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Bash Wind Farm Project

$332.5 million
Environmental and Social Review Summary

Environmental and Social Review Summary

Bash Wind Power Project

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 and other lenders, yet to be identified, into the Bash wind farm Project (referred to hereafter as “the Project”). The Project involves the design, construction, operation and maintenance of a 500 megawatt (MW) wind farm and the construction of a 162 kilometer (km) 500 kV overhead transmission line (OHTL) in the Bukhara region of Uzbekistan. Further information on the proposed MIGA guarantees is available in the Summary of Proposed Guarantee. The proposed tenor of the guarantee is up to 20 years.

The Project will be developed by ACWA Power (ACWA or the Project Sponsor) through ‘FE ACWA Power Bash Wind LLC’ (the Project Enterprise (PE), or ACWA Bash), a company registered in the Republic of Uzbekistan specifically for the development of the Project.

The Project will consist of 79 wind turbine generators (WTGs), each with a capacity of 6.5 MW linked to an onsite 500 kilovolt (kV) switchyard. The proposed WTG model for the Project is the Envision Energy with a hub height of 100 meters (m) and a rotor diameter of 171 m. The Bash wind farm will be connected to the national grid via a 162 km single circuit 500 kV OHTL, 85 meter right-of-way (RoW) that will run from an onsite substation (Bash substation, to be built) to the existing Karakul substation (Bash-Karakul OHTL), located south of the Bash wind farm. The Bash-Karakul OHTL will be funded and constructed by the Project Enterprise. During operations the OHTL will be transferred to the National Electric Grid Uzbekistan (NEGU). The Bash-Karakul OHTL is considered a component of the Project (over which the PE has full control) during construction, and then an Associated Facility, over which the PE will have no control and only limited leverage, during operations and maintenance (O&M). The Karakul substation will be expanded by NEGU to accommodate the Bash-Karakul OHTL. The Karakul substation expansion is considered an Associated Facility to the Project over which the PE will have limited control and leverage.

Additional components of the Project under the responsibility of the PE include: (i) ancillary facilities including office buildings (security, administration, control room among others), warehouses, stores and laydown area; (ii) internal access roads 6 m wide between turbines, approximately 80 km in total; (iii) electrical connection facilities comprising a 500kV switchyard and the 33/500kV substation that will connect Bash wind farm to the single circuit 500kV OHTL. Temporary construction related components located onsite include: (i) concrete batch plant; (ii) workers accommodation camp that is expected to house the Project Enterprise and Engineering, Procurement and Construction (EPC) contractor staff and (iii) contractor laydown areas. The Project site is accessed through an existing 27.5 km external unpaved access road from A-397 highway, some minor maintenance works are anticipated. The access road will be used for delivering equipment and materials, transporting employees, and transferring waste.

The Project site is located in Gijduvan district of Bukhara region, approximately 0.5 km east of Lake Ayakagitma (an Important Bird Area (IBA) and Key Biodiversity Area (KBA)) in the Kyzylkum desert. The Project was allocated an area of 285.1 hectares (ha) however the wind farm footprint is expected to comprise of approximately 178 ha. The landscape of the project site is predominantly open desert with low lying shrub and grass vegetation. The site is surrounded by cliffs on the western side that slope towards Lake Ayakagitma. The area supports breeding and resident populations of vultures and raptors that are of international and national conservation significance.

The area is sparsely populated with three villages located in the vicinity of the Project but none within the Project site. The villages include: Kuklam (1.6 km); Ayakagitma village (4.6 km) and Chulobod village (10 km). The project site is used primarily for grazing. The Project site was allocated to Kokcha LLC which is an entity under the Committee for the Development of Sericulture and Wool Industry, for the production and sale of livestock products, predominantly Karakul sheep.

There is also some existing infrastructure on site, which will not be affected by the construction and operation of the Project, including a gas pipeline in the southern section of the site operated by Asia Trans Gas, a railway line with a small railway station in the northwest section of the site connecting the city of Navoi to Zarafshan, 10 kV communication lines running parallel to the railway line under the management of Uzbekistan Railway Authority and three 220 kV OHTLs running through the north central area of the site under the responsibility of NEGU. There are also two mining areas located approximately 1km west (inactive mine, expected to resume operations in 2022) and 1.4 km east (active mine) from the Project site. The Bash-Karakul OHTL route crosses six districts - Gijduvon, Shofirkon, Peshku, Romitan, Jondor and Karakul within the Bukhara region and is located mainly within desert landscape with some areas of agricultural land; six separately owned farms are located along the route.

In addition to the Bash wind farm Project, ACWA is also developing the Dzhankeldy wind farm (which MIGA is also supporting) approximately 94 km northwest of the Bash site. For more information on the Dzhankeldy wind farm project, refer to the disclosed ESRS. Although Bash and Dzhankeldy wind farm projects are independent from each other, the two projects will share the Bash 500kV substation that will be equipped with section disconnectors to allow for independent project implementation of the Bash and Dzhankeldy projects and operation by the individual Bash and Dzhankeldy Project Enterprises. The Dzhankeldy – Bash 500 kV OTHL is approximately 128 km running from Dzhankeldy wind farm to the Bash substation (assessed as a component of the Dzhankeldy wind farm project).

ACWA is a Saudi Arabia-based developer, investor and operator of power generation and desalinated water plants with 59 assets in operation, construction, or in advanced development across a dozen countries. It is expected that construction will occur from 2022 to 2024. The Engineering, Procurement and Construction (EPC) contractor is yet to selected.  The operations and maintenance activities of the Wind Farm will be undertaken by The First National Operations and Maintenance Company Ltd. (NOMAC), a wholly owned subsidiary of ACWA Power. The OHTL will be operated and maintained by NEGU.



The Project is classified 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 associated with the construction and operation of the Project includes the development and implementation of an effective environmental and social management system at the PE level, labor and working conditions (including Occupational Health and Safety, potential COVID-19 impact, contractor management, and influx of workers); water consumption and management, biodiversity (the project is located approximately 0.5 km from an IBA and KBA), resettlement (physical and economic displacement), community health and safety, and impacts on cultural heritage sites.

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
  • PS6:  Biodiversity Conservation and Sustainable Management of Living Natural Resource
  • PS8:  Cultural Heritage

There will be no impacts related to PS7 Indigenous Peoples, thus it will not apply for this Project.  The potential presence of Indigenous Peoples was assessed in the Project’s Environmental and Social Impact Assessment (ESIA), which determined that none of the ethnic groups present in the area (Kazakhs, Tajiks, Turkoman and Kirgiz) meet the PS7 definition of Indigenous Peoples. 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 Wind Energy (2015)
  • EHS Guidelines for Electric Power Transmission and Distribution (2007)

Other Applicable Standards

  • IFC & EBRD Worker’s Accommodation, Processes and Standards (2009)

The following documents were reviewed by MIGA:

  • RINA. Environmental and Social Gap Analysis Report – Bash Wind Power Project Uzbekistan, June 2022.
  • 5 Capitals, Bash 500 MW Wind Farm Republic of Uzbekistan, Potential Biological Removal Analysis, June 2022
  • 5 Capitals, Bash 500 MW Wind Farm Republic of Uzbekistan, Collision Risk Management Plan (CRMP), June 2022
  • 5 Capitals, Bash 500 MW Wind Farm Republic of Uzbekistan, Resettlement Action Plan, May 2022
  • 5 Capitals, Bash 500 MW Wind Farm Republic of Uzbekistan, Stakeholder Engagement Plan, May 2022
  • 5 Capitals, Bash 500 MW Wind Farm Republic of Uzbekistan, Environmental and Social Impact Assessment (ESIA) Volumes 1-4, May 2022
  • 5 Capitals, Bash 500 MW Wind Farm Republic of Uzbekistan, Critical Habitat Assessment Stage 1-3, May 2022
  • 5 Capitals, Bash 500 MW Wind Farm Republic of Uzbekistan, Post Construction Fatality Monitoring Plan, April 2022
  • 5 Capitals, Bash 500 MW Wind Farm Republic of Uzbekistan, Flora Conservation Action Plan, April 2022
  • 5 Capitals, Bash 500 MW Wind Farm Republic of Uzbekistan, Pre-construction survey and relocation protocol, March 2022
  • 5 Capitals, Bash 500 MW Wind Farm Republic of Uzbekistan, Reptile Relocation Plan, April 2022
  • 5 Capitals, Bash 500 MW Wind Farm Republic of Uzbekistan, Biodiversity Chance Find Procedure Protocol, March 2022
  • ACWA Power, Code of Conduct and Ethics Policy, December 2021
  • Human Resources Manual, Employment Handbook ACWA Power Uzbekistan, January 2021
  • Environmental and Social Management System Implementation Manual, ACWA Power, January 2021
  • Construction Projects, HSSE Management Manual, ACWA Power, January 2021
  • Health, Safety, Security, Environment and Social (HSSE) Management System Framework, ACWA Power, September 2018

In addition to reviewing the above documents, MIGA carried out environmental and social (E&S) due diligence in June 2021, which included meetings with key Project E&S staff and management, and regulatory authorities followed by a site visit in June 2022 where MIGA participated in the public consultation meetings with affected communities held by ACWA’s ESIA consultant and visited the Project site. In addition, an Independent E&S Consultant (IESC) has been engaged by Project lenders to undertake E&S due diligence and review the E&S aspects of the Project against the Performance Standards, the European Bank for Reconstruction and Development’s (EBRD) Performance Requirements and Asian Development Bank (ADB) Safeguard Policy Statement. 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 March and June 2022.

Contextual risk screening was conducted, including utilizing a gender risk assessment tool to screen the project for gender-related risks (refer to the Performance Standard 2 and 4 section below for more detail) and a high-level contextual risk screening conducted at the country level. Contextual risks identified that are considered high include water stress/shortages, labor and working conditions (potential for forced labor and gender inequality).

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 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 environmental and social (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 (& social) (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, an E&S Management System (ESMS) framework was prepared for the Project, which is aligned with the applicable elements of the ACWA HSSE Management System.  The PE will use the ESMS framework to develop a Project-specific ESMS, which shall mirror the corporate structures and benchmarks established in the ACWA Power corporate HSSE management system outlined in ACWA’s Environmental & Social Management System Implementation Manual and in line with PS 1 requirements (ESAP #1). The ESMS shall include as a minimum: (i) Project specific E&S Policy; (ii) E&S governance structure including organizational capacity, responsibilities and competence for the implementation of the ESMS; (iii) reference to E&S management plans and procedures associated with the Project; and (iv) respective timeframe and budget for the development and implementation of the management plans and procedures.

The ESMS framework prepared as part of the ESIA, was developed to establish systematic structures and programs for the management of E&S risks, impacts, opportunities, and compliance associated with construction and operational phases of the Project and provides an outline of requirements of the Construction Environmental and Social Management Plan (CESMP) and Operations Environmental and Social Management Plan (OESMP) and various supporting management plans, that the  EPC and O&M contractors  will be required to develop and implement for the construction and operations phases of the Project, respectively (ESAP #2).

Policy: ACWA Power has an established E&S Policy, which will be adapted by the PE as part of the Project-specific ESMS (ESAP #1). 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 adopt or develop their own Project-specific policies for construction and operation. 

Identification of Risks and Impacts: According to Uzbekistan’s national legislation, wind power plants with a capacity of or greater than 500 MW, such as this Project, require an Environmental Impact Assessment (EIA). The Project EIA was submitted to the State Committee on Ecology and Environmental Protection (SCEEP) and was approved in September 2021. In addition, the Project will obtain the required licenses, consents and permits (e.g. construction permits; water use permits, No Objection Certificate (NOC) by Civil Aviation Authority and Ministry of Defense), prior to commencing any activities for which the permits are required (ESAP #3). 

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 requirements, EBRD’s Performance Requirements, and the Performance Standards. The ESIA process commenced in March 2021, and a draft ESIA was completed and disclosed in May 2022 on ACWA Power’s website, MIGA early disclosure, EBRD and ADB websites. Based on MIGA and lenders’ review, the ESIA is in line with the requirements of PS 1; however, some gaps were identified. These relate to biodiversity (incorporating results from additional biodiversity surveys, additional consideration on bats and respective mitigation measures), supply chain assessment, among others and to take into account comments received during disclosure and public consultation. The draft ESIA will be updated and finalized to address gaps identified (ESAP#4).

The ESIA included an assessment of the potential cumulative impacts on valued environmental and social components (VECs), these included biodiversity, air quality, noise and vibration, socioeconomics (related to job creation) and community health and safety, associated with the proposed Project, the proposed 500 MW Dzhankeldy wind power project and two existing adjacent mining sites. The cumulative impact assessment will be updated in the ESIA to consider groundwater and surface water use during construction or operations (ESAP #4).

The ESIA also considers the potential risks associated with climate change, such as warming temperatures and increased flooding. ESIA findings indicate that the potential climate change impacts to the Project during operations and throughout the project life are expected to be minimal. The Project has been sited in an area with minimal flood risks. In addition, the Project design considers the potential impacts of extreme weather events should they occur, including tolerance for extreme rain, wind and snow loads. 

Management Programs: As mentioned above, the ESIA includes an ESMS framework for construction and operation phases of the Project in order to implement the mitigation and management measures established in the ESIA. The EPC contractor will develop a CESMP prior to the commencement of construction and the O&M contractor will develop an OESMP prior to the commencement of operations in line with Project Specific ESMS (ESAP #2). During construction and operations, the CESMP and OESMP will be implemented by the EPC and O&M contractor and their subcontractors respectively with oversight from PE. The CESMP and OESMP will include roles and responsibilities and supported by plans, procedures, checklists, etc as needed to ensure adequate implementation of the ESMS. As a minimum, the additional plans are expected to include: (i) biodiversity action plan; (ii) occupational health and safety plan; (iii) emergency preparedness and response; (iv) waste management plan; (v) hazardous material management plan; (vi) water management plan; (vii) E&S monitoring plan; (viii) traffic and transportation management plan; (ix) security management plan;  (x) cultural/ archaeological management plan including a chance find procedure; xi) gender-based violence and harassment  (GBVH) Prevention & Response Action Plan; xii) supply chain management plan and others.  The PE will work together with ACWA Dzhankeldy to mitigate and manage E&S risks of shared assets (e.g. the switchyard) and potential overlapping risks, such as labor, influx, waste and emergency preparedness and response in a coordinated manner as much as possible.  

Organizational Capacity and Competency: ACWA Power has a HSSE organizational structure at the corporate level. ACWA’s ESMS implementation manual describes minimum competencies for a Health, Safety and Environment (HSE) manager for both the PE and the EPC contractor, an HSE engineer and includes requirements for the appointment of on-site management personnel responsible for social issues (e.g. social manager, community liaison officer (CLO)). The PE will appoint an E&S Manager who has overall responsibility for environmental and social management, compliance and implementation of the ESMS (ESAP #5). During construction and operations, the PE will contractually delegate responsibility for day-to-day E&S management and compliance to the EPC contractor and O&M company, respectively, and therefore the EPC contractor and O&M company will be required to have suitably qualified staff in place. The EPC and O&M contractors’ personnel will be selected based on their experience and trained to perform their jobs and responsibilities prior to construction and operations.  The PE E&S manager will oversee the EPC and O&M contractors and check that they are in compliance with national laws and PS requirements. Roles and responsibilities for E&S staff will be outlined in the CESMP and OESMP, but at a minimum, they are expected to include an: (i) E&S manager; (ii) Community Liaison Officer and (iii) Human Resources manager (ESAP #5).  A Biodiversity Manager will be appointed by ACWA Power to oversee the development and implementation of biodiversity related measures (refer to PS 6) (ESAP #5)

Emergency Preparedness and Response: Emergency Preparedness and Response Plans (EPRPs) will be prepared by the EPC and O&M contractor as part of the CESMP, and OESMP, respectively and will cover works on the wind farm site, OHTL and along the access road (ESAP #2). In order to inform the EPRP, the EPC contractor will undertake and assessment of the local emergency services, identifying potential requirement for establishment of supplementary site-based emergency response capabilities and an infectious disease (including COVID-19) risk assessment. The outcomes of the assessments will be included in the EPRP.

Monitoring and Review: The PE, EPC & O&M contractor will undertake regular E&S monitoring to assess the implementation of key E&S plans and procedures and demonstrate compliance with applicable E&S standards and PS requirements. An Environmental Monitoring Plan will be developed as part of the CESMP and OESMP, which will include baseline information; parameters to be monitored; monitoring locations; methods and frequency of monitoring; and criteria against which compliance and performance will be assessed (ESAP #2). The Project will also develop and implement an Incident Reporting and Monitoring Procedure to maintain records of accidents and incidents (including near misses (ESAP #2)).  

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. In addition, independent monitoring of environment, health and safety, labor and social aspects of construction activities will be undertaken quarterly during construction (refer to PS 2). Once construction is complete, the Project will be required to submit the annual E&S monitoring reports to MIGA.

Stakeholder Engagement:  The Project has developed a Stakeholder Engagement Plan (SEP) which describes key stakeholders, previous and planned engagement activities and strategies, grievance mechanism, roles and responsibilities, monitoring, and reporting. This document covers both construction and operation phases and will be updated periodically and as the need arises.

Stakeholder consultations for the wind farm and Bash-Karakul OHTL were conducted as part of the ESIA process between April and October 2021 (scoping stage) and January 2022 (draft ESIA disclosure) through individual meetings, public consultation meetings, and distribution of brochures and leaflets. Another set of disclosure and public consultations were conducted from June to July 2022, after disclosure of the Project’s updated ESIA, Resettlement Action Plan and SEP.  The key issues discussed during consultation meetings are summarized in the ESIA and SEP and included questions about compensation for affected assets/livelihood and employment opportunities. A Broad Community Support determination is not required for the Project. The Project will restrict access to grazing land during construction, this will result in the economic displacement of 10 herders and the resettlement of accommodation structures of three herders, Herders will be allowed to graze the land during operations. This impact will be compensated in line with PS 5 requirements (Refer to PS 5 section).  Impacted herders have been consulted through an informed consultation and participation process.


External Communication and Grievance Mechanisms and Ongoing Reporting to Affected Communities: A Grievance Redress Mechanism was prepared as part of the SEP and communicated to local communities during public consultation meetings and through distributed brochures and leaflets. The SEP states that any person or organization may send comments and/or complaints in person or via post, email, or facsimile using the contact information provided. The Grievance redress mechanism will be updated for construction and operations to include: (i) contact details of the EPC and O&M contractors; (ii) ACWA Power zero-tolerance policy against any form of reprisal/retaliation against project stakeholders due to their engagement, feedback or complaints related to the Project activities and operations (ESAP #6). ACWA Power has publicly disclosed the key E&S assessment and management documents, including the ESIA, SEP and RAP, 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.

PS2:  Labor and Working Conditions

The Project is expected to employ approximately 700 – 1000 workers during construction. Sixty percent are expected to be migrant workers recruited from China, India, Turkey and Europe and forty percent Uzbek nationals. The approximate Project number of workers will comprise a combination of PE, EPC contractor and sub-contractor staff. During operations, the workforce is expected to consist of approximately 35- 40 workers, the majority of which will be Uzbek nationals.

Working Conditions and Management of Worker Relationship: The PE  the EPC and O&M contractor will be required to develop and implement Human Resources (HR) policies and procedures consistent with national laws and the requirements of PS 2 which will apply and be made available (through training and other means) to all workers so that they are aware of its content, and articulate the Project’s commitments to labor and working conditions and set out minimum requirements on labor management for the construction and operations phase (ESAP #7). As a minimum, these include HR policy, sexual harassment policy, working conditions and terms of employment procedure and workers code of conduct (including prevention of gender-based violence (GBV) and code of conduct in the accommodation camp).

The HR policy and procedures will among others include commitments related to: non-discrimination and equal opportunity of workers, anti-sexual harassment and prohibition of gender based violence, prohibition of child and forced labor, right to start or join workers’ organizations, provision of a safe and healthy work environment, protection against reprisals among others.

The PE will ensure that all employees, including EPC contractor and sub-contractor employees will be provided with a written contract of employment prior to commencing work (ESAP #8). 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 work contract terms and conditions for both migrant and local workers will be substantially equivalent. During recruitment for the construction and operations phase, priority will be given to hiring of local community members for both skilled and unskilled positions in line with a Local Recruitment Plan (ESAP #2). The PE will be required to engage an independent labor expert to conduct quarterly labor audits during construction to ensure compliance of the EPC contractor and subcontractors against national laws and PS2 requirements (ESAP #9). The PE will submit the quarterly labor audit reports to MIGA.

There is limited local capacity to accommodate Project workers in the local communities. The Project intends to provide accommodation for workers at an on-site workers’ camp for the duration of construction phase and reduced on-site accommodation for the operations phase. In the event that maximum occupancy capacity is reached at the workers camp during peak construction, the PE and EPC contractor will identify additional accommodation in larger towns/ cities such as Navoi. The Project will develop a workers accommodation plan (ESAP #2) outlining the project requirements for (i) management of construction accommodation and provision of basic services and welfare facilities and (ii) existing accommodation facilities, consistent with PS 2 requirements, the IFC/EBRD guidance note on Workers Accommodation: Process and Standards, and guidance on COVID-19 requirements (ESAP #10).

The EPC contractor will be required to develop a demobilization plan (ESAP #2) to manage the transition from construction to operations. The demobilization plan will be developed in accordance with the national laws and PS 2 requirements and as a minimum will include: (i) a staggered approach regarding the timing of demobilization and the number of workers to be demobilized; (ii) communication strategy to minimize misinformation and rumors; (iii) a complaints/ grievance process.

Grievance Mechanism: The PE will require the EPC contractor to develop and make available a worker grievance redress mechanism for the construction phase and the O&M contractor will develop a worker grievances mechanism during operation phase in line with PS2 requirements (ESAP #6). Among others, the workers grievance mechanism will be designed to take into account reporting and managing of workplace sexual harassment and gender-based violence. The grievance redress mechanism will be disseminated to workers by the EPC contractor during construction and the O&M contractor during operations.

Protecting the Workforce: The Project will not employ any person under the age of 18. The Project will also prohibit the use of forced labor in line with the requirements of the national Labor Code (1996). Vetting and document verification will be undertaken during the recruitment process by the PE and EPC contractor. Per 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 EPC contractor will undertake a gender-based violence and harassment (GBVH) risk assessment to identify any potential risks GBVH risks in consultation with relevant stakeholders including women leaders and provide a plan on how these risks will be mitigated. The GBVH risk assessment and mitigation plan will be reviewed and updated for operations (ESAP #11).

Occupational Health and Safety: The PE will require the EPC and O&M contractor to develop an Occupational Health & Safety (OHS) Management plan to address project-specific risks for the construction and operations phases (ESAP #2). The OHS Management plan 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. The PE and EPC contractor will also undertake a COVID-19 Construction Risk Assessment prior to construction mobilization (ESAP #12). The findings of the risk assessment and appropriate measures will be incorporated into the OHS Management Plan.

Workers Engaged by Third Parties: The majority of the Project workforce is expected to consist of contractor and subcontractor workers. The PE will develop a Contractor Management Plan for managing and monitoring the performance of the EPC contractor and their subcontractors in line with PS requirements (ESAP #2). The CMP shall be developed in line with IFC’s Good Practice Note: Managing Contractors' Environmental and Social Performance. The PE will hold the EPC contractor for the actions of their subcontractors, requiring flowdown of E&S requirements down to the subcontractors.  

Supply Chain: Management of the Project’s supply chain will be guided by ACWA Power’s Chartered Institute of Procurement and Supply system which requires that all contractors and suppliers (including those engaged by the EPC contractor) are vetted and meet ACWA Power’s procurement policies as well as national requirements. The PE will be required to develop and implement a Supply Chain Management Plan (ESAP #2) that incorporates sourcing policy, supplier selection criteria, traceability system, supply chain risk assessment and monitoring focusing on labor and working conditions including OHS, age of workers and forced labor.

PS3:  Resource Efficiency and Pollution Prevention

Greenhouse Gases: The Project will not lead to additional greenhouse gases (GHG) emissions during operations, except during the construction period due to the consumption of fuel by vehicles and heavy machinery. During operations, it is anticipated that the Project will result in GHG emissions saving of around 800,000 of carbon dioxide equivalent (tCO2e) per year using a grid emission factor of 0.558 tCO2e/MWh . 

Water Consumption: Water will be required for the Project for several uses during construction including personal consumption, domestic use, dust control, civil works and concrete works at the batch plant. Throughout the construction phase, the Project is expected to require 90,000 cubic meters (m3) for construction activities (WTG foundation and substation construction) 30,000 m3 for domestic use and for drinking. Potable drinking water will be supplied by a licensed water supply company (to be identified) via water tankers during construction and operations. The PE is planning to abstract groundwater via water wells to be used construction activities. Given the scarcity of water in the Project area a water supply assessment will be undertaken to assess availability of water for the Project and if there will be significant impacts to local community users (ESAP #14). This assessment will include cumulative impacts of other proposed development projects that may also depend on the same water source and will consider the potential impacts of climate change. Prior to drilling of boreholes and water abstraction, the PE will be required to obtain water abstraction permit from the relevant authority (ESAP #3). In addition, a water management plan will be developed as part of the CESMP (ESAP #14), which will provide concrete actions to minimize water use. Water consumption during operation will be minimal.

Pollution Prevention: During construction, pollution to air, water, and soil is expected to be addressed through implementation of standard pollution prevention and control measures, defined in the Project’s ESMS.

Air emissions: Per the ESIA, air quality impacts during construction and operations are expected to be minimal, considering the nature of the Project and the distance of construction activities from local communities. In addition, standard practices during construction as stipulated in the ESIA will be followed such as dust abatement measures. The PE will require the EPC contractor to develop and implement an Environmental Monitoring Plan which will include among others, air quality monitoring (ESAP #2).

Noise: Although the Project site is in a remote location, there are noise sensitive receptors such as herders with accommodation structures within the Project site that will be impacted. Noise impacts during construction will be temporary and will result mainly from the operation of construction equipment. The EPC contractor will take into account the location for the workers camps to minimize workers' exposure to noise. The mitigation measures will be included in the workers accommodation plan. Noise modelling undertaken as part of the ESIA indicated that during operations, noise levels will exceed WBG EHS guideline at the herders’ residential structures within the Project site. As a result, the affected herders will be relocated outside the Project site in accordance with PS 5 requirements (refer to PS 5). In addition, the PE will be required to conduct noise monitoring at sensitive receptors (e.g. workers’ camps, nearby villages) during construction and operation per the Environmental Monitoring Plan (ESAP #2).

Shadow Flicker: The ESIA identifies potentially significant shadow flicker effects at the herder structures within the Project site, where exceedances of the 30 minutes per day and 30 hours per year limits are experienced.  Herders with affected structures at the Project site will be relocated in accordance with the provisions of the Resettlement Action Plan (RAP) – refer to PS 5.

Wastes:  The construction phase will generate different waste streams that includes solid waste, wastewater, hazardous waste, liquids, soil, plastic, metal scraps and other construction material waste. Domestic wastewater generated onsite will be collected in temporary holding tanks and removed by authorized contractors for offsite disposal in a licensed wastewater treatment plant. According to the ESIA, concrete washout wastewater (which may contain heavy metals) from the Batching Plant will be carried out in designated area on impermeable surfaces leading to a separate sump. Solid waste disposal will be managed through licensed waste contractors approved or contracted by the EPC contractor. The PE will assess potential waste and wastewater disposal and/or treatment facilities to identify their capacity to handle and treat the Project’s wastes (ESAP #15). In addition, waste management plans will be developed as part of the CESMP and OESMP (ESAP #2), and as a minimum will include provision for waste management on site such as the separation and recycling of waste, appropriate disposal facilities for the different waste streams and training requirements as well wastewater management / treatment / disposal and management of medical waste (ESAP #15).

Hazardous materials:  Hazardous materials described in ESIA include small quantities of fuels, paints, solvents, used oil, machinery lubricants among others. A hazardous materials management plan that will be developed as part of the CESMP and OESMP respectively (ESAP #2) which will include among others, storage requirements, handling procedures and record keeping/ chain of custody and training.

PS4:  Community Health, Safety and Security

Community Health and Safety  

The Project is in a remote desert area and potential impacts on community health and safety are expected to be limited. The Project is required by national law to establish a 1000 m Health Protection Zone (HPZ) around the WTGs and limit activities and/or people’s presence within the HPZ for safety. The HPZ will be registered with the Agency for Sanitary and Epidemiological Welfare under the Ministry of Health before commencement of operations (ESAP #3). The 1000 m HPZ around the WTGs, this is greater than the 500 m required as a setback distance for both blade throw and ice throw per the WBG EHS guidelines for Wind and Energy. Affected herders with accommodation structures within the Project site will be relocated in accordance with the provisions of the Resettlement Action Plan (RAP) – refer to PS 5.

To avoid exposure of local people to electromagnetic field (EMF) from the Bash-Karakul OHTL, the PE is required by national law to establish a minimum of 30 m HPZ on each side of the OHTL. The closest residential structure to the Bash-Kurakul OHTL is approximately 250 m, a distance with negligible EMF impact. During construction, only authorized workers will be allowed to enter the Project site. During operations, herders will be allowed to use the Project site for grazing. 

The PE obtained a preliminary No Objection Certificate (NOC) from the Civil Aviation Authority (CAA) but the final NOC will be issued by CAA and the Ministry of Defense once the exact location of the wind turbines is determined.  The PE will be required to obtain the final NOC prior to the start of construction (ESAP #3),

Wind turbine components will be transported from China via Kazakhstan. A transportation route survey of the roads that will be utilized to transport turbine components (abnormal load) was conducted. Road traffic accidents will be minimized through driver training, enforcement of speed limits and regular maintenance of Project vehicles. The PE will require its EPC contractor to develop and implement a traffic and transport management plan (TTMP) based on a detailed pre-construction route survey (ESAP#2). This will be part of the CESMP and will apply to all sub-contractors.

The EPC will prepare an Influx Management Plan to address the potential migration to the Project area (ESAP #16). The plan will among others consider impact on local community infrastructure, potential community conflict, misconduct of workers, anti-social activity, GBVH and spread of communicable diseases (e.g. sexually transmitted illnesses, COVID-19). As indicated in PS 2, HR policies and procedures will include a code of conduct, which will include rules for interaction with local communities.

As mentioned in PS 1, the Project EPRP will be developed and implemented by the EPC and O&M contractors as part of the CESMS and OESMS. This will include measures to prevent impact on community health and safety, and mechanisms to ensure communication with local communities, local authorities and emergency services in case of an emergency.

Security Personnel: During construction, the EPC contractor will engage a private security contractor to provide 24/7 security. The EPC contractor will undertake a security risk assessment, and a Security Management Plan will be prepared to address any findings of the risk assessment (ESAP #17). The plan will include a Code of Conduct for site security personnel, incident reporting, and an investigation process. The PE will monitor the implementation of this management plan via the quarterly labour audits (ESAP #9). The Project's grievance mechanism will be available for complaints related to security personnel (ESAP #6).

PS5:  Land Acquisition and Involuntary Resettlement

General: The project site is used primarily for grazing by Kokcha LLC which is an entity under the Committee for the Development of Sericulture and Wool Industry, for the production and sale of livestock products, predominantly Karakul sheep. In Uzbekistan, land is owned by different State agencies allocated for different purposes (agricultural, industry, transport). The area allocated for the wind farm was under agricultural status for use by the Committee for the Development of Sericulture and Wool Industry. All pastures intended for breeding Karakul sheep are transferred to the Committee which then independently leases to clusters for a period of 49 years.   

Kokcha LLC, a cluster under the committee was allocated 267,398 ha of grazing land which includes the land within the Project site and in the wider project area. Land take for the Project will account for less than 0.1% of the total land area allocated to Kokcha LLC. In accordance with the Land Allotment Order issued in March 2021 by Gijduvan district, the PE was allocated 285 hectares (ha) for the purpose of the development of the wind farm. The wind farm footprint is expected to comprise of approximately 178 ha of which 159 ha will be for permanent structures and 20 ha for temporary structures that will be decommissioned after construction. The land allocated to the Project has been taken back to the State reserve and is in the process of being transferred from the Committee for the Development of Sericulture and Wool Industry to the Ministry of Energy. Per the power purchase agreement (PPA), the PE will enter into a Land Lease Agreement (LLA) with the Ministry of Energy. The LLA will be on the basis of the required footprint of the wind farm rather than the whole area allocated and a land easement for the temporary structures. The Bash-Karakul OHTL route alignment has been defined and agreed with NEGU and includes a 100 m RoW corridor, the final location of pylons/towers is yet to be identified. During construction, the PE will be allocated land usage rights through a LLA with the Ministry of Energy.

Kokcha LLC allocates land to herders based on the number of livestock owned and availability of water resources. In addition to herding karakul sheep, herders are allowed to graze their own livestock. Herders from local villages are allowed to graze on land near their villages. Herders are required to request permission before construction of any structures on the land allocated to Kokcha LLC (majority of agreements are verbal). Community members from Ayakagitma village use Lake Ayakagitma for fishing. No impacts are anticipated on the activity of fishermen on Lake Ayakagitma as a result of the Project.

Displacement: According to the Resettlement Action Plan (RAP), the Project site is predominantly used for grazing activities by ten herders that will be economically displaced during construction, three of which will also be physically displaced. Of the ten herders, six have contracts with Kokcha LLC and four herders (brothers) are from Ayakagitma village without contracts. In addition, the herders engage 21 permanent workers in total (ranging from 2-8 workers per herder), who own livestock that are also grazed in and around the Project site who will also be temporarily economically displaced. Since most of the herders do not live near the grazing area, 1 to 2 roomed structures are used for accommodation. It is estimated that herders and their workers spend approximately 60-80% of their time in these accommodation structures. Of the six herders with contracts with Kokcha LLC, three have accommodation structures within the Project site and will be physically displaced. There is also one accommodation structure in ruins belonging to Kokcha LLC. In addition, there are other structures (animal stables, water wells, storage area among others) within the Project site that will be affected by the Project.

Access to grazing land on the Project site during construction (approximately 2 years) will be restricted, since construction will occur simultaneously throughout the Project site. As part of the Stakeholder engagement Kokcha LLC and herders have been informed and are aware of the restriction during construction. As mentioned in PS 4, the Project is required by national law to establish a 1000 m HPZ around the WTGs. Structures are not allowed to be constructed or retained within the HPZ. It is expected that access to the Project site for all herders will be possible during the operations in areas outside of the Project footprint.  

From the six herders with contracts with Kokcha LLC, 3 herders have sufficient land outside of the Project site boundary to continue grazing activities during construction. The Project has worked closely with Kokcha LLC and Bukhara Municipality and the herders to identify suitable alternative land for the three herders with structures within the site. Suitable grazing land has been identified for the 4 herders from Ayakagitma village.

Based on the RAP, the construction of the Bash-Karakul OHTL will result in physical and economic displacement. Based on the assessment undertaken on a 100 m RoW corridor (which includes the 30 m HPZ on each side), 28 land users were identified along the OHTL, that are using the land for grazing, farming, forestry and commercial purposes employing approximately 52 permanent and 161 temporary workers. There are 6 land users with structures within the OHTL RoW that will be moved. These include 1 herder, 2 farmers, and 3 commercial enterprises. Of the structures that will be moved, two will be physically displaced. Five out of six commercial enterprises identified along the Bash-Karakul route will lose more than 50% of their land, making their enterprises unviable. Out of the 5, 4 have not undertaken any development on their land and 1 has existing infrastructure.

The Project developed a RAP in line with PS 5 requirements to be implemented prior to commencement of construction activities.  The RAP details the following: (i) eligibility and entitlement, (ii) valuation methodology and verification, (iii) transitional support; (iv) livelihood restoration programs; (v) grievance redress mechanism among others. The RAP will be revised and updated to include: (i) finalization of the OHTL compensation package (following finalization of the Bash-Karakul OHTL route); (ii) description of the institutional arrangements of the OHTL land acquisition process (including NEGU’s responsibility); (iii) feedback received during the disclosure period (in May and June 2022); and (iv) an updated RAP implementation schedule (ESAP #18). The PE will be ultimately responsible for the implementation of the RAP in line with PS 5 requirements. The PE will monitor the RAP implementation in line with key monitoring indicators listed in the RAP and will prepare and submit RAP implementation compliance report to MIGA (ESAP #18)

The PE will be required to engage an independent third party to conduct a completion RAP audit two years after completion of the RAP implementation to verify that commitments in the RAP have been delivered and all services provided and that the mitigation actions prescribed have had the desired effect against baseline conditions (ESAP #19). Upon completion of a satisfactory audit and close-out of any related corrective actions, the resettlement process will be deemed complete. If the RAP implementation is deemed unsatisfactory, the PE will develop a Resettlement Corrective Action Plan which includes a timeline, budget and resource allocation based on the findings of the Audit (ESAP #19).

A series of consultations have been undertaken in relation to the Project. The RAP and SEP provide evidence of engagement with the herders, representatives of the affected communities and other stakeholders. Public consultation meetings were held between April and June 2021 for the Project site and in October 2021 along the OHTL. Additional consultations were undertaken in June 2022 after disclosure of the RAP.

As discussed previously, a Project-level community grievance mechanism has been established to allow affected people to submit grievances, including those arising from acquisition of land and disruption of livelihoods. Details of the Grievance mechanism are included in the RAP. 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. The PE will be required to receive, register, respond and maintain a record of all the community grievances (ESAP  # 6).

PS6:  Biodiversity Conservation and Sustainable Management of Living Natural Resource

The project is located 0.5 km east of the Ayakagitma lake and surrounding desert IBA and KBA, The IBA is of international significance for wintering waterfowl and is surrounded by cliffs in which several raptor species nest.

Bird flight activity data collected across four seasons (between 2020-2022) estimated turbine collision mortality risks with the potential for low to moderate impact on several raptors (Valued Environmental Component, ‘VEC’) including: Egyptian Vulture (IUCN Red List – Endangered, Uzbekistan Red List – Vulnerable), Steppe Eagle (IUCN Red List – Endangered, Uzbekistan Red List – Vulnerable),  Saker Falcon (IUCN Red List – Endangered, Uzbekistan Red List – Near Threatened),  Cinereous Vulture (IUCN Red List –  Near Threatened, Uzbekistan Red List – Near Threatened),  Greater Spotted Eagle (IUCN Red List –  Vulnerable, Uzbekistan Red List – Vulnerable),  and Golden Eagle (IUCN Red List –  Least Concern, Uzbekistan Red List – Vulnerable). These VECs will be subject to PS 6 Natural Habitat no net loss (NNL) requirements.

Other VECs that may be  negatively impacted through mortality, habitat loss, disturbance and/or displacement include six species of shorebirds/waterbirds, five other threatened raptors, four other bird species, seven bat species, Russian Tortoise (IUCN Red List and Uzbekistan Red List – Vulnerable), Goitered Gazelle (IUCN Red List and Uzbekistan Red List – Vulnerable) and Turkmen Caracal (Uzbekistan Red List – Critically Endangered). These VECs will also be subject to PS 6 Natural Habitat no net loss (NNL) requirements. 

Two species, Southern Even-fingered Gecko (IUCN Red List – Critically Endangered, Uzbekistan Red List – Vulnerable) may have a viable population within the Ecologically Appropriate Area of Analysis (EAAA) and that it is likely endemic to Uzbekistan. The CHA also showed that the EAAA is within breeding habitat and a migratory corridor for Asian Houbara (IUCN Red List – Vulnerable, Uzbekistan Red List – Vulnerable). Both species will be subject to PS 6 net gain requirements.

The PE will implement a comprehensive program to avoid and minimize risks on VECs. Concerning birds, the PE has relocated turbines away from high-risk areas, and will implement a Collision Risk Management Plan (ESAP #20) which involves deploying an independently proven automated shutdown on demand system (IdentiFlight®) throughout the wind farm to avoid and minimize raptor collision fatalities. IdentiFlight combines imaging, artificial intelligence, and machine learning to detect target flying bird species and will automatically trigger a shutdown of turbines if a bird approaches within a threshold distance of turbine blades. In addition, the PE will develop and implement a Livestock Carcass Management Plan to remove livestock carcasses that may attract scavenging raptors close to turbines. To minimize risks to bats, the Collision Risk Management Plan will include the use of freewheeling of turbine blades between May and November from commencement of operation, and the use of cut-in speed curtailment if bat fatality thresholds are exceeded.

Raptor nest and roost sites exist within and in close proximity to the Project and, if active, will likely be disturbed by construction activities and operating turbines. As per ESAP #21, before construction, the PE will hire a qualified consultant (ecologist/ornithologist) to develop and implement a raptor breeding survey based on good international raptor monitoring methods. The program will be designed to survey potential raptor breeding/roosting habitat within the Project site buffered to 1km to identify raptor breeding and roosting locations. Surveys will be conducted every year, starting from or before initial commissioning.

The PE will develop and implement a construction phase Biodiversity Management Plan (BMP) that will include preconstruction surveys of habitat quality, the Critical Habitat species (Southern Even-fingered Gecko and Asian Houbara) and 31 VECs and will recommend any associated avoidance and minimization measures relevant to these species (ESAP #22).  The same approach will apply to the opening of trenches and installation of towers with respect to SDOD infrastructure (as required). The construction phase BMP will include a (raptor) Breeding Bird Protection Plan based on results from the raptor breeding survey (ESAP #21) with recommended measures to minimize disturbance to nests during the construction phase and during O&M activities of the operations phase. As part of the Breeding Bird Protection Plan, the PE will avoid construction activities within 750m of nests of ESIA Tier 1 (Endangered / Critically Endangered) bird species in the nest selection period of those species (1st March to 1st July). The BMP will also include a Reptile Relocation Plan for the Southern Even-fingered Gecko and Russian Tortoise, the design and implementation of bird deterrents on the Bash-Karakul OHTL, a protocol for monitoring of bat roosts identified during the baseline surveys across all seasons during the construction phase, and a flora conservation plan. 

With respect to the operations phase, as per ESAP #23, the PE will contract an internationally recognized, specialized wind-wildlife expert(s) to collaborate with their locally contracted ecological consultancy/ expert team to finalize the design of the Post Construction Fatality Monitoring (PCFM) program for both the wind farm and OHTL and develop an operations phase BMP. As part of the PCFM workstream, the international expert(s) will be retained for the first three years of operations to provide technical support to the local consultancy/ expert team on PCFM analysis and reporting, training, and capacity building. The contract will include two site visits per year (1-month per visit) to conduct independent verification of the PCFM program. The PCFM program will be carried out for an initial 3-year period, with semi-annual reporting and annual strategic reviews, but the actual timeframe will depend on fatality results. A single fatality of ESIA Tier 1 bird species will trigger review of mitigation measures including SDOD.

In addition to the PCFM program, the operations phase BMP will include the following: i) threshold setting for ESIA Tier 1 bird species following the potential biological removal method, ii) an adaptive management framework, and iii) protocols for all onsite operational phase monitoring and mitigation activities, such as the SDOD program, the Livestock carcass management plan, and the Collision risk management plan for bats and birds. It will also include a semi-annual reporting template for centralized reporting of all bird and bat monitoring, mitigation, and documenting of adaptive management. With the exception of the PCFM protocol (see above), the operations phase BMP and accompanying protocols will be reviewed after a three-year period as other types of mitigation, including cut-in speed curtailment (e.g. for bats), might be required in the future on the basis of the results of fatality monitoring and per the adaptive management framework.

With respect to the Critical Habitat species and VECs, as indicated in ESAP #24, the PE will develop a fit-for-purpose Biodiversity Action Plan (BAP) and Biodiversity Monitoring and Evaluation Plan and a Biodiversity (compensation) Offset plan.  The BAP will include a loss/gain assessment informed by the pre-construction surveys and will identify measures to further guide habitat restoration measures in the ESIA to meet net gain objectives.  

To provide expert external evaluation and advice on conservation priorities for globally and nationally threatened bird species using the Project site, the PE will establish Biodiversity Committee of relevant international and national stakeholders (e.g., ornithologists) who will oversee the implementation and effectiveness of the mitigation strategy and advise on adaptive management (ESAP #25).

Lastly, to manage the multiple biodiversity risks and interrelated mitigation measures, the ACWA Power will contract a dedicated Biodiversity Manager (ESAP #5) who will be responsible for the overall management and reporting of all mitigation and monitoring activities relating to the project (e.g., PCFM, SDOD, implementation of the construction and operations phase BMPs, BAP and Biodiversity offset). The manager will be an English-speaking ecologist with experience managing field programs and reporting results.

PS8:  Cultural Heritage

Lake Ayakagitma and its surroundings is an area of cultural heritage importance. According to the Institute of Archeology in Uzbekistan, the area, including the Project site, has been extensively surveyed by an Uzbek – Polish expedition from 1996 – 2005 and an Uzbek- French expedition from 2006 – 2015 which yielded a number of archeological finds from the Stone Age/Middle Palaeolithic through the Neolithic and up to historical times/Medieval Ages.

Protection of Cultural Heritage in Project Design and Execution: According to the Institute of Archeology, National law requires that an archeological survey be undertaken prior to any large-scale construction. An archeological survey was undertaken in May – June 2021 by the Institute of Archeology in collaboration with the PE on the Project site. The survey identified a new Neolithic site, seven stone processing workshops of Palaeolithic Age and findings belonging to the classical periods. The findings of the survey were submitted to the Central Department of Cultural Heritage Agency under the Ministry of Tourism and Sports with an application to register the archeological sites and protection buffer zones (including protection buffer zones of sites previously surveyed). The buffers range from 50 – 300 m per site. At the request of the PE, the Agency of Conservation of Cultural Heritage has allowed for construction works to be undertaken within the established buffer zones, but under the supervision of an archeologist and specialists from the Agency.  

A memorial site to remember the location of where road accidents resulted in loss of lives was identified along the existing access road from A-397 highway to the Project site. No impacts are anticipated on the memorial site.  Based on the consultations with relevant stakeholders and review of satellite imagery, no known archaeological sites or other sites of potential cultural importance were identified within 5km radius of the Bash-Karakul OHTL, except for two kampir devor ruins. The Bukhara Region Department of Cultural Heritage Agency requires that an archaeologist is present during construction activities along the OTHL route but does not require pre-construction surveys.  

The PE will develop and implement a cultural heritage management plan for construction and operations (ESAP #26) that takes into account the known location of cultural heritage sites and procedures to ensure protection of these sites, including but not limited to training on the importance of cultural heritage on the site, demarcation with appropriate signage of sites, reporting of damage of cultural heritage sites and any recommendations as required by the regulatory authorities. A Chance Find Procedure will be developed prior to construction by the EPC contractor (ESAP #26). This will include protocols and procedures to stop work and methods preserve potential finds, as well as reporting requirements and co-ordination with the relevant regulatory agencies.

An archaeologist from the Agency of Conservation of Cultural Heritage will be present to supervise the works undertaken within the archaeological buffer zones. In addition, the PE will engage a qualified archeologist to be present at the site during construction, during earthwork activities (ESAP #26).

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

The above documentations are 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:

Sachin Abhyankar ( / +971 278 3001


  • Contact details of sponsor for general public enquiries.:

Rohit Gokhale (

Sachin Abhyankar ( +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:


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