SCHEDULE 1
E&S ACTION PLAN DATED 13 MAY 2025
Action Environmental & Social Risks Resources, Required Target and Evaluation
Item. No.
(Liability/Benefits) Investment completion Criteria for Successful
Needs, date Implementation
Responsibility
1 PS 1 Risk Management
1.1 Construction Environmental & Social Management To ensure that all the Project’s Company resources Prior to start of Project E&S Management
The company will prepare and implement the Project Construction environmental & social (E&S) and consultants construction Plan, including all sub-plans
Environmental & Social Management (ESMS) including management plans are listed within this ESAP item,
consideration of the final ESIA and the outputs of any relevant implemented at the correct time submitted and accepted by the
supplemental assessments (e.g. ESAP items related to land and consistent with the ESIA lenders.
acquisition and livelihood restoration). It will be appropriate for the impacts.
Project's scale and complexity and aligned with the general
requirements of IFC PS1. This will be documented in a Project
ESMP and will include the following subplans which will be aligned
with IFC PSs, relevant WBG EHS Guidelines and local
requirements:
Hazardous material
Occupational H&S management
Pollution Prevention and Control Management
Security management
Traffic management
Worker influx management
Waste minimisation and resource efficiency and conservation
Water conservation minimisation plan and wastewater
management plan
Stakeholder Engagement
Item. No. Action Environmental & Social Risks Resources, Required Target and Evaluation Criteria for
(Liability/Benefits) Investment completion date Successful Implementation
Needs,
Responsibility
Land Acquisition Involuntary
Resettlement and Livelihoods
Restoration Action
Biodiversity management
Community Health and Safety Management
Cultural Heritage Protection and
Management Program
Emergency response
ESHS Training Management
1.2
EPC Environmental & Social Management To ensure that all the Project’s EPC Prior to start of The Project’s Environmental and Social
environmental & social management activity of the Management plans, procedures, and policies
The company will require its main O&M
plans are implemented at the correct contractor will be applied to all direct and indirect
contractor(s) to develop implementation plans
time and consistent with the ESIA workers. All contractors/ subcontractors will be
aligned with the CESMP, including policy
impacts. committed to full compliance with project’s
statements, management and monitoring
environmental management plans.
measures, and aspect-specific management plans
applicable to its scope of work." Main contractors will be required to share their
EPC E&S Management Plan, including
relevant sub- plans, submitted and accepted by
the
lenders.
Action Environmental & Social Risks Resources, Required Target and Evaluation
Item. No.
(Liability/Benefits) Investment completion Criteria for Successful
Needs, date Implementation
Responsibility
1.3
Operations Environmental & Social Management To ensure that all the Project’s Company resources Prior to start of Project E&S Management Plan,
environmental & social management (E&S) consultants operation including all sub-plans listed
The company will develop and implement an Operations
plans are implemented at the correct within this ESAP item,
Environment & Social Management System (OESMS) consistent
time and consistent with the ESIA submitted and accepted by the
with the Project ESIA commitments, the outputs of any relevant
impacts. lenders.
supplemental assessments, IFC PS, WBG EHS Guidelines, and
national requirements.
The company will require its main O&M contractor(s) to develop
implementation plans aligned with the OESMP, including policy
statements, management and monitoring measures, and aspect-
specific
management plans applicable to its scope of work.
1.4
Commitments Register To ensure that all commitments are Company resources Prior to start of Commitments register
addressed appropriately and in a (E&S) and consultants construction submitted and accepted by the
As part of its ESMS, the company will consolidate all
timely manner lenders.
environmental and social commitments made by the company in
the ESIA documentation and the ESMP and any supplemental
assessments and through acceptance of the national permits and
legal agreements stipulated by the Government of Kosovo. Table
1 in the existing ESMP can be used as a basis for preparing this
register; a column should be added to specify which entity
(company, specific contractor, or multiple contractors) is
responsible for implementing
each commitment.
1.5
Contractor Management To ensure that all contractors are Company resources Prior to start of Contractor management plan
aware of the requirements and that (E&S) and consultants construction submitted and
The company will develop a Contractor Management Plan
they are implemented
defining its approach to managing the E&S performance of its
contractors, subcontractors, and
Item. No. Action Environmental & Social Risks Resources, Investment Required Target and Evaluation
(Liability/Benefits) Needs, Responsibility completion date Criteria for Successful
Implementation
other third parties during the various phases of the Project. The accepted by the lenders
contractor management approach will be consistent with the
general principles described within IFC Good Practice Note:
Managing Contractors'
Environmental and Social Performance.
1.6
EHS Resourcing (Construction) To ensure that the company Company resources Prior to start of Written confirmation shared
resources are adequate for the Project (E&S) and consultants construction with the lenders that suitable
The company will engage a Community Liaison Officer (CLO)
requirements candidates have been appointed.
and additional resources, as required.
The company will require its contractors to appoint sufficient
counterparts to these staff, including appropriate Health & Safety
officers, to ensure satisfactory oversight of their workforce and the
Project
construction activities.
1.7
EHS Resourcing (Operations) To ensure that the company Company resources Prior to start of Written confirmation shared
resources are adequate for the Project (E&S) and consultants operation with the lenders that suitable
The company will engage adequately qualified and experienced
requirements candidates have been
biodiversity resources to coordinate and oversee its biodiversity
program(s). appointed.
1.8
Stakeholder Engagement To ensure that the stakeholder Company resources Prior to start of Revised stakeholder
engagement process has been (E&S) and consultants construction engagement plan and grievance
The company will update the Project’s Stakeholder Engagement
conducted and documented in mechanism submitted and
Plan (SEP) in accordance with the IFC PSs and national law. The
accordance with the required accepted by the lenders.
SEP will define an engagement program for each stakeholder
standards
group during the construction and operational phase of the Project,
providing clear actions, responsible persons, timelines, and KPIs
to facilitate monitoring.
The revised plan will address all relevant gaps identified in the
RSK gap analysis report.
Item. No. Action Environmental & Social Risks Resources, Required Target and Evaluation
(Liability/Benefits) Investment Needs, completion Criteria for Successful
Responsibility date Implementation
The company will also inform the community of the Project’s
workers’ code of conduct and the availability of the Project’s
grievance mechanism to raise
complaints.
2 PS 2 Labor
2.
Workers Grievance Mechanism (WGM) To ensure that the company implements a Company resources Prior to start Workers Grievance Mechanism
1
workers’ grievance mechanism that complies (E&S) and of construction submitted and accepted by the
The company will update and implement a project-level
with the lender standards and Ukrainian consultants lenders.
worker's grievance mechanism (WGM) in accordance with
labour legislation
IFC's PS2 and national law. The WGM will be available to all
project workers, regardless of their employer or employment
Evidence of appointment of a
status.
grievance officer
The WGM will include specific considerations for receiving
gender-based violence or harassment (GBVH) grievances via a
dedicated and trained focal point, with support mechanisms also Implementation verified by the
available and documented in the procedure. lenders or their representatives
during project supervision.
The company will appoint an adequately trained grievance
officer (including detailed knowledge of Kosovan labour law
and GBVH) to attend to the worker grievances and coordinate
the implementation of the WGM.
The company will make available information on its
WGM communication channels in all facilities accommodating
project workers.
2.
Workers’ Accommodation Policy To ensure that the company adopts a Company resources Prior to start of Workers’ Accommodation
2
compliant policy that provides worker (E&S) and construction Policy, submitted and
The company will develop its workers’ accommodation policy,
consultants
establishing the basic requirements that any
Action Environmental & Social Resources, Required Target and Evaluation
Item. No.
Risks (Liability/Benefits) Investment completion Criteria for Successful
Needs, date Implementation
Responsibility
accommodation meeting accepted by the
accommodation implemented as part of the Project (including
requirements and legal lenders.
contractors and subcontractors’ facilities) should comply with Kosovan
conditions
regulations, IFC PS2 requirements, and IFC's and EBRD's Good Practice
Note on Workers' Accommodation. Workers’ accommodation
If hotels and guesthouses are to be used, the company will conduct an verified as compliant by the
audit of project-provided worker accommodation facilities before lenders through company
occupancy. The audit(s) will assess the accommodation facilities' inspection reports.
compliance with local codes and regulations and IFC/EBRD standards,
and whether they are designed, constructed and operated in accordance
to internationally accepted life and fire safety standards, and to ensure
adequate considerations related to security and gender aspects. The
company will implement the corrective actions identified by the audit.
The company will update the Human Resources Plan to reflect this
policy.
2.3 Human Resources Plan
To ensure human resources Company resources Prior to start Human Resources Plan
The company will have the following labour related policies and are managed in accordance (E&S) and consultants of construction submitted and accepted by
strategies in place. with requireemntsw of PS2 the lenders
Labour conditions and workers’ contract
Worker Handbook and worker code of conduct
Labour health and safety plan
Child and forced labour policy
Equal opportunity policy
Supply chain policy
Freedom of association
Action Environmental & Social Resources, Required Target and Evaluation
Item. No.
Risks (Liability/Benefits) Investment completion date Criteria for Successful
Needs, Implementation
Responsibility
Other policies as relevant.
3 PS 3 Pollution Prevention
3.1 Pollution prevention and waste management provisions to be Company resources Prior to start of
developed as part of the ESMP requirements (Action 1.1 and 1.2) (E&S) and consultants construction
4 PS 4 Community
4.1 Traffic and Transport Management
To ensure that all traffic and Company resources Prior to start of Traffic and transport
The company will develop and implement a traffic and transport transport related risks are (E&S) and consultants construction management plan
management plan (TTMP) that is aligned with national requirements, identified and managed prior to submitted and accepted by
IFC PS4, and Good International Industry Practice (GIIP), and that is construction the lenders.
applicable to all contractors and sub-contractors. The TTMP will
include appropriate control measures to address risks posed to road
users and communities related to construction traffic, abnormal loads,
and any road upgrade work required to be executed due to the Project.
As part of the development of the TTMP, the company will conduct a
pre-construction route survey of the local road network to assess
existing road conditions and determine if specific control measures
are required.
4.2
Shadow Flicker To ensure that risks due to Company resources Implementation Confirmation submitted
shadow flicker are minimised (E&S) and consultants prior to start of and accepted by the
Company to install shadow flicker module on WTG 7 and 10 to manage
during operation operation lenders.
impacts on residential areas.
Company to install suitable screens on substation
windows to manage impacts on workforce from WTG 9.
Action Environmental & Social Risks Resources, Required Target and Evaluation
Item. No.
(Liability/Benefits) Investment completion date Criteria for Successful
Needs, Implementation
Responsibility
4.3
Blade and ice throw To ensure that risks due to shadow flicker are Company resources Implementation Confirmation submitted and
minimised during operation (E&S) and consultants prior to start of accepted by the lenders.
Company to install vibration detection on WTGs
operation
to detect ice build up or blade failure, reducing
impacts
on residential areas and at the substation.
4.4
Security Management To ensure that appropriate controls are in place Company resources Prior to start of Security Management Plan
to manage security on site (E&S) and consultants construction submitted and accepted by the
Implement a Security Management Plan in line
lenders.
with IFC ‘Good Practice Handbook - Use of
Security Forces: Assessing and Managing Risks
and Impacts,
to manage its security personnel.
4.5
Security Monitoring To ensure that security provisions are being Company resources Ongoing Monitoring report reports submitted
appropriately implemented on site (E&S) and consultants implementation and accepted by the lenders.
Monitor security personnel during construction
and operation to allow for compliance with
international best practices and IFC Good
Practice. Furthermore, monitor the public security
services (if used/applicable) to assess compliance
with international best practices
and IFC Good Practice.
5 PS 5 Land Acquisition
5.1
Develop a detailed LRP for the OHTL in line with To avoid or minimize involuntary resettlement, Company resources Prior to the start of Detailed LRP, inclusive of a land
international standard and include all land ensure fair compensation at replacement cost, (E&S) and consultants construction of the acquisition chapter (to document
acquisition activities that have already been taken and restore or improve the livelihoods and OHTL required updates for PS5
place to date and a plan for what still has to be living standards of displaced persons through compliance), submitted and
done in terms of access to land for all aspects of transparent and participatory processes. accepted by the lenders
the Project including transport routes.
The LRP should address all relevant gaps
identified in the RSK gap analysis report (Table 4-
3 – of this report), such as including a firm
committement to a
willing-buyer, willing seller process, outlining a
Item. No. Action Environmental & Social Resources, Required Target and Evaluation
Risks (Liability/Benefits) Investment Needs, completion Criteria for Successful
Responsibility date Implementation
process for socioeconomic surveys to identify vulnerable groups and
development of specific support measures for these PAPs and a clear
plan to restore and improve the livelihoods of affected land
owners/users.
6 PS 6 Biodiversity
6.1
Biodiversity Management Plan To ensure the mitigation Company resources Prior to start of Biodiversity Management
measures are fully implemented (E&S) and consultants construction Plan submitted and
Project to develop a Biodiversity Management Plan (BAP) which will
during construction accepted by the lenders.
aim to avoid impacts on biodiversity and ecosystem services. When
avoidance of impacts is not possible, measures to minimize impacts and
restore biodiversity and ecosystem services should be included in the
BAP. The BAP should incorporate mitigation from the ESIA and
additional surveys as
appropriate
6.2 Post-Construction Fatality Monitoring To ensure the monitoring is Company resources Prior to start of Operational BMP
The company will develop an operations-phase Biodiversity completed at the correct time and (E&S) and consultants operation submitted and accepted by
Management Plan (BMP), aligned with GIIP. This BMP will include is compliant with lender standards the lenders.
two key elements, aligned with the guidance published in the IFC-KfW- and GIIP
EBRD PCFM Post-Construction Fatality Monitoring Good Practice
Handbook (2023), as follows:
i. A PCFM plan intended to characterize the species
composition, seasonal and spatial patterning of bird and bat
collision fatalities, as well as estimation of bias-corrected
overall collision fatality rates for birds and bats resulting from
the operation of the wind turbines
Item. No. Action Environmental & Social Resources, Required Target and Evaluation Criteria
Risks (Liability/Benefits) Investment Needs, completion date for Successful Implementation
Responsibility
ii. an adaptive management protocol that articulates a commitment
and provides a science-based mechanism for triggering the
implementation of additional collision impact mitigation measures
if fatality rates are found (via PCFM results) to exceed
“sustainable” (equivalent to “no net loss” NNL) levels during
project operation.
8 PS 8 Cultural Heritage
8. Develop and implement a Cultural Heritage Management Plan for the
Ensure that cultural Company Prior to start of Cultural Heritage Management
1
Project to manage any impacts to cultural heritage resources. heritage is appropriately resources (E&S) construction Plan submitted and accepted by the
protected and managed and consultants
lenders.
8. Implement provisions for managing chance finds through the chance
Ensure that chance finds Chance finds Ongoing Reporting of chance finds included
2
find procedure which will be applied in the event that cultural heritage are appropriately protected procedure implementation in monitoring reports. Evidence of
is subsequently discovered. and managed during construction training being delivered to project
workers to identify potential
chance finds.
