triconboston wind power project (pakistan)

Environmental and Social Monitoring Report Environmental and Social Monitoring Report – FY June 2020 Project Number: 50200-001 28 September 2020

Triconboston Wind Power Project (Pakistan) Prepared by Triconboston Consulting Corporation (Private) Limited for the Asian Development Bank This environmental and social monitoring report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “Terms of Use” section of this website. In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

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IFC PROJECT No: 38229

TRICON BOSTON CONSULTING CORP PVT LTD 150 MW WIND FARM PROJECT

JHIMPIR, THATTA, SINDH. PAKISTAN

ENVIRONMENTAL AND SOCIAL PERFORMANCE

ANNUAL MONITORING REPORT (AMR)

REPORTING PERIOD: July 2019 - June 2020

AMR Completion Date: September 28, 2020

Submitted to

Environment, Social and Governance Department

2121 Pennsylvania Avenue, NW

Washington, DC 20433 USA

www.ifc.org/sustainability

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AMR SECTION I

INTRODUCTION

IFC’s Investment Agreement requires for the Tricon Boston Consulting Corp. Pvt. Ltd. (TBCC), 3 x 49.735 MW Wind

farm projects, to prepare a comprehensive Annual Monitoring Report (AMR) on the Environmental and Social (E&S)

performance of its facilities and operations. This document comprises IFC’s preferred format for E&S performance reporting. This report for the period July 2019 To June 2020 is supplemented with annexes mainly related to Birds

Monitoring Report (BMR), Stakeholders Engagement Meetings (SEM) records, Grievance Records, Internal EHS and

CSR Audit Reports, EHS Inspection Reports, Training Evidences and CSR implementation evidences as appropriate

in order to ensure that all relevant information on project performance is reported.

Contents:

• Project Information

• Client’s Representation Statement by Sponsor authorized representative

• Summary of Key E&S Aspects during the Reporting Period

o Compliance Evaluation

o Major Environmental and Social Achievements

o Major Challenges and Issues

• Key Project Implementation data relevant to E&S Performance Evaluation

• Compliance with IFC Performance Standards

• Action Plan Status and Update

• Deviations/non-compliances

• Client’s Feedback

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AMR SECTION II

Project Information

Project Name 3 x 49.735 MW Triconboston Wind Power Projects

Project Scope Construction & Operation of 3 x 49.735 MW Wind Farm

Current Stage Operations Phase

Project Chief Operating Officer Khalid Aslam

Head of Operations Zeeshan Wali

TBCC Compliance Incharge Jawahar Lal

Admin & HR Manager Junaid Nizamani

O&M Contractor General Electric

O&M HSE Manager Arif Malik

HSE & CSR

Independent Monitoring Company

Arch Associates

Project Operational Status during COVID-19

Triconboston Consulting Corp Pvt Ltd Projects A, B, C remained Operational during the period when the

Government initiated a complete lockdown (with the exception of essential services including food,

pharmaceuticals and the power sector) from March 22, 2020 which continued till May 07, 2020. Following

May 07, 2020, Government relaxed the lockdown conditions selectively.

All the E&S monitoring requirements mainly the EHS Inspections, Birds Monitoring, EHS Audits etc

continued during lockdown as well.

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AMR SECTION I

INTRODUCTION

IFC’s Common Terms Agreement requires for Triconboston Consulting Corporation Pvt. Ltd. (TBCC) project to

prepare a comprehensive Annual Monitoring Report (AMR) on the environmental and social (E&S) performance of

its facilities and operations. This document comprises IFC’s preferred format for E&S performance reporting for the

period June 2019 to July 2020. The following template may be supplemented with annexes as appropriate to

ensure all relevant information on project performance is reported.

Contents:

• Project Information

• Client’s Representation Statement by Sponsor authorized representative

• Summary of Key E&S Aspects during the Reporting Period

• Action Plan Status and Update

• Deviations/non-compliances

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AMR SECTION II

Client’s Representation Statement by Sponsor authorized representative

I Khalid Aslam in my role of Chief Operating Officer and representing Triconboston Consulting Corporation Pvt Ltd

certify that

a) The Project is in compliance with all applicable E & S Requirements as described in the Common Terms

Agreement, and all actions required to be undertaken pursuant to the Environmental and Social Action Plan

(ESAP) and any subsequent supplemental action plans.

b) Beyond what is reported in this AMR for the current reporting period, in relation to the Project, to the best of

my knowledge, after due inquiry, there are no:

• Circumstances or occurrences that have given or would give rise to violations of E &S and labor Laws or E

&S and labor Claims;

• Social unrest, local population disruption or negative NGO attention due to the project

• Material social or environmental risks or issues in relation to the Project other than those identified by the

E&S Assessment and the Environmental and Social Review Summary.

• Existing or threatened complaint, order, directive, claim, citation or notice from any Authority.

• Any written communication from any Person, in either case, concerning the Project's failure to comply with

any matter covered by the Performance Standards;

• Ongoing or, threatened, strikes, slowdowns or work stoppages by employees of the Borrower or any

contractor or subcontractor with respect to the Project;

c) All information contained in this AMR is true, complete and accurate in all respects at the time of submission

and no such document or material omitted any information the omission of which would have made such

document or material misleading.

d) There have not been any new company activities (e.g. expansions, construction works, etc) that could generate

adverse environmental effects and there have been no new ESIA studies, audits, or E&S action plans conducted

by or on behalf of Tricon Boston Consulting Corporation, with respect to any Environmental or Social

standards/regulation/ applicable to the Project that IFC has not been notified of

Sep 28, 2020

Signature Date

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AMR SECTION III

(a) Summary of Key E&S Aspects during the Reporting Period

This section aims to identify the key E&S progress/activities/incidents during the Reporting period (include

Summary of Key Findings for the Reporting Period e.g. non-compliances, significant incidents, social unrest,

significant improvements/initiatives regarding E&S performance)

Key Project Implementation Data

Start of Construction 04 Aug 2017

Start of Commercial Operation Date Tricon-A: 15 August 2018

Tricon-B: 14 September 2018

Tricon-C: 10 Sep 2018

Gross Electricity Generation Capacity 3 x 49.735 MW (Total: 149.205 MW)

Net Electricity Generation Capacity 3 x 49.735 MW (Total: 149.205 MW)

Gross Electricity Generated during Review Period 370.11 GWh

Net Electricity Generated during Review Period 360.06 GWh

Plant Capacity Factor %

(–Gross Electricity generated (GWh/year) / Gross electricity

generation capacity MW x 8,760 hour/year)

28.32%

Please report on:

• Compliance with ESMP

o Currently Issue 1 of Operational Phase ESMP is followed for

implementation. The following areas has been updated w.r.t Operation

Phase

▪ Environmental and Social Management Plan

▪ Stakeholders Engagement Plan implementation based on IFC Guidelines

considering COVID-19

▪ Birds Monitoring Plan based on IFC Protocol for Carcass collection and

preservation

▪ Organization Structure and Job Descriptions

▪ Training Plans

▪ System Procedures related to O&M activities

▪ Emergency Preparedness and Response Plan

o Inspection and Auditing methods are used to monitor compliance against ESMP.

o O&M Operator follows the procedure of HSE incidents recording and reports the HSE

Statistics monthly basis including near misses (Refer Annexure-4).

o Summary of Compliance Status monitoring through Inspections performed by O&M

Operator and Independent Monitoring Consultant (IMC) and Auditing performed by

Independent Monitoring Consultant is shown below while the sample of EHS Inspection

Reports by O&M Operator and IMC are attached in Annexure 4 & 5 along with EHS

Statistics

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o During the review period, E&S Management System audit was performed in Feb 2020.

Total five non-conformances were identified of which two were major in nature and

three were minor. Due to pandemic, project was operating with lean structure and

these audit findings were not closed during the review period.

o From Mar 2020-June 2020, during the lockdown imposed by Government,

0

5

10

15

20

25

30

35

40

Jul-19 Aug-19 Sep-19 Oct-19 Nov-19 Dec-19 Jan-20 Feb-20 Mar-20 Apr-20 May-20 Jun-20

TBC-A-HSE Statistics

Total No of Violation Open Closed

0

5

10

15

20

25

30

35

40

45


TBC-B-HSE Statistics


0

10

20

30

40

50

60

70


TBC-C-HSE Statistics


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Independent Auditing was not performed however Independent Inspections continued

during the lockdown period.

o Triconboston plans to perform detailed analysis of HSE Statistics on Quarterly basis

and identify the HSE Violations trend and HSE Violations close out time. Based on

these analyses, training needs will be identified, and Turn Around Time (TAT) will be

established for different type of HSE violations.

• Regular ornithological monitoring reports / on-site bird monitoring data

o Birds Monitoring Reports (BMR) for the period July 2019-Jun 2020 are

attached in Annexure -1. There was no mortality identified during the review

period. First Quarter 2020 data reflects the back migration while April-June

2020 data shows decline in bird population and number of species observed

in the area mainly due to high temperature in the area during summer.

o During the review period, 41 species of birds were recorded from Tricon

Boston projects, including IUCN declared Endangered (EN) and Vulnerable

(VU) species of Eagles and Falcons. Steppe Eagle population has reduced in

the project area while the same species is recorded in neighboring projects in

the same monitoring period. Similarly, Cream colored courser is not recorded

within the project area during the entire monitoring period though earlier

during the construction phase and in first year of operation, it was recorded

at Project C in good numbers.

o Details of monitoring data recorded through Vantage Point method and

Ground Search method and analysis and commentary on data can be found

in the quarterly Birds Monitoring Reports in Annexure-1

o Based on the recent IFC Supplementary Studies of Super Six projects carried

during the period Dec 2019-May 2020 and report issued in June 2020,

IFC Biodiversity Consultant has advised to change the data reporting

template and record the data as “ Target” and “ Non-Target” Species and monitor the flight height of target species in relation to rotor height. The

revised templates and data recording and analysis will be implemented from

upcoming migratory season of 2020-2021

o IFC has advised to implement the carcass preservation procedure and for

this purpose protocol to implement the program has been shared.

o A training session of local consultant by IFC Biodiversity Expert has been

planned during upcoming migratory season and protocol will be

implemented post training.

• Progress in ESAP implementation and any updates in relations to ESAP action items

o All the ESAP items have been closed and currently in compliance status.

• Major Environmental and Social Achievements

o Using ISO standards, initiation of development and implementation of

Quality, Environment, Occupational Health & Safety, Social, Energy and

Asset Management Systems development as single integrated management

system in Tricon Boston Consulting Corp Pvt Ltd

o Fully Equipped Clinic with ambulatory support to handle the emergencies

has been established at Tricon Boston site. The clinic will cater to both,

personal working at project site as well as to Tricon Boston neighborhood

community.

o Adequate preventive and monitoring measures were implemented from the

start of COVID-19 and plant operations were not closed any day due to

pandemic. SOP for COVID-19 Preventive Measures is included in Annexure-

8

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• Major Challenges and Issues for the company

o Cost Effective waste management as due to absence of Sindh Environmental

Protection Agency (SEPA) authorized /approved Waste Management

Company in the local vicinity, the cost of waste disposal through urban

center based SEPA approved waste management companies is high.

o Inclusion of O&M Contractor w.r.t. E&S implementation and their

willingness to offer compliance records for third party/independent

verification

o Effective Implementation of COVID-19 Precautionary measures at Site and

TBCCPL has taken effective Monitoring Measures as mentioned in Annexure

-08

Project Status

Select the status of the project and provide a brief description of the developments in relation to the project over

the reporting period. For example, has construction been started or completed, has new equipment been installed,

has production capacity increased, or is the investment in new projects considered?

❑Design ❑Construction ❑ Expansion ❑Operation ❑ Closure ❑ Other (specify)

Currently project is in Operation Phase Since September 2018

PS1: Assessment and Management of Environmental and Social Risks and Impacts

Please provide details on the status of the following voluntary Management systems certification schemes at your

facility, provide details below?

Not being

considered

Future

consideration

Planning to

implement

Currently

Implementing

Successfully

implemented

Date of

certification/

re-certification

ISO 9001-Quality Management

System

❑ ❑ ❑ ❑ ❑ ❑

ISO 14001-Environment

Management System

❑ ❑ ❑ ❑ ❑ ❑

OHSAS 18001-Occupational

Health & Safety Management

System

❑ ❑ ❑ ❑ ❑ ❑

ISO 50001-Energy

Management System

❑ ❑ ❑ ❑ ❑ ❑

SA 8000-Social Accountability

Management System

❑ ❑ ❑ ❑ ❑ ❑

Other

• Identification of Risks and Impacts: Based on the actual operation of the Company

during the reporting year, please provide a summary of the key risks and impacts that

the Company was faced with and the actions taken.

o Formal implementation of CSR initiatives

o Improvement in Local Labor Laws compliance level by O & M Contractor and

Sub Contractors including Security Contractor

o Implementation of COVID-19 precautionary measures for Business as Usual.

In order to ensure compliance, existing IMC HSE Inspections and Monthly

Compliance reports submitted to TBC Admin have been updated to include

records / status of COVID-19 precautionary measures compliance

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• Describe any changes in the organizational structure to manage environment, health

and safety, labor and social aspects during the reporting period. Describe number of

personnel in charge of E&S issues.

o For the Operational Phase, organizational structure of TBC has been revised mainly

w.r.t. E & S Compliance. Assistant Admin and Manager Admin has now been re-

designated as “Compliance Manager and Incharge” with major responsibility of E & S

Implementation and Monitoring of Social aspects compliance. Compliance Incharge and

Administration Manager of Triconboston and HSE Manager of O&M Contractor oversee

E&S issues.

o Independent Monitoring Consultant (IMC) performs HSE Inspections of O&M Contractor

activities, E&S Audit of TBC and O&M including compliance verification against Security

Management Plan

• Describe the level of environmental, social and health and safety training provided to

staff. Provide annex with list of topics, hours of training and number of participants.

o Annex-3 provides List of Trainings conducted during the period July 2019 - June 2020,

Attendance Sheets and Training Records. Below is summary of Trainings conducted

S:

No

Training Participants

Waste Management

Triconboston & O&M Contractor

HSE Inspection and Auditing

COVID-19 Precautions

Mess Hygiene Requirements

Electrical Safety and Manual Load Handling

First Aid and CPR

• During the reporting period, are you aware of any events that may have caused

damage; brought about injuries or fatalities or other health problems; attracted the

attention of outside parties; affected project labor or adjacent populations; affected

cultural property; or created liabilities for your company?

Yes No

Provide details Not Applicable

o No damage to any asset, injury to any human or any health issue occurred

at project site during the review period. Also, during the latter half of review

period (Mar – Jun 2020), visitation to project site was stopped for external

parties.

• Stakeholders Engagement---Describe any ongoing public consultation and disclosure,

liaison with non-governmental organizations (NGOs), civil society, local communities,

or public relations efforts on environmental and social aspects

o Currently regular engagement with local communities is in place. This

engagement is done formally as well as informally. During informal

engagements done by Community Liaison Officer (CLO) of Triconboston

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Consulting, feedback including grievances are sought and documented. For

formal engagements, stakeholder’s engagement meetings are planned,

community is informed and meeting conducted either at project site or at

neighboring village. Two (02) Stakeholders Engagement meetings have been

conducted till June 2020. Annex-6 has record of Stakeholder meetings and

summary of Meetings is provided below

➢ During Stakeholder Engagement Meetings Locals were asked for

any Grievances and received response that Locals are aware from

Grievance Handling System of TBCCPL and Complaint Boxes are

installed and they informed if any Grievances they will drop it in

Complaint Box for further resolution

➢ Compliance In-charge during Stakeholder Engagement informed

Locals that IMC will conduct Training Session on COVID-19

Precautions in Neighboring Villages in the month of July 2020

➢ Due to the local cultural constraints, women do not participate in

the Stakeholder’s Engagement meetings.

➢ As mentioned on page 6, Stakeholders Engagement Plan based

on IFC guidelines for COVID-19 has been updated however as the

IFC guideline was received in May 2020 therefore compliance

evidences will be shared in next reporting period AMR

➢ Summary of two stakeholders meeting (meeting 3 & 4) are

included in below table and details of meeting records (minutes,

pictures and attendance records) is referred in Annex-6

Meeting 3 dated Nov 12, 2019

S # Discussion Action Decided Action

Date:

Action By

/ Status

1 Training on Hygiene

Improvement

Mr. Jawahar Lal informed that Training will be conducted

on Hygiene Improvement by IMC in Next Month December

2019

IMC/TBCCPL

Team

2 CSR Works Update by

TBCCPL

Mr. Jawahar Lal briefed regarding CSR Works carried out

by TBCCPL and is now focusing on following CSR Works

School Renovation

Medical Camp /Ambulatory Services at Free of Cost to

Neighboring Villages

Provision of Water to Neighboring Villages

Operation of 3 Schools in Neighboring Community

Hiring of 3 School Teachers by TBCCPL

Feb 2020 IMC/TBCCPL

Team

3 Grievances and Status

Mr. Jawahar Lal informed that Grievance Management

System is developed as well as Grievance Boxes are

installed at different locations of TBCCPL and Locals are

encouraged to contact in case of any Grievance

December

2019

IMC/TBCCPL

Team

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Meeting 4 dated Feb 02, 2020

S # Discussion Action Decided Action

Date

Action By

/ Status

1 Awareness about COVID-19

Mr. Jawahar and Waseem Ali from IMC informed

during Stakeholder Engagement Meeting to all

participants about COVID-19 Precautions and

encouraged ALL Stakeholder to must wear Face

Mask and Use Hand Sanitizers

On-Going Community

Residents

2

CSR Works Update by TBCCPL.

Completion Status of

different CSR initiatives were

shared with the participants

Mr. Jawahar Lal informed to ALL that TBCCPL is

committed and working on CSR activities based on

Actual Needs and has set Objective for Continual

Improvement in CSR Works

Completion

by Dec 2020

TBCCPL

Team

3 Cleaning of Water Storage

Tanks

Mr. Jawahar Lal informed to ALL Locals that Cleaning

of Water Tanks needs to be ensured in each Village

on Monthly Basis.

Completion

by Dec 2020

TBCCPL

Team

• Briefly describe new initiatives implemented during the reporting period or additional

managerial efforts on E&S aspects (e.g. Energy/water savings, sustainability report,

waste minimization, etc)

o Implementation of ISO 50001 Standard under UNIDO EnMS/REEE program

and with the objective of reducing Energy Losses (reducing plant auxiliary

load) identified through Energy Audit

o Implementation of Quality, Environment and Occupational Health and

Safety Management System is in process. Due to COVID-19, the

implementation process was on HOLD as the Consultant were not allowed

to visit the project site. With the relaxation in lock down, the activities have

resumed and likely to be completed by end June 2021.

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Environmental & Social Performance Annual Monitoring Report-2017-18

3 x 49.735 MW Wind Power Projects

• Briefly describe the number and type of comments and/or grievances

received by the Company in relation to E&S Issues? How many have been

resolved and how many are pending? (Please attach a table with grievance

redress registry)

o During the reporting period of July 2019-June 2020, total Three (3)

grievances were recorded and out of these two were internal

grievance. All the grievances have been closed during the reporting

phase. The summary of Grievance Handling is detailed below

Reporting

Date

Reporte

d By

Source &

Nature of

Grievance

Grievance Details

Action Taken Status Root Cause

Apr 5, 2020 Murad

Palari

External /

Actual

Water Tanker Contractor did not supply water to

neighboring village on time during April 2020

Water Tanker

Contractor was

informed to intimate

Admin in advance if

there is any delay in

water delivery.

Admin arranged water

supply from other water

contractor

Closed

in May Due to lockdown, Water Tanker Contractor

vehicles water delivery frequency was reduced

temporarily.

May 5, 2020 Siddiqui

Sarki

Internal /

Actual

Salary of April received late after 07 Days Employee was paid

salary after he submit

the leave application

Closed

in May This was because employee did not submit the

leave request required before issuance of salary

Jun 7, 2020 Mir

Mustafa

Internal /

Actual

Food Quality / Safety of Security Mess not found

as per Standard

Food Contractor/ Chef

was advised to use the

food ingredients in

moderate quantities

Closed

in Jun Due to use of more spice and oil, employee was

facing health problem

During the period July 2019 to June 2020, community did not raise

any grievances related to O&M Contractor activities performed at

project site. (Annexure -07)

Formal recording of verbal grievances has been identified by IMC as

area for improvement and advised TBC Admin to play active role in

the resolution of external as well as internal grievances. Procedure

for Internal and External Grievances Handling will be amended to

incorporate recording of verbal grievances received from project

employees or community on Grievance Form.

• Provide an update on consultation, if any, with IUCN, WWF, Sindh Wildlife

Department, Sindh Environmental Protection Agency (SEPA) and Sindh

Forestry Department.

o No consultation with IUCN, WWF, Sindh Wildlife Department,

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Sindh Environmental Protection Agency (SEPA) and Sindh Forestry

Department was done during the reporting period. All

Government offices of SEPA, Sindh Forest Department, Sindh

Wildlife were closed during the period from March-June 2020.

These departments were reluctant to have virtual stakeholders

meeting during this period

o As the upcoming IFC Study regarding development of Joint

Management and Monitoring Framework (JMMF) is scheduled to

start from Jan 2021 and the TORs of study requires Stakeholder

Consultation with SEPA, Sindh Forest Department, Sindh Wildlife

and other Stakeholders, this platform will be used to have the

consultation meeting in first Quarter 2021

o The upcoming Joint Management and Monitoring Framework

(JMMF) TORs requires identification of both type of Environmental

and Social aspects which will be managed by the projects

collectively and at individual level. Currently all the projects are

executing Community work under Corporate Social Responsibility

at individual level.

• Provide a summary of complaints, if applicable, from the Social Compliant

Register (SCR) that you have committed to develop to document all

complaints received from the local communities or any other stakeholder

and to take action and implement the mitigation measure.

o Annex-7 includes records related to Internal and External

grievances received from local communities and workers and their

resolution. Summary is mentioned above on page 13

PS2. Labour and Working Conditions

Have you changed your Human Resources (HR) policies, procedures or working conditions during the

reporting period?

• ❑Yes ❑No Provide details

Provide the following information regarding your workforce: Numbers provided as on 30 June 2020

Site # of direct

employees

# female

direct

employees

# employees

terminated

# employees

hired

#

Contractor

employees

Project Site

(Total) 72 3 0 1 182

Project Owner 27 2 0 1 47

EPC Contractor

(HydroChina)

10 1 0 0 120

O & M Contractor

GE

35 0 0 0 15

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• Retrenchment: If the Company undertook any involuntary

retrenchment during the reporting year, please provide

retrenchment data including a copy of the retrenchment plan.

o Triconboston Consulting and Operation and Maintenance

Contractor did not make any retrenchment during the reporting

period due to COVID-19. The project is currently under

warranty period. By Dec 2020, this warranty period will end,

and HydroChina will reassign its resources to other under

construction projects in the Jhimpir region.

• Grievance Mechanism: Please provide a summary of the latest

grievance mechanism in effect for workers to raise workplace

concerns (also indicate nature of EHS and social issues raised by

workers, communities and other stakeholders during the reporting

period, and the nature of corrective actions taken, its outcome and

status).

o For Internal and External Grievance Mechanism, following

methods are used by workers. As the workers are employed

by EPC Contractor (HydroChina) and O&M Contractor (GE),

therefore, their verbal grievances are recorded by Admin &

HR Heads of HydroChina and GE and written grievances are

filed in the Grievance file. In case of no action from the EPC

or O&M Contractor, workers approach Admin & HR Heads

of Triconboston (TBC). TBC Admin & HR Heads interact with

the respective Contractor HR & Admin Heads to investigate

the grievances and ensure speedy resolution.

o Community related grievances are received by Admin & HR

Head of who records / documents the grievances (if received

verbally) and investigates as per the documented procedure

and work towards its resolutions. Grievances are also

received during the Stakeholders Engagement meetings.

Resolution result of all the community grievances is also

shared in the Stakeholders Engagement meetings.

Child Labor / Forced Labor: Please state whether the Company remained compliant with the

Child Labor and Forced Labor requirements of the Performance Standards.

o Triconboston Consulting and O&M Contractor and Sub-Contractor

remained compliant with the IFC Child Labor and Forced Labor

requirements during the reporting period. Tricon Boston Consulting has

placed Child Labor Prohibition sign boards in local language at different

locations for information of local communities and sub-contractors

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Occupational Health and Safety

• Describe the main changes implemented in terms of Occupational Health and

Safety (OHS) during the reporting period, e.g. identification of hazards,

substitution of chemicals, new controls, etc.

o Since this is the 2nd operational year of the projects, therefore no

changes have been made in the systems and plans

developed/upgraded for operational phase e.g. Environment and

Social Management Plan (ESMP), Stakeholders Engagement Plan

(SEP) etc. However internal audit observations will help in

identification of changes in systems and plans in order to improve

effectiveness of compliance.

• Please provide details (description, pictures,) on the accommodation

standards if the construction camp is to be established for the workforce on

the site

o Currently Project is in Operational Phase and construction camp

for workers accommodation is not in use for any project related

activity.

o There is a marked difference in number of persons present during

construction phase ( e.g., 1713 in 2018) compared to Operational

phase as currently during the reporting period Jul 2019-Jun 2020

total persons are 254

Occupational Health and Safety Indicators

Report Total numbers for each

parameter

This reporting period Reporting period – Previous

year

Direct

employees

Contractor

employees

Direct employees Contractor

employees

Total number of Employees 27 227 34 92

Male Employees 27 227 34 92

Female Employees 0 0 0 0

Total Number of Direct Workers 27 45

Total Number of workers who are

members of workers organization

47 135

Name of Workers Organization

Total man-hours worked – Annual 220524

Total number of lost time occupational

injuries

0 0 0 0

Total number of lost workdays due to

injuries

0 0 0 0

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Number of fatalities 0 0 0 0

Occupational Health and Safety Performance (Construction / Operation Phase) (IFC E&S DOTS

Indicator)

Item Number Target

Employees Contractors Total

A: Fatalities:3 0 0 0 0

B: Total Lost Time Accidents

(including vehicular):4

0 0 0 N.A.

C: Total number of lost workdays

resulting from incidents: 5

0 0 0 N.A.

D: Total man-hours worked this

reporting period:

0 0 0 N.A.

E: Incidence during this reporting

period:

(Note: Incidence = total lost

workdays / total hours worked)

0 0 0 N.A.

F: Lost Time Injury Frequency 0 0 0 11.0 or less

Rate (construction phase)

(Number of lost time accidents x 4.5 or less

(operational phase)

1,000,000 hours / total man-

hours worked = injuries per

million hours worked)

G: Lost Time Severity Rate

(Total Lost workdays x 1,000,000

hours / total man-hours worked

= lost workdays per million hours

worked)

0 0 0 N.A.

• Provide details for the non-fatal injuries during this reporting period

None to report

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Company or

contractor

employee?

Total

workdays

lost

Description of injury5 Cause of accident Corrective measures

to prevent

reoccurrence

Project Owner 0 NA NA NA

EPC & O&M

Contractor

0 NA NA NA

EPC & O&M

Contractor

Sub-Contractor

0 NA NA NA

Describe in detail fatalities and vehicle accidents, including corrective

measures (provide copies of OHS investigation and respective corrective

plan).

None to Report

Improvement Trend of Occupational Health and Safety Performance

Item 2017 2018 2019 2020

A: Fatalities:

[Employees] [Contractors] [Total]

0 0 0 0

B: Total Lost Time Accidents (including vehicular):


0 0 0 0

C: Total number of lost workdays resulting from incidents:


0 0 0 0

D: Total man-hours worked this reporting period:


0 0 0 220524 (July

2019-Jun 2020)

E: Incidence during this reporting period:


0 0 0 02

F: Lost Time Injury Frequency Rate


0 0 0 0

G: Lost Time Severity Rate


0 0 0 0

Date

of

Incident

Type of Incident

(drop down list)

Brief

Description of

Incident

Fatalities

? (Y/N)

# of

Fatalities

Preventive measures taken

after the incident

NA NA NA 0 0 NA

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Workers Engaged by Third Parties: Please provide a summary of how the Company is managing and

monitoring the performance of third-party employees in relation to the requirements of the Performance

Standards.

• TBC performs through IMC Quarterly audit of O&M Contractor and Sub-Contractor

for HSE and Social Accountability (HR & Admin) systems implementation.

Similarly, TBC binds O&M Contractor to perform audits of its sub-contractors

and report the audit results and performance ratings.

PS3. Resource Efficiency and Pollution Prevention

• Provide the following environmental monitoring data for this reporting period. If you already have

all the data requested available in another format, this can be submitted instead. Please provide

a scaled facility map showing the precise locations of all monitoring points.

o IMC advised EPC Contractor/O and M Contractor to perform Noise Monitoring on

Monthly basis and report the results in the Monthly HSE Performance Reports. Annex-

12 includes Noise Monitoring Reports for the period July 2019 to June 2020. Refer to

page 4 of the Noise Monitoring reports.

o The coordinates of the receptors are as follows

▪ Lakhmeer Palari Village-1 at Project C (67 51’ 28.40” E, 25 2’ 36.90” N) ▪ Lakhmeer Palari Village-2 at Project C (67 51’ 10.10” E, 25 2’ 36.80” N) ▪ Murad Ali Palari Village at Project B (67 47’ 55.00” E, 25 4’ 30.20” N) ▪ Siddiq Sarki Village at Project A (67 50’ 14.20” E, 25 1’ 40.90” N)

o In order to verify the accuracy of the noise measurement data, reading from two similar

noise monitoring meters is taken at the same receptor and time and compared (Internal

Calibration method)

o In June 2020, one data point exceeded the permissible limit however no corrective

action was taken due to the following reasons

▪ The area was experiencing higher background noise due to start of construction

activities in neighboring wind farm projects.

▪ It was an isolated data compared to the whole data set of one year

o Nighttime data at some receptors mainly near villages is not taken due to cultural

limitations as during summers the villagers families sleep in the open (compound of

villages).

o IFC method including Night Time measurement was followed during the Baseline Noise

Study and later on during Construction phase, during IFC Supervision visit, they were

presented the Baseline Noise Study data showing minimal background noise during

night and distance of villages from the nearest WTG and limitation to measure Noise

Data during night near the village receptors. Beside the villages, there is no sensitive

receptor within and near the project area.

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Ambient Noise Residential, Institutional or Educational Monitoring Point Location:

Ambient Noise Industrial or Commercial Monitoring Point Location8:

Ambient Noise Parameters Collection

Frequency

WBG/IFC

Maximum

Levels

(WBG/IFC Units)

TBCC Performance

(WBG/IFC Units)

Annual average of

quarterly samples

Pakistani

Maximum Levels

(Pakistani Units)

TBCC Performance

(Pakistani Units)

Annual average of

quarterly samples

Nearest Residential,

Institutional or Educational

Receptors

Daytime (07:00-22:00 hours) Quarterly 55 dB(A) 50 dB(A) dB(A) 50 dB(A)

Nearest Residential,

Institutional or Educational

Receptors

Nighttime (22:00-07:00 hours) Quarterly 45 dB(A) 42 dB(A) dB(A) 42 dB(A)

Nearest Industrial or

Commercial Receptors

Daytime (07:00-22:00 hours) Quarterly 70 dB(A) 62 dB(A) dB(A) 62 dB(A)

Nearest Industrial or

Commercial Receptors Nighttime (22:00-07:00 hours) Quarterly 70 dB(A) 62 dB(A) dB(A) 62 dB(A)

Distance from the site

boundary to the closest noise

receptors m Mentioned in Noise Monitoring Reports

Green House Gases

• Whilst this is a carbon friendly project that may generate carbon credits,

please provide an approximate measurement of total GHG emissions

from the project (e.g., vehicles, generators etc.)

o GHG emissions avoidance of the Project (IFC E&S DOTS Indicator)

Based on the total power exported to grid (360.06 GWh) during

the reporting period, the CO2 emission avoidance based on Grid

factor of 0.6174 tCO2e / MWh is 222, 301 tCO2e. The project

has not applied for Carbon credits under Clean Development

Mechanism (CDM)

o Estimated CO2 Emissions from Mobile Sources (Gasoline Vehicles)

Total

number

of

vehicles

Total

length of

distance

travelled

(km)

Gasoline

consumed

Gasoline

vehicle

efficiency

(litre /

km)

CO2

emissions

factor

(kgCO2/TJ-

LHV)

CO2

emissions

(tonCO2) (litre) (TJ -

LHV)

63046 2.68

kg/Liter

168 Tons CO2

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During the reporting period, Project did not maintain the vehicle wise fuel

consumption. Also, total fuel consumption per month was recorded without

breakdown for Gasoline and Diesel. Therefore, for the emission calculation,

CO2 emission factor for Diesel is used instead of Gasoline. In the next

reporting year, data will be reported with more detailed analysis w.r.t.

gasoline and diesel and fuel efficiency of gasoline and diesel vehicles.

Air Emissions Management Plan

During the reporting period, emission testing of backup generator at Project A,

B & C was done. Similarly, Ambient Air Quality at all three projects was

monitored as per the planned frequency. Reports of Air Quality and Emission

Testing are included in Annexure-4.

Erosion and Sediment Control Plan

As part of Erosion and Sediment Control plan during Operational phase,

Inspection of Access Roads, Water Causeways and Culverts were not performed

by the project team after last year monsoon season.

Spill Prevention and Response Plan

During the reporting period, mock drill of spillage control was performed.

Records of mock drill are included in Annexure-14

Resource Efficiency – Water Conservation Measures: During appraisal of the

Project, about [●] m3 per day of water was estimated to be required during the operational phase of the Project, and considering the general scarcity of water in the

region, the Company was planning to adopt water conservation measures including

using recycled water as much as possible. Please provide a summary of the water

conservation measures implemented during the reporting year.

o Compared to construction phase, water consumption quantity in operational

phase is not significant. Plant operations and maintenance activities do not require

water and all water requirement is limited to the accommodation building. As

water is purchased to meet the accommodation building requirements, therefore

water consumption data is recorded. We have started to record Water

Consumption Data properly in order to identify the Water Conservation Measures.

As Water Conservation Objective is developed for the Year 2021 with Action Plan,

it will be reported in Next AMR. Also, water conservation objective will be linked

with the Biodiversity Management and Monitoring Plan specifically w.r.t. use of

janitorial water for plantation of IUCN threatened species Guggul

Pollution Prevention – Waste: Please provide a summary of non-hazardous and

hazardous waste generation and minimization activities using the table below.

Please add a summary description of major recycling activities conducted.

Waste and Hazardous Materials

Triconboston ESMP has ensured that O and M Contractor collects and quantifies

of 33



the disposed waste. Since Jan 2019 O and M Contractor has started quantification

of waste however due to COVID-19, waste collection frequency decreased at

project site and its weight was not adequately documented due to strict

implementation of COVID-19 preventive measures, external contractors / parties

were not allowed to enter substation buildings. Therefore, waste collections were

primarily done from outside the substation, without recording.

To improve the documentation of Waste Management activity as per the Raw

Materials, Hazardous and Non-Hazardous Waste Management Plan, following

actions will be implemented from July 2020 and status of compliance will be

reported in next reporting period

o Audit of Waste Management Company Management Systems

o On-Site Verification of Disposal Activities at approved Disposal Sites

o Monitoring of Solid and Wastewater Collection and Disposal Activities by

Independent Monitoring Consultant

6.11 Solid Waste Management

Solid Waste refers to non-liquid, non-soluble materials that contain complex

substances. Examples of solid waste include sewage sludge, agricultural refuse,

demolition wastes, and mining residues, some which are applicable only to specific

sectors.7

TBCC is required to monitor methods of collection, storage, handling, recycling,

reuse and/or disposal of solid waste, and report these methods and measured

quantities to IFC. Please complete the information below.

IMC, as a result of formal audits of Waste Management Plan, proposed number of practical actions for

improving the current state of hazardous and non-hazardous handling and solid and liquid waste

collection, quantification and disposal of waste including monitoring of waste disposal activities

performed by Waste Management Company.

Solid Waste Type

Includes

description

Annual

Quantity

TBCC Method of Storage, Handling and/or

Treatment

Waste from

Kitchen and

accommodation

building

including offices

60,000 kg

from Project

A, B & C

All the waste (paper, plastic, metal etc.) are collected from the

source by sweepers. In the waste yard, paper, plastic, and

metal waste are stored in separate large size drums. No

treatment of any waste is performed. Similarly, any waste if

generated at the WTG locations is collected and stored in the

waste yard.

Solid Waste Management Summary

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Solid Waste Type

(Same as Above,

Description not

Included)

TBCC Method of Recycling, Reuse or

Disposal

Waste from

Kitchen and

accommodation

building

including offices

Presently TBCC is not using any option of Reuse or Disposal and all the waste

collected at the project site is sold to Waste Disposal company who further sell

the plastic and metal waste to contractors/middle men collecting waste for the

recycled industry. Oil and Grease waste generated at WTG during maintenance

activity has not been sold to any contractor and presently stored at the site. This

waste is under the administrative control of O&M Contractor and in future it will

be sold to contractor/middlemen who further sell to Lubricating plant for

extraction of baseline from these wastes.

6.11. HAZARDOUS MATERIALS MANAGEMENT

Hazardous materials are those materials that represent an excessive risk to

property, the environment or human health because of their physical and/or

chemical characteristics. Examples include explosives, toxic or flammable

gases, flammable liquids and solids, oxidizing substances, radioactive

materials and corrosive substances.

Presently no Hazardous and Hazardous waste is recycled at the project site and sold to Waste

Management Company

• Non-hazardous and Hazardous Waste Minimization Activities

Item Non-hazardous waste Hazardous waste

Generated

(ton)

Re-

cycled

(ton)

Disposed

(ton)

Recycling

ratio (%)

Generated

(ton)

Re-

cycled

(ton)

Disposed

(ton)

Recycling

ratio (%)

A B C=A-B D=B/A E F G=E-F H=F/E

5450 0 5450 0 200 0 200 0

Waste Quantity for the year 2019 were adequately documented but due to limited access to

project site and restricted number of persons working at project site during COVID-19, waste

quantities collected by Waste Disposal companies were not adequately documented

• Please add a summary description of major recycling activities conducted.

o No recycling activity done at the project site during the review period

• TBCC is required to monitor methods of collection, storage and disposal

of hazardous materials9, and report these methods and measured

quantities to IFC. Please refer to the Hazardous Materials Management

guideline for additional information.

of 33



1. Please update us on your Hazardous Materials Management Program. You

should include your Emergency Preparedness and Response Plans, and if

available, your Hazardous Materials Risk Management Plan, Hazardous

Materials Transportation Plan and/or Hazardous Waste Management Plan.

Hazardous Material Management Plan is included in the annexure of

Environment and Social Action Plan

1.2 Pollution Prevention – Liquid Effluent Monitoring Results: For the diesel generators

installed for emergency power supply to be operated only as back-up, please provide

a summary of how the small quantity of oil/oily water was treated by oil/water

separator during the reporting year.

• Oil/Grease from the generator is collected but not drained but stored separately and then

handled as per Waste Management Plan implemented by O and M Operator.

1.3 Pollution Prevention – Noise: Please provide a summary of the noise monitoring results showing

that the monitored ambient noise levels at Project affected communities were in compliance with

Pakistan noise standards and IFC EHS Guideline noise limits of 45 dBA nighttime and 55 dBA

daytime.

o During the operational phase, Noise Monitoring w.r.t. WTGs is performed for Tricon A, B &

C and data attached in Annex-12. Details of Noise Monitoring is mentioned on page 19

1.4 Pollution Prevention – Shadow flicker: Please provide a summary of the shadow

flicker monitoring results and evaluation of the accumulated exposure on residential

properties/hamlets against recommended criteria of 30 hours per year, and whether

additional mitigation measures were determined to be necessary, and if so, how they

were implemented.

o Shadow Flickering is monitored as per the plan mentioned in ESMP. As the

project site does not have any sensitive human and ecological receptor,

therefore Flickering is measured at defined distances from the base of WTG. The

last measurement point for flickering are the villages (coordinates mentioned

on page 19).

o The direction of Shadow flickering changes as the rotor direction changes but

the defined distance from the base of WTG remains the same.

o The data of exposure to residential population is not included in the report

because all the nearest villages are at least 200 meters away from the project

boundary and from the nearest WTG, the distance is minimum 500 meters.

Considering the length of blade around 51.5 meter and rotor diameter of 103

meter, no shadow is noted at the boundary of villages.

o Results of Shadow Flickering data is included in Annexure-12

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PS4 - Community Health, Safety and Security

• Using the table below list and briefly describe any new initiatives implemented in relation to

community health and safety during the reporting period. Include risk assessments, new

infrastructure and equipment; hazardous materials and safety management, transportation and

exposure to disease.

• Fully equipped Clinic has been established at Triconboston to manage the

emergencies related to project employees and to neighborhood villages.

• During the reporting period any emergency drills have been conducted with community

participation? Are the communities aware of the emergency response plans?

o Fire Drills and Emergency Evacuation Drills were conducted in Reporting

Period and records are mentioned in Annexure-16

S.# Nature of Drill Date Status

1 Fire Emergency Mock Drill Feb 28, 2020 Conducted

2 Injury Burn Response Mock Dec 06, 2019 Conducted

3 Oil Spillage Mock Drill Sep 04, 2019 Conducted

4 Oil Spillage Mock Drill May 19, 2020 Conducted

• Please describe any changes in the Company’s engagement with private/public security forces during the reporting period and any corresponding agreements.

o No change in TBC engagement with private / public security forces.

• Implementation of key actions for community health and safety: Please provide a

summary of the planned key mitigation measures of the following during the

reporting year:

• Cordoning off the construction site from free public access;

o No physical barrier is erected to prevent access of local villagers. Only work

sites are e.g. WTG, Sub-Station etc. are properly barricaded to prevent

free public access due to safety of the public and the people working at

the site.

o Security Guards and watchmen have been trained to prevent movement

of public /non-related persons to the construction site.

• Placing information boards about public safety hazards and emergency contact

information in the Project area in the local language;

o Safety sign boards are placed at the work sites. Contact Numbers are

displayed at the TSF entrance / reception.

Mitigation Measure Expected or actual date

of Implementation Planned future

mitigation efforts?

None

of 33



• Ensuring that construction phase workers are housed in labor accommodation

facilities built at least 1km from any communities.

o Project is now under Operational phase and workers accommodation for

construction workers is not applicable

• Providing health and safety training to raise awareness about STDs and HIV;

o Not yet conducted and is planned in last Quarter of 2020

• Maintaining worker behavior standards;

o Admin Officer of O &M Operator and TBCCPL ensure discipline within the

project boundary.

• Requiring each contractor to ensure that communities be advised in advance of

project progress and near-term activities where transport issues have the potential

to impact local communities.

o Community Liaison Officer of TBC informs local villagers during informal

interactions. This is also done through stakeholder’s engagement meetings

record is attached in Annex-6

b) Implementation of key actions for security personnel management: Please provide a

summary of the planned key mitigation measures of the following during the

reporting year:

• Providing necessary trainings to the security staff about the appropriate use of

force where applicable toward workers and affected communities in line with IFC

PS4.

• Triconboston has developed a Security Management Plan (SMP) based on

IFC PS 4 and all measures, as defined in the SMP, are implemented at site

through third party security company

PS6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources

Birds Monitoring and Turbine Shutdown System

(i) Please provide detailed summaries of all birds monitoring data, bird strikes, shutdown orders

as per the requirements of the ESAP and the EMP (as appropriate use the template below to

report this information).

• During the reporting period, no bird collisions and mortality were recorded

(ii) Please provide summary of monitoring undertaken (name of consultants (if used), hours and

frequency of monitoring techniques and survey methodologies used for birds.

• Arch Associates is performing the Ornithological studies. An Ex-WWF Ornithologist

and three surveyors perform the monitoring activities based on the Birds Monitoring

Plan. Birds Monitoring Plan is developed using the Scottish Natural Heritage guideline

(referred by IFC in EHS Guideline for Wind farms Aug 2015)

• Each vantage point is monitored for three hours for each session during the week. In

total the monitoring is divided into three sessions i.e. morning, afternoon and

of 33



evening. From July 2020, new template has been adopted for recording of Birds data

with distinction of target and non-target species.

Biodiversity Value Key Performance Indicator Comment

Collision Risk Analysis summary Bird mortality (wintering,

migratory, breeding species).

List species killed and

conservation status

Annexure-1

Turbine shutdown System

TBCC will retain an

Independent Ornithological

Expert (IOE) to establish a

monitoring program that would

contain an agreed protocol for

mitigation measures, including

the reduction of the speed of

the turbines or, potentially, for

the turbines to be temporarily

turned off should a migrant

flock be observed to be

approaching either site.

Date and duration

Specify whether species are

resident, migratory, breeding or

over-wintering in the area

• Please attach monitoring reports and data as necessary

Implementation status of the key actions: Please provide the implementation status / key findings and

follow-up actions of the following:

• [Bird monitoring activities by a bird monitoring consultant ([name]) retained by the Company];

o Triconboston has retained Arch Associates (AA) as consultant for performing the

ornithological studies. An Ex.WWF Ornithologist and three surveyors perform the birds

monitoring using the Vantage Point methodology as per Scottish Natural Heritage

protocols.

• Detailed and prolonged studies on the impacts on birds to be conducted during the migratory

season of birds (October – March) and the bird monitoring report issued by [name];

o Birds monitoring studies were conducted as per the Birds Monitoring Plan and each

season Birds Monitoring report is attached in Annex-1

• Bird mortality count in the immediate vicinity to establish any links between the wind turbines

and birds mortality for two years starting from the commissioning of the wind farm;

o Birds Monitoring activities using Vantage Point and Ground search methods were

conducted during the review period. Few Birds mortality events were recorded during

the review period however their carcasses were not preserved as IFC guidelines for

carcass preservation was received in Aug 2020. Also based on the new birds monitoring

methodology prescribed by IFC and implemented in IFC Super Six projects, Birds

of 33



monitoring activities including data collection and recording have been amended from

July 2020

• Review of the results and recommendations of the [bird monitoring study], and the need for

additional mitigation measures beyond what were described in the [Final Initial Environmental

Examination Update].

o IFC Biodiversity Expert has advised to start the process of carcass collection and

preservation as per the protocol developed by IFC.

o A formal training of Biodiversity Consultant has been planned by IFC on methods of

Fatality monitoring, carcass collection and preservation and Fatality Estimation

Software GenEst use

(iii) What changes, if any are being proposed to the EMP based on this monitoring?

• None, based on the monitoring period (July 2019 – June 2020)

(iv) Summary of any coordination or engagement with any local or international bird NGOs/

conservation organizations.

• No consultation with IUCN, WWF, Sindh Wildlife Department, Sindh

Environmental Protection Agency (SEPA) and Sindh Forestry Department

was done during the reporting period. At the moment its unlikely to have

this meeting at project site due to COVID-19 and once the IFC protocol

advises to resume the normal method of Stakeholders Engagement, this

meeting will be planned.

• As the upcoming IFC Study regarding development of Joint Management

and Monitoring Framework (JMMF) is scheduled to start from Jan 2021

and the TORs of study requires Stakeholder Consultation with SEPA, Sindh

Forest Department, Sindh Wildlife and other Stakeholders, this platform

will be used to have the consultation meeting in first Quarter 2021

(vi) Please summarize any changes in Pakistani law relating to any Environmental Matter

concerning the Project

• Recent No Objection Certificate (NOC) issued by Sindh Environmental Protection

Agency (SEPA) to wind farms, explicitly mention the IFC Performance Standards as the

criteria for compliance w.r.t. EHS.

(vii) Please provide a summary of any changes to the Jhimpir wind corridor area and any new

regulatory action associated with the area including management requirements or restrictions.

• Currently ten new wind farms are under construction in neighborhood of Tricon

Boston and out of these 10, six are IFC Super Six projects

• Rainfall of 2019 and 2020 has impacted the Flora and Fauna Biodiversity positively

with agriculture activities happening in the area due to water availability

(viii) Please provide a summary of any agricultural crop management restrictions or controls that

TBCC has required/ implemented to control or mitigate risks to biodiversity

of 33



• As the Jhimpir Wind Region biodiversity has completely changed after regular rainfall

in 2019 and 2020, therefore formal Biodiversity Assessment will be done and

completed by Dec 2020

Using the table below describe any new activities or expansions that have increased the project footprint

into new areas of habitat during the reporting period.

New activity/expansion Total area covered Habitat type

No new activity Same as per original

plan/layout

During the Due-Diligence and Construction phase, IFC did not recommend any formal Biodiversity

Assessment of Project area. However, as the new studies at IFC Super Six projects and other under

construction projects have revealed the presence of IUCN threatened botanical specie Commiphora

wightii (Guggul), therefore now Tricon Boston will undertake the Biodiversity Assessment to determine

the presence of Guggul. As the Jhimpir Wind Region biodiversity has completely changed after regular

rainfall in 2019 and 2020, therefore formal Biodiversity Assessment will be done and completed by Dec

2020. Formal Biodiversity Management and Monitoring Plan and results of plantation will be reporting

in next reporting period

Using the table below provide details of (deforestation i.e. removing the plantation) conducted during

the reporting period.

Site Total area

cleared of

mangroves/

plantation

Type of species

lost Total area

replanted Type of

species

planted

Replanted

mangroves for

commercial

use Y/N

None

As IFC has increased its focus on other aspects of Biodiveristy mainly Flora after reporting of IUCN

threatened species in Jhimpir area an Ecological Assessment will be conducted to identify the presence

of this and other species in Tricon Boston project area and based on the assessment results, Biodiveristy

Monitoring and Management Plan will be developed and implemented with focus on adaptive

measures.

To determine the approximate area for Guggul plantation, following method will be used:

• Determine the area used by Sub-Station, Access Roads and WTG in projects A, B & C

• Using Google Earth, determine the historical plantation cover in project A, B & C

• Determine the required area for plantation

• Select the area for plantation

• Explore the use of janitorial wastewater (after getting water Quality results from Agriculture

University) for plantation of Guggul

1.5 Corporate sustainability activities: Please provide a summary of the Company’s corporate sustainability activities (e.g. corporate social responsibility activities,

corporate community support activities, corporate sustainability reporting activities),

if conducted during the reporting year.

of 33



o Some of CSR initiatives which were started from Construction phase are still continued

during operational phase mainly those related to provision of water to neighboring

community and support in running of three schools in neighboring villages. Also, from

Operational phase, neighboring villages are facilitated in medical service by providing them

access to Clinic established at project site in partnership with O&M operator.

1. Implementation status of the Environmental and Social Action Plan (ESAP): Please provide a summary

of the implementation status of the ESAP using the table below. Please add relevant supporting

documents / reports as necessary.

ESAP (included in IFC’s Environmental and Social Review Summary, disclosed on [date])

Task Title & Description Anticipated

Completion

Date

Implementation

Status

No. 1: The Company will get the Social Environment Health & Safety

Policy signed by its management, and will display at its corporate

office, the project operation site and at the Company’s website.

Completed Policies related to

Environment,

Occupational Health

& Safety and Social

Responsibility are

displayed at

different locations

within project site.

No. 2: The Company will monitor the CPPA-G’s [and National Transmission and Dispatch Company (NTDC) Limited’s] progress of their Environmental Impact Assessments for associated

transmission lines and a substation that are needed for

successful implementation of the Project.

Completed NTDC

Environmental

Study conducted

and copy will be

sought from NTDC

or Sindh

Environmental

Protection Agency (SEPA) office or confirmation from SEPA will be sought

of 33



No. 3: The Company will update the Corporate Social Responsibility

(CSR) program to meet the requirement of the Sindh EPA IEE

approval of [date].

Dec 2020 Community

Development Plan /

Corporate Social

Responsibility (CSR)

Plan has been

developed with

different short- and

long-term action

items. The plan is

yet to be presented

to Sapphire Group

board for approval

and budget

allocation. Due to COVID-19, review of

plan was delayed and now it will be presented for review

and approval by year end

No. 4: The Company will appoint (i) EHS Manager and Community

Relationship Officer prior to start of the construction, and (ii)

Engineering and EHS Manager, prior to start of the operation.

Completed Condition complied

during construction

phase and in

continued implementation

during Operational

Phase

No. 5: The Company will establish its HR policy and procedures in

line with IFC Performance Standard 2.

Completed Developed and

Implemented.

No. 6: The Company will develop an Employment Plan which defines

requirements and procedures on identifying and developing

employment opportunities, managing employees, recording and

reporting employment data, terminating work contracts, and other

labor-related issues, with an aim to enhance local employment. The

Plan will include a skill development program to help enhance

employability of the local population, and a local hiring program to

ensure that unskilled and semi-skilled labor be hired from the local

communities.

Completed As the project is

now in Operational

Phase therefore

modalities of

construction phase

Employment Plan

are not applicable.

Skill development

plan is now covered

under CSR Plan

workforce

employment

human resource

policies and

procedures are

addressed in HR

Manual

of 33



No. 7: The Company will prepare the storm water diversion plan

that will help to increase irrigation of the surrounding open area for

the local villagers.

Completed Storm Water

Diversion Plan has

been developed and

its implementation

will be monitored

by IMC. Also review

of effectiveness of

these plans is in

process based on

heavy monsoon

rains experienced in

Aug - Sep 2020

No. 8: The Company will review the results and recommendations

of the bird monitoring study to be conducted by [name to be

provided], and determine the need for additional mitigation

measures beyond what were described in the [date] IEE Update

(e.g. operational turbine shut-off).

Completed Birds Monitoring

Plan will be updated

once IFC Updated

CIA study is

completed and

thresholds for

different species is

defined in the

report and

applicable for all

wind farms

No. 9: The Company will re-engage with the IUCN / Completed Not applicable now

as IFC is planning to

have updated CIA of

Jhimpir wind Region

and development of

Joint Monitoring &

Management

Framework beside

Fatality Monitoring

Studies

2. Implementation status of the Environmental and Social Management Plan:

Please provide a summary of the implementation status of the following:

3.1 Implementation status of the [“Proposed Environmental and Social Management Plan for the TBCCL Wind Energy Project”]. (Please attach copies or relevant audit reports and or monitoring results).

o Refer to Annex-4 (HSE Inspection Records), Annex-5 (HSE and

HR/Admin Audits), Anex-13 (EPC/O&M Contractor and Sub-Contractor

HSE Performance Reports)

3.2 Implementation status of [(Mitigation Measures) of the Shadow Flicker

Study Report of 150 MW Wind Power Project of TBCCL].

o As there is no immediate human settlement or any sensitive receptor

of 33



within 500 meters of WTGs, no negative impact of flicker was observed

nor reported by neighboring local community during stakeholder’s consultation. Shadow Flicker Study reports are attached in Annex-12

3.3 Implementation status of [Stakeholder Engagement Plan, Tricon Boston

Consulting Corporation (Private) Limited].

o During the review period, two meetings have been conducted.

Evidences of stakeholder meetings are attached in Annex-6.

3. Conclusion/Recommendation (Please provide summary assessment of Company’s performance and suggested next steps)

o Based on the recent IFC guidelines on COVID-19, Environmental and Social Management

Plan and Stakeholders Management Plan will be amended to incorporate the IFC

guideline requirements.

o As the sub-contractor of O&M Contractor is being replaced, formal training sessions for

the new sub-contractor needs to be planned and executed.

o As IFC is now focusing flora Biodiversity and planning to implement the Joint Monitoring

& Management Framework (JMMF), Triconboston should per Flora Biodiversity Risk

Assessment due to recent changes in Biodiversity and identify any mitigation measures

if applicable

o As the local community use the project access roads and watchmen in the project area

are from the neighboring villages, it is extremely important to energize the Stakeholders

Engagement Process with the local community and train and educate them on

precautions related to COVID-19 in order to protect the community and project

operations and human capital.

triconboston wind power project (pakistan)

Documents