ACWA Power Sirdarya
Environmental and Social Review Summary
ACWA Power Sirdarya
This Environmental and Social Review Summary (ESRS) is prepared by MIGA staff and disclosed prior to the date on which MIGA’s Board of Directors considers 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 MIGA’s Board of Directors. Board dates are estimates only.
Any documentation that 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.
MIGA has been requested to provide guarantees covering non-shareholder loans by Standard Chartered Bank, Bank of China Limited, Industrial and Commercial Bank of China Limited, China Construction Bank Corp. and China Minsheng Banking Corp., and/or potentially other lenders yet to be identified, jointly referred to as “Lenders”, into the construction and operation of a 1,500 megawatt (MW) greenfield combined-cycle gas turbine (CCGT) power plant in the Sirdarya region of Uzbekistan (“Project”). Further information on the proposed MIGA guarantees is available in the Summary of Proposed Guarantee.
The Project will be developed by ACWA Power through ‘ACWA Power Sirdarya LLC’ (the “Project Enterprise” or “PE”), a company registered in the Republic of Uzbekistan specifically for the development of the Project. The Project is located approximately 1.9 kilometer (km) northeast of the city of Shirin, a border town on the Uzbekistan/Tajikistan border. The location is close to the existing Sirdarya Thermal Power Plant (a 3,000 MW oil/gas power plant), and adjacent to another site that has been identified for the development of a separate 1,500 MW CCGT, which is being developed with advisory support from IFC (hereafter referred to as ‘the IFC project’).
The Project will include the design, construction and operation of (i) 1,500 MW CCGT, utilizing 2 gas turbines; 2 heat recovery steam generators ; and 1 steam turbine; (ii) induced draft wet cooling towers; (iii) 500/220 kilovolt (kV) switchyard and substation (which will be a common facility with the adjacent IFC project); (iv) gas connection to the existing gas supply station; (v) wastewater treatment plant; water intake and outfall; and (vi) administrative buildings. The switchyard will be constructed by the Project, and then transferred to JSC National Electric Networks of Uzbekistan. Associated Facilities (as defined in Performance Standard 1) include: (i) an overhead transmission lines; (ii) approximately 2 km spur gas pipeline and (iii) a less than 2 km access road. The details of the transmission lines are still under investigation, but it is understood that the transmission lines for the Project will part of a comprehensive grid enhancement to support the development of both the Project and the IFC project. There are currently 2 transmission line corridors (one 500 kV and another 220 kV) on either side of the Project site, and it is expected that at least some of the lines to be constructed will be short lines connecting the Project substation to these existing lines. Other transmission lines under consideration include an approximately 100 km 500 kV line from the Project substation to a substation near Tashkent and a 220 kV line to a nearby industrial site. LSC National Electric Networks of Uzbekistan (NENU, the off-taker) will be responsible for design, construction, operation and maintenance of the transmission lines. The access road will be constructed by the Engineering, Procurement and Construction (EPC) contractor as part of Project construction. Fuel will be supplied by JSC National Electric Networks of Uzbekistan and JSC Uztransgaz, and JSC National Electric Networks will be responsible for construction of the spur pipeline.
Two units at the existing Sirdarya Thermal Power Station have reached the end of life and are in the process of being decommissioned. Once the Project is commissioned, a further 2 units will be decommissioned. The remaining 6 units are being progressively modernized (with 2 being modernized last year, 2 this year and the final 2 scheduled for next year). The intention is for the remaining 6 units to remain on standby only to be used at peak times or during planned or unplanned outages of the Project and IFC project.
The Project will be developed on an 84 hectare (ha) site (including the switchyard), which the government has allocated to the PE for the purpose of the development of the Project. The land is currently in use by local farmers for rice and vegetables cultivation, in addition to irrigation ditches and fruit trees. The land around the site is also primarily farmland, though there are several residential areas within 2 km of the site boundary with the closest being farmer houses located approximately 200 meters from the boundary. The Project is separated from the existing Sirdarya Thermal Power Plan by the Yuzhny-Golodnostepsky (YG) canal, which will be used to supply water for the Project.
China Gezhouba Group International Engineering Co. Ltd. has been engaged as the Engineering, Procurement and Construction (EPC) contractor and First National Operation and Maintenance Co. Ltd. has been selected as the Operations and Maintenance (O&M) contractor. Construction is anticipated to commence in 2021 and take approximately 2 and a half years to achieve commercial operations of the open cycle gas turbines and approximately 3 years to reach commercial operations of the combined cycle.
The Project is categorized as Category A according to MIGA’s Policy on Environmental and Social Sustainability (2013) because it includes activities with potentially significant adverse environmental or social risks and/or impacts that are diverse, irreversible, or unprecedented. Key risks and impacts include economic displacement, air emissions (including greenhouse gases); noise; water resource use and occupational and community health and safety. There are also potential cumulative impacts associated with the potential continued operation of some units at the existing Sirdarya Plant and the construction and operation of the adjacent IFC project.
While all Performance Standards 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
PS5: Land Acquisition and Involuntary Resettlement
The Environmental and Social Impact Assessment (ESIA) determined that the Project site is heavily modified habitat with very little flora and fauna, and the YG canal is of low ecological value. The ESIA concludes that effects upon biodiversity will not exceed minor with the application of standard mitigation measures, and therefore, PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources does not apply.
The potential presence of Indigenous Peoples was assessed in the ESIA, which determined that there were no ethnic or cultural groups within the Project area that meet the PS7 definition of Indigenous Peoples. Therefore, PS7: Indigenous Peoples does not apply to the Project.
The risk of encountering cultural heritage during works is considered relatively very low; and therefore, PS8: Cultural Heritage doesn’t apply, but nonetheless, a Chance Find Procedure will be prepared.
In addition, the following World Bank Group Environmental, Health, and Safety (WBG EHS) Guidelines are applicable to the Project:
General EHS Guidelines (2007)
EHS Guidelines for Thermal Power Plants (2008)
EHS Guidelines for Electric Power Transmission and Distribution (2007)
The following documents were reviewed by MIGA:
WSP. Environmental & Social Due Diligence Assessment. Sirdarya CCGT, Uzbekistan: 1,500 MW CCGT. September 2020
5Capitals. Environmental & Social Impact Assessment Non-Technical Summary (Volume 1). ACWA Power Sirdarya 1,500MW CCGT Power Plant (IPP), Republic of Uzbekistan. October 2020
5Capitals. Environmental & Social Impact Assessment Main Text (Volume 2). ACWA Power Sirdarya 1,500MW CCGT Power Plant (IPP), Republic of Uzbekistan. October 2020
5Capitals. Framework for Environmental & Social Management (Volume 3). ACWA Power Sirdarya 1,500MW CCGT Power Plant (IPP), Republic of Uzbekistan. October 2020
5Capitals. Environmental & Social Impact Assessment Appendices (Volume 4). ACWA Power Sirdarya 1,500MW CCGT Power Plant (IPP), Republic of Uzbekistan. August 2020
5Capitals. Stakeholder Engagement Plan. ACWA Power Sirdarya 1,500MW CCGT Power Plant (IPP), Republic of Uzbekistan. October 2020
5Capitals. Livelihood Restoration Framework. ACWA Power Sirdarya 1,500MW CCGT Power Plant (IPP), Republic of Uzbekistan. October 2020
5Capitals. Livelihood Restoration Plan: Terms of Reference. ACWA Power Sirdarya 1,500MW CCGT Power Plant (IPP), Republic of Uzbekistan. June 2020
Due to the Coronavirus Disease 2019 (COVID-19) travel restrictions, MIGA was not able to undertake a due diligence site visit. In addition to reviewing the above documents, MIGA carried out virtual environmental and social (E&S) due diligence in October 2020, which included meetings with key E&S staff and management, and regulatory authorities. Virtual meetings with affected communities will be held at the end of October or in early November. In addition, an Independent E&S Consultant (IESC) has been engaged by Project lenders to review the E&S aspects of the Project against the Performance Standards and the European Bank for Reconstruction and Development’s (EBRD) Performance Requirements. As part of the lenders’ due diligence, the IESC reviewed relevant E&S and technical documents and undertook a visit to the Project site in September 2020.
MIGA’s due diligence review considered the environmental and social 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 period, are summarized in the paragraphs that follow and in the E&S 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 issues associated with the Project business activities are summarized in the paragraphs that follow.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Assessment and Management System:
The Project Sponsor, ACWA Power, has a corporate level Health, Safety, Security and Environment (HSSE) Management System, which is in line with the requirements of PS1. The HSSE management system is designed to facilitate consistent and structured HSSE management for all ACWA Power projects. As part of the ESIA, a framework E&S Management System (ESMS) has been prepared for the Project, which is aligned with the applicable elements of the ACWA HSSE Management System. The PE will use the framework ESMS to develop a Project specific ESMS, which shall mirror the corporate structures and benchmarks established in the ACWA Power corporate HSSE management system (ESAP).
The framework ESMS has been developed to establish systematic structures and programs for the management of E&S risks, impacts, opportunities and compliance associated with construction, commissioning and operational phases of the Project. Through the E&S requirements in their contracts, the EPC and O&M contractors will be required to develop and implement Project-specific ESMSs for the construction and operations phases of the Project, respectively (ESAP).
ACWA Power has an established HSSE and CSR Policy, which will be adapted by the PE as part of the Project-specific ESMS (ESAP). The policy will be signed by the Chief Executive Officer of the PE and displayed at site. The EPC and O&M contractors will either develop their own Project-specific policies for construction and operation, which will be consistent with ACWA corporate policies and the PE’s Project-specific policies or will adopt the PE’s Project-specific policies as part of their ESMSs.
Identification of Risks and Impacts:
Thermal power plants with a capacity greater than 300 MW, such as this Project, are considered “Category 1 – High Risk” requiring a comprehensive Environmental Impact Assessment (EIA) process according to the Uzbekistani regulation. The Uzbekistan National EIA process comprises three stages (Stage 1 Preliminary Statement of Environmental Impact; Stage 2 Statement of Environmental Impact; and Stage 3 Statement of Environmental Consequences). The Project’s Statement of the Environmental Impact (which fulfilled the requirements of Stage 1 and Stage 2) was submitted to the State Committee on Ecology and Environmental Protection on 23rd June 2020 and approved on 22nd July 2020. In line with national laws and regulations, the Project will obtain the necessary licenses, consents and permits (e.g. construction permits; water use permits), including the Stage 3 approval, prior to commencing the activities for which the permits are required (ESAP).
In order to meet lenders’ requirements, the PE engaged an independent consultant to undertake an Environmental and Social Impact Assessment (ESIA) in line with national environmental requirements, EBRD’s Performance Requirements and the Performance Standards. The ESIA process commenced in October 2019, and a draft ESIA was completed in August 2020. The ESIA included consideration of contextual risks, such as gender-based violence, and the potential risks and impacts of Associated Facilities; though the assessments will need to be reviewed and updated once the exact footprint of these facilities is determined (ESAP). While the draft ESIA, which was reviewed by lenders, MIGA and the IESC, broadly satisfies the requirements of the Performance Standards, some gaps were identified. Key gaps included the need for a more comprehensive project description, better identification of the project area of influence and updates to the air quality dispersion modelling assessment. The consultant updated the ESIA to address these gaps, and the ESIA was finalized in October 2020 and will be publicly disclosed by the Project.
The ESIA included assessment of the potential cumulative impacts, including air quality, noise and water resource use, associated with the proposed Project, the proposed adjacent 1,500 MW CCGT project and the proposed existing Sirdarya Thermal Power Plant modernization project. The ESIA also considers the potential risks associated with climate change, such as the impacts of warming temperatures on turbine efficiency and increasing water stress related to shifts in rainfall patterns and consumptive demand. Findings of the ESIA indicate that though the project site is in a region expected to see a continual increase in water stress under unabated climate change, the impacts to operations over the 25-year project life are expected to be minimal. The plant also includes design considerations to limit the impacts from extreme weather events should they occur, including built-in tolerance for extreme rain, wind and snow loads.
With respect to contextual risks, the decommissioning of the existing Sirdarya Thermal Power Station, which is one of the main employers in Shirin, is likely to result in the retrenchment of a large number of staff. While some of the staff are likely to find new employment with the Project and the IFC project, the new plants will be significantly more labor efficient; and therefore, these two plants will not be able to employ all of the employees let go from the Sirdarya Thermal Power Project. Socio-economic surveys indicated that approximately 20% of the surveyed heads of households were unemployed and actively seeking employment, and during stakeholder engagement, the potential for employment during both construction and operations were identified by the community as expected Project benefits. While not directly related to the Project, this retrenchment presents a social risk that may affect the Project’s support from the community and implementation of livelihood restoration activities. The Project impact assessment and development of mitigation measures, livelihood restoration programs and stakeholder engagement activities will consider the potential social risks related to the retrenchment of workers from the existing Sirdarya Thermal Power Plant (ESAP).
In order to implement the mitigation and management measures established in the ESIA, the ESIA includes a framework Environmental and Social Management Plan (ESMP, October 2020) for construction, commissioning and operations phases of the Project. The construction ESMS developed by the EPC contractor will include a Construction ESMP (CESMP), which will be prepared prior to the commencement of construction (ESAP) and a separate Commissioning ESMP (CoESMP), which will be prepared prior to commissioning (ESAP). The O&M contractor will be required to prepare an Operation ESMP (OESMP) prior to the commencement of operations (ESAP).
The CESMP, CoESMP and OESMP will include plans, procedures, checklists, etc. as needed to ensure adequate implementation of the ESMS. As a minimum, the additional plans are expected to include: (i) waste management plan; (ii) occupational health and safety plan; (iii) emergency preparedness and response; (iv) hazardous materials handling and storage; (v) environmental monitoring plan; (vi) traffic management plan; (vii) security management plan; and (viii) chance find procedure (ESAP).
Once the sponsor has been identified for the adjacent IFC project, the PE will coordinate with the IFC project sponsor on the management of any shared assets (e.g. the switchyard) and in other areas of potential overlapping risk, such as labor, influx, waste and emergency preparedness and response (ESAP).
Organizational Capacity and Competency:
The PE will engage a Health, Safety and Environment (HSE) Manager who has overall responsibility for environmental and social management, compliance and implementation of the ESMS (ESAP). The Project HSE Manager will also be supported by ACWA’s HSE staff at the corporate level. During construction and operations, the PE will contractually delegate responsibility for day-to-day E&S management and compliance to the EPC and O&M contractors, respectively, and therefore the contractors will be required to have suitably qualified staff in place. The PE’s HSE team will be responsible for ensuring that the EPC and O&M are in compliance with E&S requirements, and oversight will be provided by the ACWA corporate HSE team. Roles and responsibilities for E&S staff will be outlined in the construction and operations ESMSs, but at a minimum, they are expected to include an Environment, Health and Safety (HSE) Manager (or similar) supported by a team including health and safety, environment and community liaison officers (ESAP).
Emergency Preparedness and Response:
Emergency Preparedness and Response Plans (EPRPs) will be prepared as part of the CESMP, CoESMP and OESMP, which will cover works on the Project site and along the access road (ESAP). The EPRPs will identify contingencies for a variety of potential emergency situations relevant to construction, commissioning and operations, including accidental leaks and spills, fire, vehicle accidents, natural hazards, and security events (among others). The EPRPs will also incorporate relevant recommendations of the COVID-19 Risk Assessment (see below). The EPRPs will outline the response mechanisms, roles, responsibilities, training and equipment requirements, internal and external communication mechanisms.
Monitoring and Review:
The PE, EPC and O&M will undertake regular E&S monitoring to demonstrate compliance with national environmental standards and lender requirements. E&S Monitoring Plans will be developed as part of the CESMP, CoEMP and OEMP, which will include parameters to be monitored; monitoring locations; methods and frequency of monitoring; and criteria against which compliance and performance will be assessed. The Project will also develop and implement an Environment, Health, Safety and Social Incident Reporting Procedure to maintain records of monitoring, accidents and incidents (including near misses (ESAP)).
The PE and the EPC contractor will both be responsible for day-to-day monitoring during construction, and semi-annual monitoring reports will be shared with MIGA and lenders. Independent monitoring of environment, health and safety, labor and social aspects of construction activities will be undertaken quarterly during construction (ESAP). As per national legislation, the relevant government authority will also monitor the Project at least annually. Once construction is complete, the Project will be required to submit annual E&S monitoring reports to MIGA.
Stakeholder consultations were conducted as part of the ESIA between March and June 2020 through bi-lateral meetings, official letters, calls and public consultation meetings. All in person stakeholder consultation meetings were held with appropriate COVID-19 safety measures in place, and in line with national quarantine requirements in place at the time. A second round of public consultation meetings was planned for late June and July 2020, which were cancelled due to COVID-19 travel restrictions and restrictions on large gatherings. The Project plans to undertake additional consultation meetings once restrictions are lifted. In the meantime, alternative consultation methods have been employed, such as video conferences and distribution of brochures, which summarize the ESIA process and the grievance redress mechanism. The key issues discussed during consultation meetings are summarized in the ESIA and Stakeholder Engagement Plan (SEP) (August 2020), and included questions about compensation for affected land; employment opportunities and requests for community development projects.
The Project will result in the economic displacement of 12 farmers, approximately 50 permanent farm workers and about 100 seasonal workers from the area surrounding the Project, which has a population of over 18,000 people. This impact will be mitigated through the implementation of a Livelihood Restoration Plan (LRP, refer to section on PS5) which is in the process of being developed. Once the LRP is finalized, consultation meetings will be held with affected people to ensure that there is support and community buy-in for the proposed measures. A Broad Community Support determination is not required for the Project.
External Communication, Grievance Mechanisms and Ongoing Reporting to Affected Communities
A Grievance Redress Mechanism has been prepared as part of the ESIA and was communicated to local communities during public consultation meetings and through distributed brochures.
ACWA will publicly disclose all key E&S assessment and management documents, including the Stakeholder Engagement Plan and Grievance Management Plan, on the Project website in English, Russian and Uzbek. ACWA also discloses a corporate annual sustainability report, which will include information on the Project’s performance.
Affected communities will be regularly informed of Project progress through the activities listed in the SEP.
PS2: Labor and Working Conditions
Working Conditions and Management of Worker Relationship:
The Project workforce is expected to reach approximately 2,200 workers at the peak of construction, of which, approximately 50% are expected to be sourced from the local population. ACWA is currently working with the local administration to produce a list of potential goods and services providers and employees. The construction phase is anticipated to last approximately 36 months.
During operations, the average workforce is expected to comprise approximately 40 people. ACWA will coordinate with Sirdarya Thermal Power Plan and the local administration to engage suitably qualified employees who will be let go from the plant following decommissioning (ESAP). The plant will operate 24 hours a day, 7 days a week on a three eight-hours shift schedule per day.
Human resources policies and procedures, including recruitment and training plans; performance management procedures; working conditions and terms of employment will be prepared by the PE and EPC contractor in line with the requirements of PS2 prior to the start of construction (ESAP). The policies and procedures will include reference to non-discrimination and equal opportunity, right to privacy of personal information, and right to start or join workers’ organizations. The EPC will appoint a Human Resources Manager (or similar) to ensure implementation of the human resources policies and procedures (ESAP). The O&M contractor will prepare human resources policies and procedures prior to the start of the operations phase (ESAP). The EPC contractor will also prepare a staffing plan for the construction phase of the Project, indicating the number of staff and type of jobs expected throughout the construction phase (ESAP). The staffing plan will also include a workforce demobilization plan to guide demobilization of staff at the end of the construction phase.
The PE will ensure that all employees, including contractor and sub-contractor employees will be provided with a written contract of employment prior to commencing work. The contracts will be in line with the requirements of national legislation and requirements of PS2. Contracts will specify working hours (including provisions for overtime); salary; annual leave; dismissal process; responsibilities of the employee (including responsibilities related to environment, health and safety; responsibilities of the employer and right to join trade unions. The human resource policies and procedures will be subject to periodic audit by an independent consultant (quarterly during construction) (ESAP).
It is anticipated that the EPC contractor will have temporary worker accommodation on the Project site during the construction phase. No on-site accommodation is expected for the operations phase. The EPC contractor will prepare a Worker Accommodation Plan in line with the requirements of the IFC / EBRD Worker Accommodation Guidelines (ESAP). Any sub-contractors that have temporary accommodation will be required to apply the Worker Accommodation Plan to their accommodation. The Worker Accommodation Plan will also integrate considerations from the COVID-19 Risk Assessment (see below), such as process for isolation or high-risk workers; quarantine requirements; etc.
The grievance mechanism that has been established for the local communities is also available for employees, and it provides specific mechanisms for employees to submit grievances anonymously or confidentially.
Protecting the Work Force:
Human resources policies and procedures will clearly indicate that the minimum age of employment for the Project is 18 years of age in line with the requirements of the national Labor Code (1996). Forced labor is prohibited by Labor Code, and in line with the Labor Code, the PE will ensure that employees have the right to terminate their individual contract by giving a written notice two weeks’ in advance. The CESMP will include a Worker Code of Conduct, which will include an overview of culturally appropriate measures and etiquette and will also include zero tolerance for sexual harassment and gender-based violence (ESAP).
Occupational Health and Safety:
Consideration of occupational health and safety is incorporated into ACWA’s HSSE Management System, which will be adapted for the Project-specific ESMS. For the construction phase and operations phases, the EPC contractor and O&M contractor will prepare Project-specific Occupational Health & Safety (OHS) Management Systems to address project-specific risks (ESAP). The OHS Management Systems will include as a minimum means to identify and minimize potential health and safety hazards; provision of preventative and protective measures; provision of appropriate equipment; training of workers and provision of appropriate incentives for them to comply with health and safety procedures; procedures for documentation of accidents, incidents and diseases; and emergency prevention, preparedness and response (ESAP). The PE and EPC will also undertake a COVID-19 Construction Risk Assessment prior to construction mobilization (ESAP). The findings of the risk assessment will be incorporated into the OHS Management System.
Workers Engaged by Third Parties and Supply Chain:
The EPC contractor will require its sub-contractors to develop and implement workplace rules, processes, and procedures in line with the EPC contractor’s human resources, OHS and environmental policies and procedures. The EPC contractor will also prepare a Supply Chain Management System to identify primary suppliers and ensure that OHS and other labor requirements (i.e. minimum age of employment, no forced labor) are cascaded to the primary supply chain (ESAP).
PS3: Resource Efficiency and Pollution Prevention
It is anticipated that the Project’s carbon intensity will be in the range of 338 – 343 grams of carbon dioxide equivalent per kilowatt hour (gCO2eq/kWh). This is below the World Bank Group (2008) EHS Guidelines Net Carbon Intensity Guideline (348 – 374 gCO2eq/kWh) and significantly below the average carbon intensity of power production in Uzbekistan (which is approximately 536 gCO2eq/kWh). Based on the carbon intensity and the anticipated annual generation of approximately 110,000,000 gigajoules per year, greenhouse gas (GHG) emissions are estimated to be 3,921,436 to 4,324,960 tonnes of CO2e/year. GHG emissions accounting will be undertaken on an annual basis and provided to MIGA as part of the Annual Monitoring Report.
Water will be supplied to the site via the existing YG canal, which is branched from a diversion canal of the Farkhad Hydropower Plant, which is branched from the Sirdarya River. A Water Supply Assessment Report (April 2020) was undertaken as part of the ESIA to determine whether there are sufficient water resources to supply the Project without affecting other water resource users. The study determined that the expected water abstraction for the Project (approximately 0.37 cubic meters per second (m3/s) is estimated to be approximately 0.3% of the long-term mean water flow (121.1 m3/s) and only 7.4% of the minimum recorded flow (5 m3/s). The ESIA also considered the potential impact of future climate change on water availability and determined that the potential reduction of water resources over the next 30 years is not expected to be consequential for the Project. Water abstraction for the Project is not likely to significantly affect water availability for other resource users. Project design includes a zero-liquid discharge (ZLD) wastewater treatment process to ensure that water abstraction is minimized, and water reuse is maximized within the plant. The cooling towers design has also been optimized to include cooling tower drift eliminators to minimize drift losses in line with Good International Industry Practice.
During construction, the primary emissions are of dust and particulate matter. These are expected to be addressed through mitigation measures (e.g. dust suppression; management of vehicle loads and speeds). The primary air emissions anticipated from operation of the Project comprise oxides of nitrogen (NOx) (i.e. nitric oxide (NO) and nitrogen dioxide (NO2)) and carbon monoxide (CO) emitted during the gas combustion process. There is also potential for ammonia (NH3) emissions (referred to as ammonia slip) from the proposed Selective Catalytic Reduction (SCR) process. The PE has committed to meeting the BAT guidelines established by the European Union BREF document for Large Combustion Plants (2017), which are below the emission standards in the WBG EHS Guidelines. The Project will only operate on natural gas and no provision for secondary fuel (e.g. light distillate oil or heavy fuel oil) has been made. The main point source emission point in the vicinity of the Project is the existing Sirdarya Thermal Power Plant, which primarily emits a combination of NO2, CO and occasionally SO2 to the local airshed. Regardless, due to the height of the stacks at the existing plant, the airshed at the Project site itself has minimal influence from pollutants and is not considered to be degraded. Modelling undertaken as part of the ESIA process consider the potential impact of the Project on nearby sensitive receptors, defined as residential areas, commercial premises and industrial facilities. Modelling assumed a baseline scenario where all 10 units of the existing Sirdarya Thermal Power Plant are operational; however, following the operation of the Project, it is understood that 4 units will be decommissioned and the remaining 6 will modernized and held on standby. The models also considered the operation of the adjacent IFC project, which, if it becomes operational, would start operations at least a year after the Project.
Modelling indicates that Project emissions are unlikely to have a significant impact on CO and NOx concentrations at all receptors. Predicted concentrations of NH3 arising from the Project are very low and unlikely to exceed the relevant standards. Continuous Emissions Monitoring System (CEMS) will be installed in all stacks to ensure that emissions remain within the allowable limits (ESAP).
Modelling further considered the Project emissions in addition to the operation of the 6 modernized units of the existing Sirdarya Thermal Power Station and with the operation of the proposed IFC project. When considering the Project plus the 6 modernized units of the existing Sirdarya Thermal Power Station, NOx concentrations are predicted to be compliant with applicable standards (including the WBG EHS Guidelines). For hourly and 8-hour mean concentrations of CO, there are no exceedances of the relevant standards; however, the modelling indicated that there may be exceedances of the 24-hour and monthly mean standards at certain receptors. These exceedances, however, are due to high background concentrations in the area. The impact from the emissions of the Project will be less than 1% of the standard, and therefore the impact of the Project is considered to be insignificant. When the potential emissions from the IFC project are considered, the predicted long-term NOx and CO predicted environmental concentrations are below the relevant standards at all sensitive receptors. The model identified potential exceedance of the hourly mean NO2 standard at two residential areas located approximately 8 km east of the site; however, it was considered that this was likely an overprediction due to the conservative nature of the model (i.e. it used worst-case meteorological conditions and assumed no NOx mitigation from the IFC project) and inaccuracies in applying the model in hilly terrain.
Noise will be generated from construction equipment, during the construction phase, and from turbines and cooling towers during the operations phase. Modelling undertaken as part of the ESIA process concluded that the Project noise emissions are likely to be compliant with WBG EHS guidelines at all sensitive receptors during both the construction and operations phases. If elevated noise levels are detected, then noise attenuating shelters and other mitigation will be considered. Noise modelling also considered the operation of the 6 modernized unites of the existing Sirdarya Thermal Power Project and the presence of the IFC project. In these scenarios, noise was still likely to be within the relevant WBG EHS guidelines; however, at one receptor, the increase above the baseline was just over 3 decibels, which can result in nuisance noise impacts. Depending on the final future design of the adjacent IFC project, additional mitigation measures may be required to reduce cumulative noise impacts.
As indicated above, the plant is designed to be zero discharge, and therefore, the anticipated wastewater streams from the Project are limited to sanitary wastewater, site surface water drainage and gas turbine wash water. Sanitary wastewater will be collected and treated in a dedicated sanitary treatment plan on-site. Following treatment, the treated wastewater will be used for irrigation of landscaped areas and / or discharge to the canal. Rainwater from roofs and paved areas will be collected by the plant’s storm water drainage system and discharged to the canal. Rainwater falling on potentially contaminated surfaces (such as oily drains, fuel gas area, car parking area) will be directed to an oil / water separator prior to discharge. Gas turbine washing is expected to occur approximately 4 times per year. Wastewater will be collected and pumped to tankers for off-site disposal.
Hazardous materials, which are expected to primarily include oil and fuel, will be stored in designated areas in accordance with the national requirements and standards, WBG EHS Guidelines and good practices guidelines to prevent any spillage on the site.
The Project will generate both non-hazardous wastes and hazardous wastes. Non-hazardous wastes will include general solid waste, organic food waste and packaging waste, while hazardous waste will include used generator and turbine lube oil; spent gas turbine air filter cartridges; and spent gas turbine lube-oil filter cartridges. Used oil and oily materials will be collected on site and then removed in drums for controlled disposal. Waste management plans will be developed as part of the CESMP, CoESMP and OESMP, which will apply the waste hierarchy (prevention, reuse, recycling, recovery, disposal) to develop mitigation measures (ESAP).
PS4: Community Health, Safety and Security
Community Health and Safety
The ESIA identified 3 sensitive receptors within 1 km of the Project boundary: military barracks (0.6 km); a kindergarten and sports center (0.82 km); and farmhouses (0.21 km). The Project is required to establish a 500 m health protection zone around the 2 main stacks and the switching gear. There are currently no sensitive receptors residing within a 500 m radius of the proposed stacks and switching gear.
Community health and safety issues associated with the construction and operation of the Project include unauthorized access to project sites, road safety, impacts associated with in-migration of the project workforce, impact on community water resource use and emergency situations. The site will be fenced, and security posted to prevent community access to the site. Mitigation measures identified in the ESIA include that all high-risk areas including fuel storage areas will be secured with internal fencing and will be patrolled by security throughout the day. During both construction and operations, only authorized workers will be allowed to enter the site. Road traffic accidents will be minimized through driver training, enforcement of speed limits and regular maintenance of Project vehicles. The EPC contractor will prepare a Traffic Management Plan as part of the CESMP (ESAP).
The EPC will prepare an Influx Management Plan to address the potential migration to the Project area (ESAP). The plan will include consideration of gender-based violence, anti-social activity and the transfer of communicable diseases including sexually transmitted illnesses and COVID-19. As indicated in previous sections, human resource policies and procedures will include a Code of Conduct, which will include rules for interaction with local communities. In addition, the PE will prepare a Community Response Action Plan, which will define the site action to support community stakeholders, including local health authorities, in planning, responding and recovering from outbreaks such as COVID-19 (ESAP).
As discussed in the section above, water abstraction for the Project is not expected to affect community water resource use. Appropriate mechanisms for emergency control (e.g. well-equipped firefighting equipment) will be placed at suitable positions around the site. The Project EPRP will include measures to prevent impact on community health and safety, and mechanisms to ensure communication with other nearby power plants, local leaders and emergency services in case of an emergency.
During construction, the EPC contractor will engage a private security contractor to provide 24/7 security, and during operations, the PE will engage site-based security. Other security measures will include fencing of the site; use of Closed-Circuit TV (CCTV); pre-approval of vehicles permitted to enter the site; and restricted access to construction workers with valid ID cards. The EPC contractor will undertake a Security Risk Assessment, and a Security Plan will be prepared to address any findings of the risk assessment (ESAP). The plan will be aligned to the UN Code of Conducts for law enforcement officials, the IFC’s Good Practice Handbook on the Use of Security Forces: Assessing and Managing Risks and Impacts and the UN Basic Principles on the use of Force and Firearms by law enforcement officials (where firearms are in use).
PS5: Land Acquisition and Involuntary Resettlement
The Project will be constructed on 84 ha of land (for both the Project footprint and the switching station) which is currently used for farming and livestock grazing. The Project will also be required to reroute a series of irrigation ditches and canals that provide water to adjacent farms. In Uzbekistan, agricultural land is owned by the State, which leases the land to residents for use. Leases can be terminated at any time by the Government or by lessees but is considered voluntary when terminated by lessees and compulsory when terminated by the Government. National legislation provides detailed processes for termination of lease agreements and required compensation.
As per the conditions of the Power Purchase Agreement, the Government is responsible for acquiring the land and allocating it to the PE for construction and operation of the Project. The land for the Project was identified by the Ministry of Energy, which, in January 2020, requested the Sirdarya Regional administration to begin the process of returning the land to the State. The Sirdarya Regional administration, then, through the Bayavut District and Shirin town administrations, issued lease termination letters to affected farmers in January and February 2020. The lease termination letters included the reason for terminating the lease (i.e. construction of a new thermal power plant with a capacity of 1500 MW), general provisions, including whether an entire land holding or only part of the landholding was being withdrawn, and conditions for returning the land. The next step is the valuation and compensation process, which is currently being undertaken.
The Project footprint and switchyard will require the economic displacement of 12 farmers: 8 farmers with legal lease agreements; 1 farmer without a legal lease agreement; and 3 farmers who are renting land from 1 of the 8 farmers with legal lease agreements. In addition, the farmers engage seasonal and permanent workers (approximately 200 workers), often family members or relatives to work on the farms, some of whom will also be economically displaced. Also, a small amount (approximately 1.24 ha) of the affected land (the area required for the water intake and outfall) is owned by Shirin Municipality.
With regards to the associated facilities, 2 farmers who are already affected by the Project footprint will also be affected by the routing of the gas pipeline and the construction of the access road. The Project access road will also affect 5 farmers, who are also affected by the Project footprint. As the routing of the transmission lines is still under consideration, the number of farmers and amount of land potentially be affected by the transmission lines are still being assessed. People affected by the construction of the transmission lines for the Project are considered in the Livelihood Restoration Framework (LRF) and will be entitled to compensation and access to livelihood restoration programs.
Temporary economic displacement impacts have also been identified. The water intake and outfall construction will temporarily disrupt gas supply to a gas station, which is likely to cause temporary loss of income for the gas station and its 18 employees. This impact is likely to be short-term, and the gas station and employees will be compensated based on the number of days the gas supply is disrupted. The Project will also be required to reroute irrigation canals that currently cut through the site. Water flow to adjacent farmland may be temporarily disrupted while the Project reroutes these canals. The Project proposes to reroute affected irrigation canals during the winter to minimize any impact on crops. Mechanism for measuring and compensating any impact from disruption of irrigation canals will be included in the Livelihood Restoration Plan (LRP).
As mentioned above, the Project is required by national law to establish a 500 m health protection zone around the main stacks and switching gear. The Project is currently seeking guidance on the implementation of this health protection zone, but it is currently anticipated that it will not requirement any physical or economic displacement. Initial feedback from the government has indicated that farming activities are permitted within the zone. If farming is not permitted, 8 of the already affected farmers will lose additional land and 1 additional farmer will be affected. Farmers and farm workers affected by the establishment of the health protection zone will be entitled to compensation and access to livelihood restoration as per the entitlement matrix in the LRF.
Affected farmers within the Project footprint and switchyard received Termination of Land Lease Agreement letters from the Bayavut District and Shirin town administrators in February 2020 and January 2020, respectively. The Bayavut District further followed up with letters in May 2020 requesting that farmers not plant any further crops.
A LRF (October 2020) was prepared as part of the ESIA, which describes the process for development of a LRP. The LRF indicates that compensation for the affected land has yet to be determined, and the Project is in the process of coordinating with the local authorities to determine whether suitable replacement land will be available for affected farmers. Local authorities have initially identified replacement land that is over 50 km from the Project area, which local farmers indicate is too far from their homes. A full inventory of losses, entitlement matrix (including an indication of whether replacement land will be available) and compensation calculation methodology will be provided in the LRP (ESAP). The LRP will also propose livelihood support programs and provide measures to address impacts on vulnerable groups. The LRF and Terms of Reference for the LRP indicate that it will be prepared in line with the requirements of PS5 and EBRD’s Performance Requirements.
As discussed previously, a Project-level grievance mechanism has been established to allow affected people to submit grievances, including those arising from acquisition of land and disruption of livelihoods. Evidence to date indicates that the grievance mechanism is functioning as designed, as the Project has already received and responded to a number of grievances related to land acquisition.
Private Sector Responsibilities under Government-Management Resettlement:
As indicated above, the Project has committed to ensuring that land acquisition is undertaken in line with the requirements of PS5, and to this end is supporting the Government with the development of a PS-5 compliant LRP. The LRF includes a gap analysis between national requirements and the PS and identifies measures to address the identified gaps. The measures will be incorporated into the LRP.
A Broad Community Support determination is not required for the Project.
The documentation listed below is available electronically as PDF attachments to this ESRS at www.miga.org.
5Capitals. Environmental & Social Impact Assessment .ACWA Power Sirdarya 1,500MW CCGT Power Plant (IPP), Republic of Uzbekistan. October 2020
The above documentation is also available for viewing at the following locations:
Local physical addresses, contact name and telephone:
International Business Center Block-A, 13th Floor 107-B, Amir Temur Avenue Tashkent, 100084, Uzbekistan // Sherzod K. Onarkulov // T + 998 71 238 9960 M + 998 90 003 9960
Contact details of sponsor for public enquiries related to environmental or social issues:
Bernardo Del Castillo (BDelCastillo@acwapower.com)
Hicham El Maanouni (firstname.lastname@example.org) / +971 278 3001
Contact details of sponsor for general public enquiries.:
Tom Teerlynck (TTeerlynck@acwapower.com)
Hicham El Maanouni (email@example.com) / +971 278 3001
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:
International Finance Corporation
2121 Pennsylvania Avenue NW
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400