultation process [See consultation guidance note] Level of stakeholder support for analysis and planning for additional benefits [see stakeholder support guidance note] Generally not relevant Conformance with plans for additional benefits [see conformance with plans guidance note] Optimisation of opportunities to deliver additional benefits to directly affected stakeholders and the broader community Fully optimised with no gaps Close to fully optimised with very few non-critical gaps Well optimised with a number of noncritical gaps Somewhat optimised with critical gaps Not optimised Success in achieving net project benefits based on cost benefit analysis factoring in social and environmental Table 1: Aspect Score Card 2.5 Impact and Effectiveness The more the learning points are shared between Projects the more the impact and benefit of the protocol will have for the Projects. 2.6 Applicability to Range of Scale and Regions None 2.7 Adequacy of Implementation Guidance The Implementation Guidance is duplicated in all four sections of the Protocol and makes up a large portion of the documents. The Protocol can be seen as overwhelming as it is a rather thick document. It also includes some information that is not relevant to all parties involved in the assessment. As suggested earlier, this could be alleviated by splitting the Guidance Notes from the assessment. Other Issues: Table 3 appears after Table 4 The order of the aspects on page 6 Table 1 of the guidance notes is not the same order as the aspects in the assessment. Page 8 of 12

2.8 Presentation of Results The reasons for scores of 5 should be documented and made available to all IHA members in order to share best practices. The reasons for scores of 1 and 2 should also be noted so that the project can create actions from these. It will be beneficial to record the sub-attribute scores as well in order to have a comprehensive report for the Project. The space provided in the evidence column of the auditor worksheet Table 3 on page 10 of Section IV is not enough to fill out all the evidence presented. A suggestion is to add another graph (e.g. Figure 1) which shows the average score of the attributes with a target value. This will emphasise to the project which attributes need to get attention. For example Figure 1 indicates that the project needs to concentrate their consultation processes. Attribute Average 5 4.5 4 3.5 Avg 3 2.5 2 1.5 1 Assessment Management Consultation Stakeholder Support Conformance with Plans Complince Effectiveness Attribute Figure 1: Attribute Average A recommendation was made to send an electronic file of the assessment scores to the Power Stations, which will allow them to draw their own graphs and do their own analysis. A sample of such a spreadsheet is sent as a separate attachment to this report. 3 ASSESMENT RESULT FROM THE DRAFT PROTOCOL TRIAL ASPECT BY ASPECT 3.1 River Basin & Transboundary Issues The attribute Compliance is described as generally not relevant in the protocol (p24), in South Africa there are some legal requirements were compliance are needed with regards to the Aspect River Basin & Transboundary Issues. 3.2 Economic Viability Including Additional Benefits The attribute Compliance is described as generally not relevant in the Protocol (p26). Eskom s only shareholder is the government and they have to Page 9 of 12

comply to the Public Finance Management Act when they deal with Economic Viability and therefore the attribute Compliance was felt to be relevant. 3.3 Financial Viability 3.4 Public Sector Governance The second sub-attribute (p29) of the attribute Assessment s numbers who refer to the notes (p30) are incorrect. 3.5 Corporate Governance 3.6 Regulatory Approvals The Protocol states that the attribute Effectiveness is not relevant at implementation stage. This was felt not to be the case as there needs to be compliance to the approvals during implementation / construction. 3.7 Integrated Project Management & Communications It was recommended that Communication should be a separate aspect (see above - 2.3). 3.8 Construction Management This aspect was not assessed as it was felt that this aspect is already covered by other aspects (e.g. Social Management Plan, Labour and Working Conditions, Environmental Management Plan ). 3.9 Procurement 3.10 Social Management Plan 3.11 Project Affected Communities The sub-attribute of Management describes the difference between a score of four and five as Formed for many and Formed for most. It is difficult to distinguish between the words most and many. It will be recommended to replace the word most with the word all. 3.12 Indigenous People The definition of Indigenous People allows identification of various people that may not be deemed to be indigenous people as the definition does not state that they have to be economically disadvantaged. This aspect was not scored as it was felt that Indigenous People were already covered under the aspect Project Affected Communities. Page 10 of 12

3.13 Resettlement & Land Acquisition Perceptions may differ in terms of the improvement of standards of living for displaced persons (e.g. some may prefer to live in a less sophisticated manner). 3.14 Benefit Sharing 3.15 Labour & Working Conditions Health and Safety are extremely important aspects on any site, the aspect deals with people s lives and has its own processes and compliance requirements. It is recommended to separate Health and Safety from the Labour & Working Conditions aspect and to add it as another aspect. 3.16 Cultural Heritage 3.17 Public Health 3.18 Asset & Community Safety 3.19 Environmental Management Plan The first sub-attribute of Assessment mentions the social baseline, the feeling was that it should be replaced by environmental baseline. 3.20 Catchment Management 3.21 Reservoir Management This aspect was not assessed, because it was felt that reservoirs of a pump storage scheme are relatively small and that all the characteristics of the aspect were covered by other aspects. 3.22 Environmental Flows & Downstream Sustainability The Protocol indicates that the attribute Compliance is not generally relevant at this stage however the trial participants indicated that it should be relevant and it was therefore rated. 3.23 Biodiversity & Invasive Species It was recommended to split Biodiversity and Invasive Species into two aspects. The comment made was that Invasive Species have an economic impact while Biodiversity has an environmental impact. Biodiversity is a very broad field covering a large amount of issues. Invasive species have major resource and economic impacts. Page 11 of 12

3.24 Erosion & Sedimentation 3.25 Water Quality The one sub-attribute of Effectiveness asks a question about the operation stage which is not possible to answer at this stage of the project. 3.26 Waste, Noise & Air Quality 3.27 Hydrological Resource Availability & Management This aspect is indicated on p6 of the Guidance Notes to be part of the assessment for Section III but it does not appear in the assessment. Page 12 of 12

South Africa - Eskom- Ingula Pumped Storage Scheme - November 2009 Draft Hydropower Sustainability Assessment Protocol Section III Results Process Attribute Scores Performance Attribute Scores Stakeholder Conformance Perspectives ASPECT NAME Assessment Management Consultation Compliance Effectiveness Low High Support with Plans Attribute Sub- Attributes Attribute Sub- Attributes Attribute Sub- Attributes Attribute Sub- Attributes Attribute Sub- Attributes Attribute Sub- Attributes Attribute Sub- Attributes 4 3.75 3.83 3.58 4.71 3.67 3.46 Covernance Technical Financial & Economical Social Environmental Geographic Public Sector Governance 4 4 4 3 3 4 4 3 3 N/A 3 3 3 3 4 3 3 3 4 Regulatory Approvals 5 5 5 5 4 4 4 4 5 5 4 4 4 4 4 5 Corporate Governance 5 5 5 4 5 4 4 5 5 5 5 4 4 4 5 5 5 5 5 5 5 5 4 5 Integrated Programme Mgmt & Comms 4 4 4 3 3 3 3 4 3 4 4 N/A 3 3 3 4 4 3 4 Construction Management N/A N/A N/A N/A N/A N/A N/A 0 0 Hydrological Resource Availability & Management 4 4 4 5 4 4 4 5 5 4 4 4 4 5 5 5 5 5 4 5 Asset & Community Safety 4 4 4 4 3 3 4 4 5 5 4 4 3 3 3 3 5 Economic Viability incl. Additional Benefits 4 4 4 4 4 4 4 4 4 4 5 5 4 4 4 4 4 4 5 Financial Viability 4 5 5 4 5 4 4 5 4 4 4 4 5 5 3 3 3 3 3 4 3 5 Procurement 4 5 4 5 4 3 4 4 3 4 4 4 4 5 5 3 3 3 4 3 3 3 5 Social Management Plan 3 3 3 3 3 4 4 2 2 4 4 3 3 3 3 4 2 4 Project Affected Communities 3 3 4 3 3 5 4 3 4 3 4 2 2 5 5 3 3 3 3 4 3 2 5 Indigenous Peoples N/A N/A N/A N/A N/A N/A N/A 0 0 Resettlement & Land Acquisition 4 4 5 3 3 3 3 4 3 4 2 2 4 4 3 3 3 4 3 2 5 Benefit Sharing 3 3 3 2 2 3 3 4 4 N/A 3 3 3 3 2 4 Labour & Working Conditions 4 4 4 4 4 4 4 3 3 3 4 4 3 3 2 3 2 2 4 2 4 Cultural Heritage 4 4 4 4 4 4 4 4 4 5 5 5 5 4 4 4 4 4 5 Public Health 3 3 3 3 4 3 3 3 3 3 4 4 4 4 3 3 4 4 3 4 Environmental Management Plan 4 4 4 4 4 5 5 3 3 5 5 4 4 3 4 3 3 5 Biodiversity & Invasive Species 5 5 5 5 5 5 4 4 5 5 4 4 4 4 5 4 4 5 Erosion & Sedimentation 4 4 4 4 4 4 4 4 5 5 4 4 4 4 4 4 5 Water Quality 5 5 5 5 5 5 4 4 5 5 3 3 3 3 3 3 5 Waste, Noise & Air Quality 2 2 3 3 3 3 3 3 4 4 4 4 3 3 3 2 4 River Basin & Transboundary Issues 5 5 5 5 5n/a 4 4 5 5 5 5 4 4 4 4 4 5 Catchment Management 5 5 3 3 2 2 4 4 5 5 3 3 3 3 3 2 5 Reservoir Management N/A N/A N/A N/A N/A N/A N/A 0 0 Environmental Flows & Downstream Sustainability 4 4 5 5 5 5 4 4 5 4 4 5 5 4 4 4 4 4 5

5 4 3 2 1 Aspect Range 2009 Effectiveness 2 Score Public Sector Governance Regulatory Approvals Corporate Governance Integrated Programme Mgmt & Comms Construction Management Hydrological Resource Availability & Management Asset & Community Safety Economic Viability incl. Additional Benefits Financial Viability Procurement Social Management Plan Project Affected Communities Indigenous Peoples Resettlement & Land Acquisition Benefit Sharing Labour & Working Conditions Cultural Heritage Public Health Environmental Management Plan Biodiversity & Invasive Species Erosion & Sedimentation Water Quality Waste, Noise & Air Quality River Basin & Transboundary Issues Catchment Management Reservoir Management Environmental Flows & Downstream Sustainability Covernance Technical Financial & Economical Social Environmental Geographic