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Non-Technical Executive Summary

SKURPIE WIND FARM POLAND

March 2013

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Introduction and general project presentation

Grupa PEP is developing a wind farm in the Płośnica commune (gmina) located in the

county of Działdowo town, warmińsko-mazurskie region (województwo), north-eastern

Poland.

The subject wind farm configuration includes:

16 wind turbine generators (WTGs), type Siemens SWT-2.3-108,

main electrical substation (MES);

underground infrastructure of power transmission and control cables;

access roads to individual WTGs and assembly and service yards.

Total installed capacity of the wind farm will amount to 36.8 MW.

The WTGs are to be located in two groups:

10 WTGs on the land plots located to north of the village of Skurpie

6 WTGs on the land plots located to the south of the village of Skurpie.

The project is classified both from the point of view of European Union and Polish legislation

(Executive Order from November 9, 2010 on investments potentially significantly impacting

the environment), as the one which may be required to undergo Environmental Impact

Assessment process as an investment which could have a potentially significant impact on

the environment. The local authorities taking into account the environmental regulations

decided that development of an environmental impact assessment report is obligatory for the

investment.

This non-technical summary presents information enclosed in the environmental impact

assessment reports (EIA) prepared for the project execution and other environmental

documentations prepared for the needs of the planned wind farm.

Based on the environmental impact assessment reports and analysis of available

information, the project is not likely to generate significant adverse social impacts or need

for involuntary resettlement or economic displacement. No regulatory non-compliance

issues were identified in this audit.

WTGs description

A typical wind turbine generator consists of a tower and a gondola comprising a rotor and

measurement apparatus. The rotor is composed of the blades, attached to each other by

a bearing. The blades are moved by the wind and transmit this force to the bearing, which is

connected to a multiplier that increases the axle speed. The mechanical energy is

transferred from the multiplier to an electricity generator, which transforms it into electricity

for subsequent injection into the grid.

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According to the information provided by the developer, Siemens SWT 2.3 108, with power

of 2.3 MW, will be installed at the wind farm. During the course of the wind farm planning the

number of WTGs has been reduced from 19 WTGs to 16 WTGs due to the technical

conditions of a connection to the power grid.

The plans include construction of 115 m high hubs with rotors of 108 m in diameter.

Access to the WTGs will be provided by a network of access roads. Total length of newly

constructed roads will amount approximately 3.5 km. Total area developed as part of the

project including areas of the newly constructed roads, technical yards and foundations in

the vicinity of WTGs and the main electrical substation will amount to approximately 5 ha.

The individual WTGs will generate electricity of a 0.69 kV voltage, which after transformation

in the individual, on-site, container substations will be transferred to the MES via an

underground power cables. The cabling route connecting the MES with MES operated by

the operator of the power line will approximately 7.8 km long and will not pass any sensitive

environmental areas, according to the environmental impact assessment report.

The construction works has not started yet, however, the project already passed the EIA

procedure, granted environmental decision, and construction permit.

Project Location

The Skurpie wind farm is to be developed in the commune of Płośnica, Działdowo county,

Warmińsko-Mazurskie voivodeship. According to the available sources, the Płośnica

commune occupies an area of 163,09 km2, of which 73% is occupied by agricultural land

and 18% by forests. As of 2004, the population of the commune counted approximately 5900

inhabitants.

The wind farm is to be located at two sub-sites respectively to the north and south of the

village of Skurpie. The first site of an approximate area of 8 km2, located north will house 10

WTGs and can be described as irregular of a roughly crescent shape, with its longer edge

stretching out along the north-west and south-east axis. The nearest WTG is located

approximately 1 km north from the Skurpie village. The second site of an approximate area

of 8 km2 located south will house 6 WTGs and can be described as of trapezoid shape, with

the nearest WTG located approximately 1,5 km south from the Skurpie village.

Based on the site visit observations and review of aerial photos and topographic maps,

the wind farm development area has a rural character. The area of Skurpie wind farm

development is located within the moraine upland among narrow, poorly formed valleys of

the Płośniczanka stream and tributaries of Wkra and Działdówka rivers. The terrain is hilly

with elevation varying from 170 to 185 m asl. According to J. Kondracki country regional

division the area belongs to the Wzniesienia Mławskie hills mesoregion, which is part of the

Nizina Północnomazowiecka lowland region.

The sites are located away of the environmentally sensitive areas. All locations of the

Skurpie wind farm development were designed on agricultural areas

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For the purposes of this environmental assessment, all communes bordering with Płośnica

commune, i.e.: Działdowo, Kuczbork-Osada, Lidzbark, and Rybno were contacted. All

commune offices were contacted via telephone and the representatives of local authorities,

responsible for environment protection and development investment were interviewed. The

interviews were focused on obtaining general information regarding any wind farm

investments (existing or being developed) within the borders of the subject commune.

Based on the interviews, it is concluded that there is one operating WTG in the Jankowice

villages, located over 10 km from the wind farm. A study on spatial development of the

commune of Działdowo, located 5 km south-east from the Skurpie wind farm development,

defines areas for the potential locations of wind farms. Currently, the study on spatial

development is in the process of being updated to define precise locations of the wind farm

investments in the commune. There are also initial plans for potential location of two

additional wind farms located in the Płośnica commune, located over 5 km from the subject

wind farm. Other communes are located over 15 km from the Skurpie wind farm. As part of

the EIA procedure no significant cumulative impact was assessed to potentially occur.

Rationale for this Project

In line with the European Climate Change Program, many European countries, including

Poland, have adopted national programmers aimed at reducing emissions. These cover

various policies, adopted at the European level as well as national levels, and include among

others:

Planned increase in use of renewable energy (wind, solar, biomass)

Improvements in energy efficiency in e.g. buildings, industry, household appliances;

The main regulations of EU countries to reduce emissions is the Emission Trading Scheme

of carbon dioxide and legislation tackling with emissions of fluorinated greenhouse gases.

The development of wind energy is one of the measures to be implemented, and leads to

the limitations of air emissions and an increase of production of energy from renewable

resources. The main benefit is that wind turbines convert the wind’s kinetic energy to

electricity, while producing none of the emissions to the air. Conventional energy sources,

mainly based on various types of coal incineration, when producing energy generate

emissions of greenhouse gases, SO2, dust and others.

The wind energy is considered to be one of the cleanest ones, in fact, during the exploitation

phase of the turbines no pollutants are emitted to the atmosphere.

According to the EIA report, the expected annual energy production will amount approximately 119 400 MWh. Therefore the environmental benefit of the project will be to reduce greenhouse gases emission in an amount of 76 177 tons (calculated based on an emission factor, representative for projects supplying additional electricity to the grid, as of 0.638 tCO2/MWh, produced for Poland in 2012) per year. The development will also help the country to meet the national plan to achieve 15% share of renewable energy use in total energy consumption by 2015.

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Apart from saving the greenhouse gases emission, the project will also result with significant

“avoidance” of post-combustion emissions. As an example, the equivalent production of

electricity by the largest Polish hard-coal power plant in Kozienice would result with the

following emissions (estimations based on Elektrownia Kozienice emission factors for 2011)

PM: approx. 11 tons/year;

SO2: approx. 314 tons/year;

NOx: approx. 205 tons/year.

Exploitation of the subject wind farm can be therefore considered a measure to avoid the

emissions to the atmosphere of the comparable amounts of pollutants.

The issues of social advantages of the project were widely discussed with the representative

of the Płośnica commune. The following direct advantages were agreed with the

representative during the discussion:

the project will increase income of the commune by taxes paid by the operator for

commercial activities in the area,

the project will increase income of the owners of the land occupied by the wind farm

and its infrastructure;

the project helps the local authorities to promote pro-ecological behavior of the local

citizens.

Legislative Context and Public Consultations

The procedure regarding the wind farm location had been commenced by elaboration of

local spatial planning documents including: elaboration of amendments of the the commune

frame development plan (studium kierunków i uwarunkowań zagospodarowania

przestrzennego) and development of the Local Zoning Plan (miejscowy plan

zagospodarowania przestrzennego). The procedure was conducted by the authorities,

following the rules of the Act on Spatial Planning and Development of March 27, 2003 (with

further amendments).

According to environmental regulations: Regulation on disclosure on environmental information, public participation in environment protection and on environmental impact assessments, an Environmental Impact Assessment (EIA) procedure must be performed for projects which can always significantly impact the environment (group I projects) or particular ones which can potentially impact the environment (group II projects), or may impact an area of ‘Natura 2000’ protected land. An EIA is carried out to obtain a decision on Environmental Conditions (environmental decision) which is obligatory for a realization of an individual project.

In the administrative procedure for the project, the Authorities obligated the Investor to

prepare an EIA report.

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Information on the planned investment together with EIA Report were made available for

comments of the public, including local communities and potential interested parties. The

summary of the public consolations and official procedure is summarized as follow:

On January 4, 2010 the Płosnica Commune Head issued a note informing on the

commenced proceedings regarding issuing the decision on environmental conditions for the

wind farm and about the obligation of preparing the EIA report. Following completion of the

EIA report, the Commune Head on February 25, 2010, issued a note informing about the

proceedings and public consultations. The note was published on the official notice board of

Płośnica commune along with copies on notice boards in the commune village of Skurpie,

and was available at the commune office official web page of Płosnica. The time period for

filing complaints or comments: 21 days since the date of publishing the note. An official note

informing about comments and acceptance of the EIA report by the Regional Environmental

Authorities (RDOŚ) and Sanitary Authorities (PPIS) was published on April 23, 2010.

Due to issue raised by RDOS the investor was obliged to analyze the cumulative impact of

the wind farm with other planned wind farms. Following completion of the EIA procedure, the

Płosnica Commune Head issued on November 30, 2010 the decision on environmental

conditions of the Skurpie wind farm project. To complete the administrative procedure the

Authorities issued a notice informing on the decision on environmental conditions of the wind

farm project. Similarly, the note was published on the official notice board along with copies

on a notice board in the local commune village of Skurpie and was available at the commune

official web page. The time period for filing complaints or comments: 14 days since the date

of publishing the note, after which the notice was deemed effective.

The key environmental conditions and comments resulting from the environmental decision

are:

to conduct a post-construction birds and bats monitoring. In case when the results would show increased impact on the avifauna, in comparison with the results showed in the EIA report, the investor will be obliged to undertake appropriate mitigation procedures, including temporary switching of the WTGs.

to comply with the regulation on maximal environmental noise levels;

to perform environmental noise measurements after commencing the wind farm operation, and when to undertake appropriate actions reducing impact of the wind farm on the acoustic climate.

What is the current condition of the existing environment?

The planned wind farm is located away from environmentally sensitive areas.

The nearest one (Natura 2000 Special Protection Area No. PLB140008 “Dolina Wkry i

Miławki”) is located approximately 2 km to the south from the nearest wind farm sub-site.

Other environmentally sensitive areas located at a distance between 5 km and 10 km from

the wind farm include: landscape park “Welski Park Krajobrazowy, located 8.3 km west;

landscape protected area (Obszar Chronionego Krajobrazu)“Dolin rzek Nidy i Szkotówki”,

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located 6.8 km east; landscape protected area “Doliny Górnej Wkry”, located 7.3 km west;

landscape protected area “Zieluńsko-Rzęgnowski”, located 8.2 km south; landscape

protected area “Grzybiny”, located 9.3 km north-west. Natura 2000 Site of Community

Importance No. PLH280014 “Ostoja Welska”, is located 9.3 km west from the wind farm

area. There are four other landscape protection areas and two nature reserves, at a distance

between 10 and 15 km from the wind farm.

Below you will find a map presenting the WTG locations (red dots) to the nearest nature

protection areas (source: Raport o oddziaływaniu na środowisko zespołu elektrowni

wiatrowych FW4 w gminie Płosnica)

Birds and bats issues

As a part of the pre-investment process, including preparation of the EIA report, a year-long

monitoring of birds (from January 1, 2010 till January 3, 2011) and bats monitoring

conducted between March and November 2009.

The monitoring of birds comprised transect and point observations, the intensity of which

depended on the part of the year. During the observations, the researchers observed

number and species of flying birds - estimation of the intensity of flights (local and long

distance), as well as flight altitude (in ranges 0-50 m, , 50-170 m and above 170 m) and

direction.

The monitoring was conducted in line with the widely applied methodology of common

breeding birds monitoring (MPPL) to determine the avifauna values in relation to the

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reference data representative for the whole country. Estimation of the quantity and

distribution of breeding rare species and large species (in particular prey, storks, cranes etc)

was conducted.

The monitoring program included 36 field campaigns in total.

The quantities of birds identified during the monitoring are typical for the Polish territory and

do not deviate from those reported for other parts of the country.

In total 99 bird species were identified in the area of the planned wind farm. The most

valuable species observed at the site are these listed in the Annex I to the Bird directive and

included 13 species. Out of the 99 species, approximately two thirds(60 species, including 6

species listed in the Annex I to the Bird directive) were defined as birds nesting in the wind

farm region, and next 9 species (including 3 species listed in the Annex I to the Bird

directive) utilized the area of the wind farm during the breeding season.

The general conclusion presented in the report was that the wind farm will not generate an

extensive impact on birds.

The monitoring of bats comprised of field, transect observations, during which noise

detection measurements was carried out. Five species of bats were identified in the area of

the wind farm. All protected by national and European law but none listed in the Annex II to

the Habitat Directive.

Bats were observed mainly in the vicinity of forests, flying along trees and roadsides. For

detected bats, an activity index was calculated following the guidelines for assessment of

wind turbines on bats. For most of the transects the bats activities established based on

activity indexes was small to medium, except for four detection transects, on which bats

activity was large or very large (one case). These transects are located away from the

planned WTG locations.

Taking into account the results of the bats monitoring, it was assessed that potential impact

of the planned wind farm should not negatively impact on the local bats group.

Social impacts

The project has direct socio-economic impacts on development of the Płośnica commune

and local inhabitants. The following direct impacts have been identified:

increase of the commune tax income;

increase of the annual income of land leasers;

Development of the Project will not require any displacement of the people or business. The

negative impact is related to decrease of the land area used for agricultural purposes,

however, this will be compensated by the land lease fees.

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What impacts during construction will there be?

The main impacts of the projects associated with the wind farm development relate to earth

works (primarily during setting of foundations for the towers), construction works and

increased transport traffic and include intrusion and disturbance within soils strata,

temporary change of groundwater level (when groundwater draining is required during the

construction), increased noise and vibration. To limit the impact the investor is obliged to

undertake a number of measures such as:

the use of construction equipment of good technical state: complying with noise and exhaust fumes abatement levels and in order to limit potential impact on soil and groundwater quality resulting from potential fuel/oil leakages;

construction works cannot create any limits in use and operation of adjacent lands;

construction works should be reserved for daytime;

conduct waste management in line with the provisions of Waste Act and local commune regulations.

What will be the impacts during operation?

Completed investigations and public consultations conducted primarily as part of the

environmental impact assessments procedure identified that main environmental impacts

associated with the operation of the wind farm refer to increased noise levels, change in the

landscape and potential influence on avifauna and bats.

Noise generation

Noise emission is considered as one of the most common environmental impacts generated

by wind farms. For the purpose of noise impact assessment, a numerical modeling of noise

distribution was conducted as part of the EIA and during planning stages of the project.

Noise distribution calculations were conducted with use of a dedicated certified software,

compliant with Polish technical standards relating to the assessment and management of

environmental noise. The calculations were conducted for maximum acoustic power of the

Siemens WTGs (107 dB) and the results were then verified against permissible noise levels

specified by the dedicated Executive Order (Rozporządzenie Ministra Środowiska z dnia 14

czerwca 2007 r. w sprawie dopuszczalnych poziomów hałasu w środowisku).

The results of calculations indicated that the operation of the wind farms will not cause

breaches of the ambient noise standards at any of the acoustically protected areas both

during the daytime and nighttime, and that the maximum noise levels at these areas borders

will vary between 41.5 and 45 dB(A). It should be mentioned here, that the planned WTGs

can be operated with reduced noise emission, which together with positive noise distribution

calculation results should secure the noise standards to be kept at the protected areas. The

investor will be obliged to perform post-construction noise measurements and when required

to undertake appropriate actions aiming at reduction of the wind farm impact on the acoustic

climate.

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The maps illustrating the calculated acoustic climate, (with visible isolines of 40 ,45 and 50 dB) are presented below (source: Raport o oddziaływaniu na środowisko zespołu elektrowni wiatrowych FW4 w gminie Płośnica).

Daytime noise levels Nighttime noise levels

Birds and bats

The location of 16 WTGs will create some threat to birds and bats. Nevertheless it should be

pointed out that a number of observations and reports on active wind farms and its impact on

birds populations indicates that birds avoid collisions with wind farms. The number of deaths

of birds resulting from collisions with wind turbines is significantly smaller than those caused

by collisions with e.g. cars, power lines and houses.

To recognize the local birds populations and undertake applicable measures during the

planning stage the investor has conducted a number of ornithological observation at the

areas of the planned wind farm. In a view of the pre-investments monitoring results, the

identified avifauna was classified as typical of the Polish territory and does not deviate from

those reported for other parts of the country.

The general conclusion presented in the report was that the wind farm will not generate

extensive impact on birds. The investor is obliged to conduct a post-construction birds and

bats monitoring. In case when the results would show increased impact on the avifauna, in

comparison with the results showed in the EIA report, the investor will be obliged to

undertake appropriate mitigation procedures, including temporary switching off the WTGs.

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Landscape

The wind farm will be developed in agricultural area i.e. the natural landscape has already

been influenced by humans. Construction of the wind farm will introduce new visual

dominants (WTGs and newly constructed roads) to the landscape. Importance of its impacts

on landscape depends on the scale of converted/impacted landscape (i.e. local, sub-regional

or regional), what type of landscape is transformed (natural, semi-natural, agricultural,

cultural, industrial etc) and whether the impacted landscape is protected, as well as the on

the number of people remaining/visiting the impacted landscape.

Due to long distance and presence of of forest areas, it was assessed that the planned wind

farm will be hardly visible from Welski Landscape Park (located approximately 8.3 km to the

west) and from other landscape protected areas (the distance is over 6.8 km). The WTGs

will not be visible on the background of the above mentioned form of nature.

Based on the EIA, there are no cultural heritage registered as historical monument objects

located in the wind farm area of influence. The nearest area is located in the town of

Działdowo, approximately 3.5 km from the site. There are also some buildings and other

objects (e.g. cemetery, churches) protected by the heritage/culture regulations and/or

located within protected area. Protection of the cultural values in these zones includes the

protection of of special character of the developments in general and protection of

settlements of outstanding cultural values. It is required to keep the character and scale of

the objects with the possibility of introducing new elements in general with traditional forms.

The area of the planned wind farm is located over 0.7 km from such zones.

The WTGs will be visible mostly to local inhabitants and to a lesser extent also to travelers

and inhabitants of Działdowo town. For the latter, no cumulative significant visual impact can

be expected as no other developments of similar character are currently under development

in the distance smaller than 5 km from the Skurpie wind farm.

The rotating blades of the turbine may cause the shadow flicker effect. Such impact impacts

have been mentioned in the EIA reports, however, without a detailed assessment. It was

concluded in the EIA report that such effect causes nuisance in

a distance equal to 2-3 height of WTG, thus apart from some impact during winter season

(i.e. due to presence of sun just above horizon) should not be an issue of concern at the

subject wind farm.

Measure Aiming at Limitation of the Impact

The main measure which may be used to prevent significant environmental impact of a wind

farm is a good choice of the location. Thus, during the project preparation different locations

of wind turbines have been analyzed. Preparation of the investment, apart from

technological and economic issues such as winds characteristics and costs of land purchase

and use, have taken into account the following issues, important from the perspective of

environmental protection:

existing land development and use, including distribution of residential housing, forests, farming lands, protected objects;

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mutual impact of individual objects on each other, including also possible adding up of sound waves,

necessity of protecting the objects of residential housing against noise.

location from the perspective of birds and bats protection,

The second aspect of choice, very important from the point of view of environmental

protection, was the choice of the producer and supplier of the equipment. The investor has

chosen modern installations minimal level of emitted noise. In summary it may be stated,

the layout of wind turbines has been planned in that way to achieve the following goals:

to be located out of nature and landscape protected areas,

not to disturb the continuity of ecological corridors,

not to exceed the binding environmental noise quality standards,

Post construction monitoring

Noise

The environmental decision conditions oblige the investor to conduct a post construction

noise level measurements and impact on the acoustically protected areas after start-up of

the wind farm operation. If the measurements indicate that permissible noise levels are

exceeded, then a noise reducing action will be necessary to be implemented (i.e. reduction

of the acoustic power of the subject wind turbine(s) or its temporary disconnection especially

during the nighttime are should be considered).

Birds and Bats

The environmental decision conditions oblige the investor to conduct a post construction

birds and bats monitoring. The scope of the monitoring must be agreed with the

Environmental Authorities (RDOŚ) and must cover monitoring of protected bird species and

mortality index. Similarly, the bats monitoring should be aimed at research of bats mortality

and monitoring of protected bat species.

The monitoring is to be completed twice as one yearlong monitoring, within 3 years after the

start-up of operation of the wind farm. Results are to be submitted to the Environmental

Authorities (RDOŚ) in Olsztyn every 6 month.

Should significant impact and mortality (i.e. above those presented in the EIA report) are

detected, the developer will be obliged to develop and introduce appropriate birds and bats

protection measures.

Environmental and Social Action Plan

The developer is a newly created company which will manage construction of the wind farm

and later its operations. As reported, all construction and operational tasks will be

outsourced to certified and reputable companies. In order to meet the EBRD Performance

Requirements as per Environmental and Social Policy (2008) and IFC Performance

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Standards as per International Finance Corporation’s Performance Standards on Social and

Environmental Sustainability (2006), the company will need to establish and maintain

a management structure for environmental, health and safety and social issues

management, as well as establish certain procedures and rules applying to service providers

with respect to preparation and maintaining a program for monitoring of the construction

works and then operation of the wind farm. It is proposed to develop a set of Key

Performance Indicators (KPI) to monitor environmental, H&S and social matters during

construction works and then operation of the wind farm. The KPIs should include but not be

limited to: number and type of events that could affect environment during construction

works; number and type of H&S accidents during construction works; number and type of

events that could affect communities within the influence area of undertaken construction

works and cargo deliveries; environmental emissions (including types and amounts of

generated wastes) of the wind farm during its exploitation; number and type of H&S

accidents affecting employees of the wind farm operator; number and type of accidents

affecting external individuals and causing damages; number of third party grievances due to

shadow flicker effect, electromagnetic impacts, noise and other impacts generated by

operating wind farm.

It has been proposed to develop procedures for reporting on the project status to lenders

and disclosure of information to external stakeholders. Annual reports to lenders should

present among others: status of the project implementation; key performance indicators,

summary of submitted grievances and description of how these have been addressed;

summary of stakeholders engagement activities; environmental monitoring results and

discussion; summary of actions undertaken to improve EHSS performance of the wind farm;

summary of any EHSS legislative changes that may affect the project.

After completion of the construction works it has been proposed to undertake environmental

monitoring in line with requirements of environmental decision. Should monitoring results

indicate excessive impact of the wind farm develop and implement appropriate mitigation

plan.

Additional information and grievance procedure

The mechanism for the claim procedure will be implemented by the company as part of the

project management system. The procedure assigns a coordinator of the integrated system,

who will be responsible for reacting in case of complaints.

All requests for additional information related to the Wind farm should be addressed to the Environmental Specialist of the PEP Group: Marta Porzuczek Polish Energy Partners S.A. 169 Wiertnicza Street, 02-952 Warszawa Tel: +48 22 39 08 116 Email: marta.porzuczek@pepsa.com.pl