Actis South Africa Wind Power
This Environmental and Social Review Summary (ESRS) is prepared by MIGA staff and disclosed in advance of the MIGA Board consideration of the proposed issuance of a Contract of Guarantee. Its purpose is to enhance the transparency of MIGA’s activities. This document should not be construed as presuming the outcome of the decision by the MIGA Board of Directors. 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. MIGA has reviewed the attached documentation as provided by the applicant, and considers it of adequate quality to be released to the public, but does not endorse the content.
Okavango Biology Mauritius Limited (“the Guarantee Holder” or “GH”) is seeking MIGA Guarantees for the equity and potential shareholder loan investments into the construction and operation of two greenfield wind power plants in South Africa, (collectively, “the Project” or “the Projects”). The following is a brief description of each wind farm:
Excelsior – a 32.5 MW wind farm under construction located approximately 30 kilometers (km) south west of Swellendam in the Overberg region of the Western Cape Province. The wind farm will cover an area of approximately 2400 hectares (ha) and consists of 13 turbines. It will be connected to the grid owned by Eskom, the South African electricity public utility, via a 13 km 132 kilovolt (kV) transmission line, which is included in the project scope. The site is located on land that has previously been zoned for agricultural use (sheep grazing and commercial cultivation of cereal crops (Canola and Sunflower)). Option to lease and compensation agreements are in place with landowners for the overall facility as well as for 3 encroachment servitudes in cases where the blades of the wind turbines will encroach on the air space of certain neighboring properties. Servitude agreements are also in place with 7 landowners for the powerline. The facility is planned to be commenced in February 2020.
Other structures within the Excelsior project site layout are the existing Vryheid substation and existing 66 kV power line operated by Eskom. These structures are not considered associated facilities to the Project because they existed at the Project site before the Project.
Golden Valley 1 (GV 1) – a 120 MW wind farm is being constructed on 8,100 ha in the Blue Crane Route Municipality in the Eastern Cape Province near the towns of Cookhouse and Bedford. It will consist of 48 turbines. The site is located on four farm properties. The entire site is private farmland and was primarily used for grazing. GV 1 will be connected to the Eskom grid by a 7 km 132 kV overhead transmission line, which is a part of the project. The facility is planned to be commenced in November 2020. Lease agreements have been put in place with all landowners including two that will have servitudes and three with encroachment servitudes on their properties. No informal land users were identified at risk of economic displacement as a result of the development of the site and no other issues were identified with respect to land acquisition and involuntary resettlement. GV 1 is surrounded by other wind farm development projects (Amakhala, Nojoli and Cookhouse)..
Both sites are located in Renewable Energy Development Zones (REDZ) which are areas identified by the government-led Strategic Environmental Assessment (SEA) process for the development of large-scale wind and solar energy facilities in a manner that limits significant negative impacts on the natural environment, while yielding the highest possible socio-economic benefits.
The Guarantee Holder is a wholly-owned subsidiary of Actis Energy 4 LP (‘AE4’), a fund managed by the private equity firm Actis of the United Kingdom. AE4 signed a sale and purchase agreement to acquire the Project developer BioTherm Energy (Pty) Ltd of South Africa which is an African renewable energy development company. The Projects have signed 20-year Power Purchase Agreements (PPAs) with Eskom SOC, the state-owned public utility and off-taker, and signed Implementation Agreements with the Department of Energy. These Projects are part of Round 4 of the South Africa Renewable Energy Independent Power Procurement Program. Project development is being led by BioTherm, with wind turbines provided by Goldwind which is also the Engineering Procurement Construction (EPC) Contractor and Operations and Maintenance (O&M) Contractor.
In addition to the wind farms, Actis is seeking MIGA coverage for two solar power projects, considered in a separate ESRS document which was disclosed on MIGA website on May 28, 2019 and is accessible at this link.
While all Performance Standards (PSs) are applicable to this investment, based on our current information, the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:
- PS1: Assessment and Management of Environmental and Social Risks and Impacts
- PS2: Labor and Working Conditions
- PS3: Resource Efficiency and Pollution Prevention
- PS4: Community Health, Safety, and Security
- PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS5 (Land acquisition and Involuntary Resettlement) does not apply to this investment. All land where the wind farms will be developed are private land parcels and all land transactions have taken place on a willing-lessee / willing-lessor basis. No physical or economic resettlement was required for both projects.
PS7 (Indigenous Peoples) is not relevant to this project since indigenous communities are not present in the area.
PS8 (Cultural Heritage) is not relevant for this project as no sites of archeological significance were identified. Environmental Management Programs for both sites include Chance Find Procedures.
In addition, the following World Bank Group (WBG) Environmental, Health, and Safety (EHS) Guidelines are applicable to the Project:
- General EHS Guidelines;
- EHS Guidelines for Wind Energy; and
- EHS Guidelines for Electric Power Transmission and Distribution.
The following documents were reviewed by MIGA:
- Environmental Impact Assessment (EIA) for the proposed BioTherm Wind Energy Project (Excelsior) near Swellendam: Final EIA Report, prepared by CSIR in April 2011
- Reports on avifaunal pre-construction monitoring at the proposed Excelsior Wind Energy Facility prepared by Chris van Rooyen Consulting in 2012, 2016 and 2018.
- Excelsior Environmental Management Program (EMPr) prepared by Savannah Environmental (Pty) Ltd. in December 2016.
- EIA: Proposed Amstilite (RF) Proprietary Limited Golden Valley Wind Energy Project – Phase/Project 1, Blue Crane Route Local Municipality, Cookhouse. Volume 3: Environmental Impact Assessment Report prepared by EOH Coastal & Environmental Services in February 2016
- BioTherm Energy (PTY) Ltd. Golden Valley Phase II Wind Energy Facility Near Cookhouse – Eastern Cape, 12 months pre-construction bird monitoring. Final report. Prepared by WildSkies Ecological Services (Pty) Ltd in March 2016.
- Golden Valley Environmental Management Program (EMPr) originally prepared in October 2010 and updated in December 2015 by EOH Coastal & Environmental Services
- Strategic Environmental Assessment for wind and solar photovoltaic energy in South Africa. Department of Environmental Affairs, 2015. CSIR Report Number: CSIR/CAS/EMS/ER/2015/0001/B. Stellenbosch available at https://egis.environment.gov.za/redz
- Excelsior Wind Farm Critical Habitat Assessment prepared by Chris van Rooyen Consulting in July 2019
- Golden Valley 1 Wind Farm Critical Habitat Assessment for Avifauna prepared by WildSkies Ecological Services (Pty) Ltd in July 2019
- Excelsior Wind Farm: Biodiversity Action Plan (draft) prepared by Chris van Rooyen Consulting in August 2019
- Golden Valley 1 Wind Farm Draft Biodiversity Action Plan (draft) prepared by WildSkies Ecological Services (Pty) Ltd in August 2019
In addition to reviewing the above documents, MIGA’s Environmental and Social (E&S) Specialist visited both project sites in April 2019. The visit included a walk-over of the Project site and meetings with land owners, Project and the EPC staff and local communities.
MIGA’s due diligence review considered the E&S management planning process and documentation for the Project and identified gaps (if any) between these and MIGA’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable time, are summarized in the paragraphs that follow and in the Environmental and Social Action Plan (ESAP) attached to this ESRS. Through the implementation of these measures, the Project is expected to be designed and operated in accordance with the Performance Standards.
Key E&S risk and/or impacts associated with the Project business activities are summarized in the paragraphs that follow.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Policy
BioTherm has developed an Integrated Environmental, Social and Occupational Health and Safety Policy document. This corporate policy applies to all aspects of its operations – construction, operation and maintenance; and is communicated to employees and other stakeholders. It emphasizes that BioTherm will maintain high business integrity standards, implement a sound Environmental and Social Management System (ESMS), protect the sustainability of local communities, and implement occupational health and safety standards in line with South Africa Occupational Health and Safety Act (1993). The Policy also states that BioTherm will establish a non-discriminatory environment for people with HIV/ AIDS and maximize its contribution to socio-economic development in the areas where the Company operates. The BioTherm policies were communicated to all BioTherm site-based employees.
Environmental and Social Management Systems
The Project has developed site-specific Health, Safety and Environment (HSE) Management System (MS) manuals and BioTherm HSE Managers have been appointed to oversee their implementation. Goldwind has used these manuals as a guideline to develop and implement their own site-specific HSE MS. This system is based on the Plan-Do-Check-Act model for HSE control and continuous improvement. It also refers to the requirements of South African legislation, the PSs and the WBG EHS Guidelines. It focuses on occupational health and safety (OHS) risks and impacts and outlines elements such as site and job specific responsibilities, permit to work system, visitors’ induction, security procedure, HSE statistics and incident investigation, emergency response, HSE training, HSE inspections and audit. The Project will develop and implement an overarching ESMS framework or manual for the construction and operation phases of wind power plants in line with PS1 requirements (as per the ESAP). The ESMS framework will also incorporate the existing management plans and programs.
Environmental and Social Assessment
EIAs were completed for each site by independent environmental consulting companies during the period of 2011-2016 as required under South African National Legislation. The EIA process included public consultations and disclosure with local stakeholders including state authorities, interested Non-governmental Organizations (NGOs) and affected communities. The EIA reports have been approved by the Department of Environmental Affairs (DEA). Site alternatives were assessed in the EIAs considering existing land use and biodiversity sensitivity. Outcomes of these analyses are captured in each respective EIA report. As a part of the EIA process, the project has also developed an Environmental Management Programs (EMPr) for each site which describe generic mitigation measures for planning, construction, rehabilitation, operations and decommissioning phases of the project.
In the June 2019, two independent consulting companies conducted Critical Habitat Assessment (CHA) studies based on the results of the baseline monitoring. This work has been supervised by the thirds party consultants specifically contracted by Actis this purpose.
Potential cumulative impacts on biodiversity were considered as part of the EIA and CHA studies. As the GV 1 site is in proximity to other wind projects in the Cookhouse zone, there is a need for strategic planning and cooperation to better understand the cumulative biodiversity impacts that may result from wind farm development in the Cookhouse REDZ. BioTherm has been working with local NGOs such as BirdLife South Africa to understand individual contributions to regional cumulative impacts. The Project will engage with the other wind farms to jointly develop a framework for Cumulative Impact Assessment (CIA) study and explore joint mitigation efforts (as per the ESAP).
The HSE function is managed on-site through the EPC Construction Manager, Health and Safety (H&S) Manager and Environmental Officer. BioTherm provides an HSE oversight role and has appointed several specialists to assist with independent quality assurance and compliance verification. BioTherm has also appointed an independent Environmental Control Officer (ECO) from local E&S Consulting Companies (Savannah Environmental at Excelsior and Nsovo Consulting at Golden Valley). The ECO is responsible for the monitoring of compliance against the EMPr and EIA. For the HSE aspects, BioTherm has appointed an independent part-time Health & Safety Agent.
Ongoing engagement with community stakeholders is currently being undertaken by the Goldwind Socio-Economic Development (SED) Manager and locally recruited Community Liaison Officers (CLO) for each site (2 in total) who oversee the
economic development program and local recruitment process. A dedicated BioTherm Stakeholder Engagement Manager (SEM) has been recently recruited in the Eastern Cape province to support GV 1 project. Overall stakeholder engagement effort is led by the Economic Development Director in the BioTherm Headquarters in Johannesburg.
Specifically, at Excelsior in addition to CLO work, stakeholder engagement effort from Goldwind is supported by a third-party contractor, Economic Development Solutions (EDS). The EDS team consists of 4 people who assist Goldwind in conducting regular meetings with stakeholders focusing mainly on local recruitment and maintaining a job seekers database.
Monitoring and Review
The EMPr contains framework level monitoring requirements and procedures as well as key parameters and indicators to evaluate potential adverse E&S impacts. HSE management responsibilities, monitoring, and reporting requirements are outlined within the procedures. Third party contractors are managed and monitored through procurement procedures, and report on any E&S issues to the assigned Goldwind H&S Managers. Whenever necessary, Goldwind will elevate performance or non-compliance issues to the BioTherm team.
Environmental performance is evaluated on monthly basis by the ECO who submits reports to the DEA for the wind farms and Eskom for the Excelsior transmission line. The reports contain information on the construction progress, incidents and non-conformities, dust monitoring, vegetation clearance, waste management practices, progress on implementation of the EMPr and recommendations for continuous improvement. In accordance with the requirement of the Department of Labor (HSE performance is assessed monthly by third party companies (Health & Safety Agents) who regularly visit the sites and review the compliance of the HSE documentation
Stakeholder Analysis and Engagement Planning
Goldwind has developed a site-specific Stakeholder Engagement Plans and Economic Development Plans (EDPs) for each site which are mostly focused on creation of economic opportunities for local communities in line with the requirements of the South Africa nation-wide Broad-Based Black Economic Empowerment (B-BBEE) Program. The B-BBEE is an inclusive program launched by the South African government to advance economic transformation and enhance the economic participation of black people in the South African economy.
The current community engagement process mostly serves as a platform to provide economic opportunities to local small and medium enterprises and to provide jobs to local communities. It should also include farm workers who permanently reside in the immediate vicinity to the construction sites and might be exposed to environmental impacts such as dust. The Project will enhance its stakeholder identification and engagement framework to ensure that farm workers are aware of the potential impacts and have access to grievance mechanism (as per the ESAP).
Stakeholder engagement at site level throughout the project development have indicated that the local communities in general welcome the arrival of the project, and anticipate jobs and eventually socio-economic development benefits to the surrounding areas.
BioTherm has developed a Stakeholder Engagement and HSE Communication Plan for each site that outlines the responsibilities of the company and its contractors with regards to stakeholder engagement, the mandate of the CLOs and the procedure for stakeholder engagement. An overarching Stakeholder Engagement Plan (SEP) will be developed at corporate level, in line with PS1, detailing the engagement to be carried out during the operations phase of the Project and ensure coordination of engagement efforts at the construction phase. The over-arching SEP will incorporate the existing, site-specific SEPs and ensure that the Project also periodically updates the community on: (i) the E&S risks of the power plants; (ii) the grievance mechanism procedure; (iii) the community development program; (as per the ESAP). The Project will also include stakeholder engagement records in the periodic reporting to MIGA during the construction and operations phases.
Goldwind has developed Community Grievance Mechanism Procedures and Community Grievance Registers for both sites. The registers describes the responsibilities of the project team and how the grievances were addressed. CLOs are the primary points of contact for communities to communicate their grievances. Most of the complaints and issues so far were about provision of jobs for local communities, fair and equal distribution of opportunities for local businesses and between local contractors.
Emergency Preparedness and Response
The site has a detailed Emergency Response Plan in place, including potential incidents affecting or involving community members. All visitors and persons working at the site are to be made aware of this plan as part of site induction, and there are regular emergency drills and testing of alarms.
PS2: Labor and Working Conditions
Human Resources (HR) Policies and Procedures
Labor practices in South Africa are regulated by the Labor Relations Act 66 of 1995 which is enshrined in the South African Constitution and standardizes employees’ work-related rights, working conditions and stipulates obligations of employers and employees.
HR Policy documents have been developed for both sites in accordance with applicable South African regulation as well as the International Labor Organization (ILO) fundamental conventions. The policy includes provisions for human rights, child labor, non-discrimination, safe and healthy work environment, fairness and transparency of the recruitment process. It is stated in the document that the requirements of the Policy will be applied for all contractors and subcontractors.
As stated in Goldwind Equal Employment Opportunity Policy, Goldwind is responsible for providing an environment where all employees are treated fairly, and any type of discrimination is discouraged. No accommodation is provided on site for employees as workers including unskilled workers are from the nearby towns and villages. Workers are transported to the sites daily by minibuses arranged according to the contracts with local taxi associations. Goldwind has agreements with local hospitals (located about 20-25 km away from the site) for ambulance services in the event of emergencies and each construction team has a trained first aider and a first aid kit.
There is no formal HR function at corporate or Project level as HR issues are dealt with by senior management (specifically the Chief Executive Officer) and contracts for workers (in line with national requirements) have been developed by a legal firm. Operations stage of the project will not require significant workforce. The Project will develop an organizational chart that details the HR structure and persons responsible for HR (as per the ESAP).
Workers’ Organizations
While there is no impediment to workers joining a union should they wish to do so, none of the workers are unionized and the Project is not party to any collective bargaining agreements. Workers are however represented on the Health and Safety (H&S) Committees.
Grievance mechanism
An internal Goldwind Grievance Resolution Procedure has been developed in line with PS 2 requirements including a policy, grievance procedure form and grievance tracking register, and an integrated grievance mechanism poster. The Policy also commits to monitoring grievances.
Child Labor and Forced Labor
The Project, as well as the contractors and subcontractors involved in the project, follow the South Africa Basic Conditions of Employment Act. The age screening is compulsory for all new workforce and the documentation is regularly checked during the inspections organized on behalf of the Department of Labor.
Occupational health and safety
Construction staff are exposed to such hazards and risks as dust, noise and vibration, working under heat stress, risk of collision with moving parts of machinery and equipment, falls from height, blasting and excavation, risks related to transportation of people to and from the site, possible snake bites.
Site specific Health & Safety and Environmental (HSE) Plans have been prepared by Goldwind for both sites in compliance with the Occupational Health & Safety (OHS) Act (1993). These documents adequately address the requirements of PS2 with respect to the management of occupational health and safety. The HSE plan provides roles and responsibilities, detailed provisions for the management of H&S in relation to site activities e.g. blasting, excavation works, working at heights, and procedural requirements including, hazard identification and risk assessments, signage, communication and liaison, induction and training, permit to work and lock-out procedures; and audit, monitoring and reporting requirements, etc. A permit to work system is in operation for the following disciplines: Digging, Hot works, excavation work, Crane operation, Work area permits (after turbine installation), Commission / Energize, Electrical Systems, Extended Hours Working or Night Work, Removal of material/equipment off site.
Goldwind has also developed project specific HSE Rules that are included in the exhibit of the contract with each sub-contractor. It states that contractors shall establish, maintain, and ensure that all their sub-contractors establish and maintain safety, health and environmental standards and systems as necessary, and to comply with all Acts, regulations, ordinances, by-laws, standards, codes, rules and requirements of public, municipal and other authorities, including but not limited to, the OHS Act. Health and Safety incidents are tracked and reported via an incidents’ register. No fatalities or significant H&S accidents or lost time H&S related injuries have been reported by BioTherm or the EPC to date.
Traffic Management plans have been developed for each site. They identify traffic hazards and risks including collisions with pedestrians, accidents involving livestock and wild animals, transportation of abnormal and oversized loads (e.g. turbine blades), traffic interaction with construction related activities (e.g. excavation and blasting). According to the traffic management plans these risks are managed by the enforcing the speed limits, installing proper signage, providing training to drivers, implementing trip assessment and journey management procedures and enforcing vehicle preventative maintenance.
PS3: Resource Efficiency and Pollution Prevention
Greenhouse Gases
The development of the Projects has the potential to result in significant Greenhouse Gases (GHG) reductions and is in alignment with the objectives of the South Africa’s Integrated Plan for Electricity 2010, which seeks to reduce carbon dioxide (CO2) emissions by 34 percent by 2020 and 42 percent by 2025. Based on the calculations following the methodology of the United Nations Framework Convention on Climate Change (UNFCCC) the estimated reduction of CO2 would be about 411,054 tons CO2/MWh on average per year for GV 1 and about 117,220 tCO2/MWh for Excelsior.
Water Consumption
Pollution Prevention
Dust and noise mitigation measures are summarized in the Projects’ HSE Plans During construction and operation air emissions will be minimized by proper road maintenance measures, re-scheduling of works during the periods of high winds, application of dust suppressants to gravel roads and cleared areas, vehicles speed control and training for drivers, and maintenance of equipment. Dust emissions will be negligible during operation stage.
Wastes
Site-specific waste management plans for both sites were developed by Goldwind in November 2018. These describe legislative requirements, roles and responsibilities and measures for the safe management, storage, transport and disposal of site waste including inter alia procedures for: waste assessment and inventory, waste collection, handling and storage areas, disposal (including specific requirements for safe disposal of hazardous waste e.g. broken solar panels), procedures in case of spill, record keeping and training. Site-specific Hazardous Chemicals Substance Storage plans are also in place, developed by Goldwind in November 2018. These are in compliance with the requirements of MIGA PS 3 and detail requirements and procedures for the identification and management hazardous chemical related risks including Hazard Chemicals Substance Register; Material Safety Datasheet; Spill Kits; and Daily Site Task Instructions.
PS4: Community Health, Safety & Security
The project sites are located in rural and remote areas far from community centers, residential, and commercial areas and within privately owned farms. Nonetheless, potential community impacts can be significant during the movement of equipment to and from the site. Risks and impacts, in the context of health and safety of off-site communities, include risks during construction activities caused particularly by increased traffic of heavy machinery, noise and dust levels during construction, and risks of increased social and health issues due to the influx of workers to nearby town centers. Given stringent regulated local content requirements, the risk of community exposure to disease via migrant workforce is anticipated to be a low to negligible risk.
Both sites have detailed Security Management Plans in place developed by Goldwind. They provide clear commitment by the Project in terms of recruitment, vetting and appropriate training of security contractors and ensuring all sub-contractors are accredited with the South African regulated industry association standards. These standards include a Code of Conduct with respect to weapons and use of force.
Project sites are currently fenced due to their location within private farms. Security for all sites consists of an access control system. Third-party security providers are hired at each site.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Critical Habitat
Potential biodiversity impacts during construction and operation of the Project include temporary bird species displacement due to construction activities, disturbance to wildlife due to vehicles, machinery and onsite workforce, permanent habitat loss resulting from construction of foundations for wind turbines, and collision risk for birds and bats during turbine and transmission line operations. Because the Excelsior and Golden Valley 1 project sites are located in different provinces and maintain different biodiversity values, two separate sections below describe compliance with PS6 at each site.
Excelsior
The Excelsior site is located in the center of the Overberg Wheatbelt region which is classified as an Important Bird Area (IBA) and Key Biodiversity Area (KBA). The De Hoop Nature Reserve, which is located around 30 km south from the project site, is a home to the last remaining colony of the Cape Vulture in the Western Cape province and there are no other Cape Vulture colonies in the radius of around 500 km. The area is characterized by undulating, cultivated, shale hills and is predominantly agricultural, with most farms producing sheep and cultivating such grains as wheat, barley and canola. Thus, the majority of the site area is located in agricultural lands with low botanical sensitivity and significant impacts on natural vegetation are not expected. Nevertheless, the EIA study has shown that the remnants of the natural Renosterveld vegetation which is found mostly along drainage lines and on steeper slopes that are unsuitable for agriculture, can be expected to support various plant species of conservation concern.
A study of impacts on bats for the Excelsior was conducted in 2015 by an independent consulting company by means of a 12 months survey involving acoustic monitoring of the echolocation calls of bats to determine the species composition at the sites and their nocturnal activity patterns. Based on the study the flight activity was dominated by the Natal long-fingered bat (Miniopterus natalensis, 67%), and seven other species all of which are classified as Least Concern according to the International Union for Conservation of Nature (IUCN).
A pre-construction baseline bird monitoring has been conducted by an independent consulting company in accordance with the “Best practice guidelines for avian monitoring and impact mitigation at proposed wind energy development sites in southern Africa”. It covered 12 months of observations in 2011-2012, spring -summer period in 2015-2016 and autumn- winter period in 2018 totaling to 2 years of monitoring.
Based on baseline studies that included transect and point counts, vantage points observations and focal point counts, 86 bird species have been recorded on site. Of them only 6 species are species of concern according to the IUCN classification including Cape Vulture (Gyps coprotheres, IUCN EN[1]), Black Harrier (Circus maurus, IUCN EN), Blue Crane (Anthropoides paradiseus, IUCN Vulnerable (VU)), Martial Eagle (Polemaetus bellicosus, IUCN VU) Secretarybird (Sagittarius serpentarius, IUCN VU) and Denham's Bustard (Neotis denhami, IUCN NT). In addition, the IUCN LC restricted range Agulhas Long-billed Lark (Certhilauda brevirostris) was observed on site. Among the 6 species of concern the flight activity was dominated by the Blue Crane (74 individuals) and the Cape Vulture (47 individuals) based on the 2015-2016 observations. An assessment of potential fatalities due to collisions with turbine blades concluded that the Blue Cranes and the Cape Vultures are most at risk, but significant impacts related to collisions are not expected based on flight patterns in the Project area and monitoring data from operational wind farms in South Africa.
The biodiversity consulting firm has conducted a Critical Habitat Assessment (CHA) for Excelsior in June 2019 in accordance with the PSs. The Project Area of Impact (AoI) was defined as an area comprising of site footprint itself and a 5km buffer zone around turbines, and a 2km buffer zone around the proposed 14km long 132kV grid connection powerline running from the on-site substation to the Vryheid substation. The Area of Analysis (AoA) was defined for each species and ecosystems separately.
The CHA concluded that the area where the project site is located provides a Critical Habitat for i) the Black Harriers and ii) the Cape Vultures as the AoA contains a globally important concentration of these species and both of them are congregatory species (Criteria 1a, 1c and 3); iii) Agulhas Long-billed Lark because it is a restricted range specie and the Overberg Wheatbelt IBA (AoA) provides for approximately 37% of its total distribution range (Criterion 2); iv) the Blue Crane, as the IBA sustains, on a cyclical or regular basis ≥ 1 percent of the global population of the species at any point of its lifecycle (Criterion 3); and v) the Renosterveld vegetation biomes which were determined as high priority for conservation by the South African National Biodiversity Institute in 2011 (Criterion 4b).
The site is located in the Overberg Renewable Energy Development Zone (REDZ) established as a result of the Strategic Impact Assessment (SEA). Based on the pre-feasibility assessment establishing the site elsewhere would expose the project to additional biodiversity related impacts and, therefore, no other viable alternatives within the region exist for development of the project.
To address potential impacts and achieve net gains for the biodiversity values linked to the identified critical habitats, the Client has developed a Biodiversity Action Plan (BAP) that describes measures to avoid, or where avoidance is not possible, minimize adverse impacts on the identified biodiversity values.
Measures proposed to eliminate the risk of collision for the Cape Vultures include eliminating food sources, and monitoring and timely removal of carcasses, as wells as the marking of high-risk sections of the powerline with bird flight diverters, potentially painting turbine blades if viable to enhance visibility , turbine management and shut down on demand option. Potential habitat enhancement measure for vultures will be defined after research activities proposed by the Project. They will include satellite tracking to establish the patterns of the food supply of the Cape Vultures at the Potberg Vulture Colony, investigation of land use patterns and farming practices to see how they influence the foraging behavior of the birds, e.g. the timing of lambing (as per the ESAP). The results of such research will show if there is a need for a supplementary feeding program to achieve the net gain.
Offset mitigation measures for Black Harrier are compatible with those proposed for Renosterveld ecosystems and will include habitat enhancement outside the project site. This can be achieved through cooperation with the Overberg Renosterveld Conservation Trust’s “Conservation Easement” program through assistance with implementation of Integrated Management Plans (IMPs), which include alien clearing, watercourse restoration, erosion control (sheet and gully erosion), grazing management (through fencing), ecological burning, etc.). Monitoring indicators to evaluate the success of the IMPs will include improvement of vegetation quality and the number of harrier sightings in suitable habitats.
Following the principles of the adaptive management stated in the BAP, though fatalities are not expected, the Project will develop a fatality threshold policy for Black Harrier and Cape Vulture, with input from relevant stakeholders to identify and implement further effective mitigation actions, if necessary.
The Agulhas Long- billed Lark is not a species of immediate conservation concern but it is vulnerable to natural or anthropogenic changes in its habitat. Therefore, measures to avoid habitat transformation mainly include good construction practices, i.e. minimizing construction footprint and habitat restoration after construction works. The project will also co-finance a research on the ecology of the Long-billed Lark to better understand the effective mitigation measures (as per the ESAP).
Collision mitigation measures for the Blue Cranes will mostly focus on the transmission lines since the risk of collision with the turbines is expected to be fairly low. The high-risk sections of the project powerline will be marked with Eskom approved Bird Flight Diverters (BFD’s). The routing of the powerlines follows the low risk areas and the design was also reviewed and approved by the birds monitoring specialists. The habitat displacement will be avoided by the active search for the Blue Crane nests by the team of environmental monitors and by strictly following the construction HSE plans. The project will also conduct a survey of the transmission lines in the project AoI that are not associated with the project to define the high- risk sections and potential risks. The recommendations in the survey will be communicated to the entities who are in control of the powerline (as per the ESAP).
Following the successful implementation of the BAP, the Project is not expected to lead to measurable adverse impacts on identified biodiversity values, neither will it lead to a net reduction in the global and/or national/regional population of any Critically Endangered, Endangered or Vulnerable species over a lifetime of the Project. The Project will ensure that the principles of adaptive management are reflected in the BioTherm ESMS documentation and site-specific EMPr are updated to reflect the findings of the CHA and to include the BAP items (as per the ESAP).
The Project will develop a Biodiversity Monitoring and Evaluation Program (BMEP) for operations stage. It will incorporate the BAP requirements and will include a post-construction monitoring for three consecutive years in accordance with the WBG EHS Guidelines for wind energy (as per the ESAP). Monitoring data will be utilized to evaluate the level and adequacy of mitigation measures and will be included in the annual monitoring reports (AMR) containing relevant E&S information throughout the guarantee period
Golden Valley 1
Most of the GV 1 site was heavily degraded due to its primary use as a grazing area. The project site area is covered with low sensitivity scrub grassland with scattered rocky outcrops. The site is of low botanical sensitivity and will not significantly impact natural vegetation. The area where the GV 1 is located was defined as a Cookhouse Renewable Energy Development Zone (REDZ), one of the eight REDZs in South Africa. According to the birds sensitivity maps in the SEA report developed by the government, the GV 1 site is outside of the Very High sensitivity areas. It is within the High and Medium sensitivity category. Four features are relevant to the GV 1 site following the SEA classification: most of the site falls within the 40 km buffer around the Agieskloof Cape Vulture roost (High sensitivity); the southern edge of the site contains slopes of greater than 75⁰ (High sensitivity); parts of the site fall within an area of ‘Presence data for threatened impact susceptible large terrestrial birds’ (Medium sensitivity) (these species are Blue Crane, Ludwig’s & Denham’s Bustard, & korhaans) and the western half of the site falls within the 5 km buffer around power lines (Medium sensitivity).
Independent consulting company was contracted by BioTherm in October 2017 to conduct pre-construction bird monitoring covering 12 months of observations. As a result, 12 species of concern were recorded flying on site during this period including Ludwig’s Bustard (IUCN EN), Martial Eagle (IUCN VU); Secretarybird (IUCN VU), Blue Crane (IUCN VU)), Denham’s Bustard (IUCN NT) and one species which is regionally endemic, the Jackal Buzzard (IUCN LC).
The consultant also conducted a CHA study in June 2019. AoI for GV1 was determined to be the GV1 site itself and a 5 km buffer around its outer boundary and 2 km buffer on either side of the grid connection power line (6.5 km long). Based on the CHA none of the species have met a quantitative threshold to qualify the project area of impact as Critical Habitat for the key biodiversity values. The project site is located in the natural habitat for the identified species of concern. The seasonal non-breeding Cape Vulture roost site, Agieskloof is located 43 km to the north. The topography of the wider landscape suggests that vultures are more likely to be foraging regularly in the rugged and mountainous terrain north of Cookhouse, and not in the relatively flat area where project is located. Also, movement corridors are likely to be predominantly to the east of Agieskloof since it is positioned at the very western range of the population. The low frequency of vulture observations on the GV1 site suggests that the project site and its surrounds are not favored for foraging, and food may rarely be available. The project will conduct a continuous bird monitoring on site and will cooperate with other stakeholders like Endangered Wildlife Trust whose research program uses tracking devices to analyze movement of vultures (as per the ESAP).
To address potential risks of collision and displacement of birds species the Project has developed a draft Biodiversity Action Plan that describes avoidance and minimization measures, monitoring as well as additional conservation measures. Avoidance and minimization measures include conducting construction activities outside of the buffer zones of the potential nesting areas, the control over vegetation clearance and implementation of the construction management plans, control over the raptor species food supply and collaboration with farmers to improve carcass management practices, various engineering decision such as installation of static bird diverters and mobile bird flappers. The project will also develop fatality threshold policy for each priority species that would trigger additional mitigation and identify potential adaptive management actions, including a turbine shutdown on demand (SDOD) protocol and training of the key staff (as per the ESAP). The BAP states that additional conservation mitigation measures will be developed through the collaboration between the wind facilities in the Cookhouse REDZ and a continuous research into Cape Vulture movements (e.g. through satellite tagging); the role of food availability in and around the Project area and potential collision risks with transmission lines located within the project AoA (as per the ESAP).
The Project will develop an operations stage Biodiversity Monitoring and Evaluation Program (BMEP) that will reflect the BAP requirements and will include a post-construction monitoring for three consecutive years in accordance with the WBG EHS Guidelines for wind energy (as per the ESAP). Monitoring program will assess at minimum injuries or fatalities of birds or bats caused by collisions with turbines and/or power lines, presence, activity levels and nesting of bird species of concern on site, potential displacement of bird species by turbines, the effectiveness of the vulture food management program, of shut down on demand, and of bird diverters/flappers on transmission lines and a Monitoring of the Agieskloof Cape Vulture roost site. Monitoring data will be utilized to evaluate the level and adequacy of mitigation measures and will be included in the annual monitoring reports (AMR) containing relevant E&S information throughout the guarantee period. Site-specific EMPr will be updated to reflect the findings of the CHA and to include the BAP items (as per the ESAP).
[1] Used abbreviations are from the IUCN Red List Categories and Criteria as follows: EN (Endangered), VU (Vulnerable), NT (Near Threatened), LC (Least Concern).
The power plants were issued with Environmental Authorizations by the DEA in 2013. While the power plants have obtained all permits and compliance certificates required to operate, the Project continues to liaise with the DEA on an ongoing basis with regards to implementation of the EMPr. Since the EIA, the Project continues to engage with the local community on an ongoing basis, however the Project will develop and implement a SEP for the operations phase. The SEP will include the following elements: engagement principles, objectives and criteria; requisites and regulations; summary of any previous engagement activities including any documented evidence (e.g., agreements and minutes of meetings); identification, characterization and priority of stakeholders, focusing on those directly affected and identifying any vulnerable individuals or groups; engagement program including indication of how interactions should be formalized (e.g., agreements and acknowledgment of receipt of information); description of grievance redress mechanisms; list of time-bound activities; and resources and responsibilities (as per the ESAP).
Broad Community Support (BCS) is not required for this project.
The following documentation is available electronically as PDF attachments to this ESRS at www.MIGA.org:
- Environmental Impact Assessment (EIA) for the proposed BioTherm Wind Energy Project (Excelsior) near Swellendam: Final EIA Report, prepared by CSIR in April 2011
- Excelsior Environmental Management Program (EMPr) prepared by Savannah Environmental (Pty) Ltd. in December 2016.
- EIA: Proposed Amstilite (RF) Proprietary Limited Golden Valley Wind Energy Project – Phase/Project 1, Blue Crane Route Local Municipality, Cookhouse. Volume 3: Environmental Impact Assessment Report prepared by EOH Coastal & Environmental Services in February 2016
- Golden Valley Environmental Management Program (EMPr) originally prepared in October 2010 and updated in December 2015 by EOH Coastal & Environmental Services
- Excelsior Wind Farm Critical Habitat Assessment prepared by Chris van Rooyen Consulting in July 2019
- Golden Valley 1 Wind Farm Critical Habitat Assessment for Avifauna prepared by WildSkies Ecological Services (Pty) Ltd in July 2019
- Excelsior Wind Farm: Biodiversity Action Plan (draft) prepared by Chris van Rooyen Consulting in August 2019
- Golden Valley 1 Wind Farm Biodiversity Action Plan (draft) prepared by WildSkies Ecological Services (Pty) Ltd in August 2019
It is also available for viewing at the following locations:
BioTherm Energy (Pty) Ltd.
Building 1, Ground Floor,
Leslie Avenue East,
Design Quarter District, Fourways,
South Africa.
Contact: Libby Hirshon, Environment Social and Governance Director, LHirshon@biothermenergy.com
MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities.
In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of MIGA.
Independent of MIGA management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of MIGA’s environmental and social performance through its compliance arm.
Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing to the address below:
Compliance Advisor/Ombudsman
International Finance Corporation
2121 Pennsylvania Avenue NW Room F11K-232
Washington, DC 20433 USA
Tel: 1 202 458 1973 Fax: 1 202 522 7400
E-mail: cao-compliance@ifc.org