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Stakeholders Engagement Plan Radzyń Chełmiński Wind Farm Prepared for: GB Radzyń 401 Sp. z o.o. Warsaw, Prepared by: ENVIRON Sp. z o.o. Warsaw, Date: June-July 2014 Project Number: PL1073 Stakeholders Engagement Plan Project No: Report status and issue: Project Manager: (signature) PL1073 Revised Final Maciej Rozkrut Project Director: (signature) Magdalena Trybuch Authors: Maciej Rozkrut, Agnieszka Rogowiec,Leszek Andrzejewski Date: June-July 2014 Disclaimer ENVIRON Contents Stakeholders Engagement Plan Page 1 Introduction 1 2 Requirements 1 3 Summary of Previous Stakeholder Engagement Activities 2 4 Stakeholder Identification and Analysis 3 5 Disclosure of Information 6 6 Stakeholder Engagement Program 7 7 Grievance mechanism 11 8 Monitoring 12 9 Resources and Responsibilities Timetable 13 ii ENVIRON Stakeholders Engagement Plan 1 Introduction GB Radzyń 401 Sp. z o.o. (the company) is developing a wind farm project (the project) near the municipality of Radzyń Chełmiński, Grudziądz county (powiat), Kujawsko-Pomorskie voivodeship (województwto). The project consists of 12 wind turbine generators (WTGs) in its core part and one additional WTG located in Wąbrzeźno commune, adjacent to the Radzyń Chełmiński commune. For the wind farm (WF), Vestas V112 (3 MW each, 140 m hub height) or Siemens (3 MW each, hub height 127 m) WTGs are considered. Apart from the WTGs, each of the wind farm projects consists also of an internal infrastructure of power transmission and control cables, roads and assembly yards as well as dedicated main transforming station (MTS) in the municipality of Radzyń Chełmiński. Connection to the national power grid will be developed separately by Energa Operator SA (a Distribution System Operator) as an underground 110 kv power line, appox. 500 m long, to the existing power line passing to the east of the MTS. The project (except for the Wąbrzeźno alternative option) is being developed on a green fields currently used for agricultural purposes but dedicated in the local zoning plans of the communes for development of wind farm facilities. In the Wąbrzeźno commune the local zoning plan does not exist for the subject area hence WTG development (if selected there) will be conducted based on an individual zoning decision. The core project and additional WTGs were granted environmental decisions based on the EIA procedures completed by the local authorities and were also granted construction permits (except for the WTG in Wąbrzeźno commune). The project has also secured grid connection conditions and grid connection agreement with Energa Operator SA.. This stakeholder engagement plan aims at identification of the project stakeholders at different stages of development and establishment of the rules for management of exchange of information between the company and the stakeholders 2 Requirements The company and its daughter companies are not legally obliged to publish any environmental or social reports on their environmental and social performance. Such information, however, can be published as a part of annual reports to the stockholders. Public disclosure of the project related information is required for newly developed projects at the stage of its environmental impact assessment (EIA). The scope of disclosed information includes among others general presentation of the project, its expected environmental and social impacts - including these on Natura 2000 protected areas, and measures necessary to mitigate these impacts. Disclosure of such information and securing public participation in the EIA process is managed by the authorities in charge to undertake EIA procedures. The authorities are also obliged by law to make all resolutions and decisions taken within the procedure available for public review and manage comments and grievances submitted by the interested parties. The EIA process for the projects of similar nature to the subject one is conducted at least once, prior to the environmental decision is PL ENVIRON Stakeholders Engagement Plan granted to the project. The procedure can be repeated then, if, e.g. detailed solutions adopted by the building design differ significantly from these considered at the stage of application for the environmental decision. In such case, the second EIA procedure is conducted by the authorities prior the building permit is being granted to the project. The second procedure is also open to public participation and requires in a wide range disclosure of the project related information. Although not legally required, some project stakeholders, such as e.g. the lenders, may require additional disclosure of project related information, e.g. in a form of a performance reports. At the discretion of such stakeholders, the performance reports may also be required to be publicly available. 3 Summary of Previous Stakeholder Engagement Activities The stakeholder engagement activities conducted to date comprised: Communication with landowners at the sites, negotiations of land lease contracts and signing the contracts undertaken in 2008 and Formal contacts with the communes and environmental authorities within the local zoning plan establishments and EIA procedures between 2009 and 2014 Formal contacts with Distribution System Operator while negotiating conditions of wind farm connection to the distribution networks and connection contracts. Formal contacts with Energy Regulatory Office while applying for promises for energy generation concessions. Formal contacts with road, water management, aviation and other authorities and organizations while applying for acceptances or approvals necessary for wind farms and their infrastructure designing. Formal contacts with building authorities while applying for building permits. As a part of the EIA procedures a disclosure of project related information and securing of public participation in the procedures was maintained by the commune authorities. The procedures were conducted in line with the environmental law, in particular the environmental reports and other documents were available for review by interested stakeholders who had also a right to submit their concerns. The authorities disclosed information to the stakeholders by posting appropriate notifications on their websites and information boards in the commune offices and involved villages. No meetings with local citizens and other stakeholders were arranged by the authorities. When operating in Radzyń Chełmiński commune, Green Bear followed the company s practice to build good and friendly relations with the commune and local community. GB also participated and supported numerous initiatives like: annual harvest festival since 2011 PL ENVIRON Children s Day and St. Nicholas Day since 2011 Stakeholders Engagement Plan purchase of a truck and first aid equipment for local fire brigade in August 2011 Association of local Integration and Development in 2012 Bee-keeper Day in September 2012 purchase of a boat for local fishing guard in July 2013 services for disabled people in Stakeholder Identification and Analysis The following major stakeholders groups were identified: Societies and individuals: Residents of places where investment works will be implemented; Land owners of investment sites; Workers of the company; Commercial organizations: power distribution service operators; Administrative stakeholders: Ministry of Economy (Ministerstwo Gospodarki); Ministry of Transport, Engineering and Marine Economy (Ministerstwo Transportu, Budownictwa i Gospodarki Morskiej) ; Ministry of Environment (Ministerstwo Środowiska); Energy Regulatory Office (Urząd Regulacji Energetyki) ; RDOS - Regional Directorates of Environmental Protection (Regionalna Dyrekcje Ochony Środowiska); State Labor Inspectorate (Państwowa Inspekcja Pracy); Construction Inspectorate (Inspektorat Nadzoru Budowlanego) State Sanitary and Epidemiological Inspectorate (Państwowy Inspektorat Sanitarno- Epidemiologiczny) PL ENVIRON Province Marshals (Marszałkowie Województw); Local, self-governmental administration; Stakeholders Engagement Plan Road administration at commune, county, voivodeship and national level; Police; Fire brigades. Non-Governmental Organizations: local, regional, national and worldwide avifauna protection organizations; local, regional, national and worldwide ecological organizations; Organizational stakeholders: Contractors and subcontractors executing the construction works; Equipment suppliers; Lenders International Finance Institutions. The environmental documentation prepared for the needs of the project development confirmed that none of the stakeholders will be disproportionally affected by the project implementation. The implementation of the project will result in improvement of the socioeconomic conditions of the community by generation of new working places. The project will also benefit low environmental emissions as compared to conventional power plant. Nevertheless, continuous communication with all of the project stakeholders will be maintained both at the stage of the project development and later during the facility operations. Characteristics of the stakeholders is provided in the following table: Societies and individuals Residents of communes where investment works will be implemented Citizens of Wąbrzeźno and Radzyń Chełmiński communes, in particular villages located nearby the development sites. Land owners of investment sites Company workers The company employs approximately 20 people. There are no labor unions in the company. Commercial organizations Power Distribution Service Operators Energa-Operator SA o/gdańsk ul. Marynarki Polskiej 130 PL ENVIRON Gdańsk tel.: faks.: Stakeholders Engagement Plan Administrative stakeholders Ministry of Economy Ministry of Transport, Engineering and Marine Economy Ministry of Environment Energy Regulatory Office /Urząd Regulacji Energetyki/ GDOŚ /General Directorate of Environmental Protection/ RDOŚ /Regional Directorate of Environmental Protection/ Ministerstwo Gospodarki Warszawa, pl. Trzech Krzyży 3/5 tel: faks: Ministerstwo Transportu, Budownictwa i Gospodarki Morskiej Warszawa ul. Chałubińskiego 4/6 tel: , faks: Ministerstwo Środowiska Warszawa, ul. Wawelska 52/54 tel: faks: Grants concessions, approves of energy tariffs, counterworks market monopoly. Urząd Regulacji Energetyki ul.chłodna 64, Warszawa tel: (22) , (22) , fax. (22) Generalna Dyrekcja Ochrony Środowiska ul. Wawelska 52/ Warszawa Regionalna Dyrekcja Ochrony Środowiska w Bydgoszczy ul. Dworcowa 63, Bydgoszcz tel: (052) State Labor Inspectorate Construction Inspectorate /Inspektorat Nadzoru Budowlanego/ Sanitary Inspectorate Province Marshals Local, self-governmental Główny Inspektorat Pracy Warszawa, ul. Krucza 38/42 fax: (22) , (22) and the branch of State Labour Inspectorate in Kujawsko-Pomorskie, province. Główny Urząd Nadzoru Budowlanego ul. Krucza 38/ Warszawa fax: (0-22) and province and local branches appropriate for the project location Province and country inspectorates URZĄD MARSZAŁKOWSKI WOJEWÓDZTWA KUJAWSKO- POMORSKIEGO Plac Teatralny 2, Toruń ; tel. (56) Urząd Miasta i Gminy w Radzyniu Chełmińskim PL ENVIRON administration ul. Plac Towarzystwa Jaszczurczego Radzyń Chełmiński tel. (56) , , Stakeholders Engagement Plan Urząd Gminy Wąbrzeźno ul. Mickiewicza Wąbrzeźno tel.: Road Administration Police Fire brigade Generalna Dyrekcja Dróg Krajowych i Autostrad ul. Żelazna Warszawa tel. (+48 22) and road management administration at province, county and commune level. Police stations at province. county and commune level Fire brigades at province. county and commune level relevant to the wind farm location. Non-Governmental Organizations NGOs birdlife associations local and international OTOP Ogólnopolskie Towarzystwo Ochrony Ptaków BirdLife International OTOP ul. Odrowąża Marki k. Warszawy tel: faks: World Wildlife Fund, WWF Polska ul. Wiśniowa Warszawa tel. (22) / tel. (22) / fax (22) Organizational stakeholders Construction companies Equipment suppliers Security companies Lenders International Finance Institutions Construction works are contracted through tender procedures. European Bank for Reconstruction and Development One Exchange Square London EC2A 2JN United Kingdom tel and other banks providing financial service to the company 5 Disclosure of Information Disclosure of information and further proper communication with the stakeholders is an important measure to identify issues that could affect project development or environmental PL ENVIRON Stakeholders Engagement Plan or social issues that should be taken into account to meet the good management practice rules. Disclosure of project related information will be arranged following the legal requirements as well as the international standards of project development and internal company standards. The disclosure of project related information is required by law in the following circumstances: while applying for environmental decision for the projects which significantly affect the environment or may significantly affect the environment, or, which may affect Natura 2000 zones; while applying for a building permit if another EIA is required by the authorities; in half-yearly and yearly reports on use of environment submitted to the environmental authorities; in reaction to requests of the environmental control authorities if significant breaches of the environmental law or permit conditions were indicated by such authorities. The Company will strictly follow legal requirements for disclosure of information. In order to meet the highest international standards as well as specific requirements of EBRD the company will also implement the internal procedures of information disclosure. These will comprise: presentation of the project on the company web page which will include (but not be limited to): nontechnical summary, grievance form; the web page will be updated on regular basis; presentation of the Annual EHS reports of the company environmental practices and performance on the Company web page; at the discretion of the Company PR actions in local newspapers, radio and TV and in nationwide informational media; active participation in public consultation process arranged and managed by the administrative stakeholders at the discretion of the Company direct contacts with academic and organizational stakeholders and NOGs; distribution of the project related information among the own employees and employees of the daughter companies. 6 Stakeholder Engagement Program The consultation with the stakeholders will be conducted by: PL ENVIRON Bartosz Gorgolewski Senior Project Manager; Katarzyna Skucha PR Manager; Marcin Kostrzewa Manager of Engineering and Environmental Department. Stakeholders Engagement Plan Consultations with the administrative stakeholders will follow the project assumed time schedule. At this stage it is assumed, that these stakeholders will be informed in advance of the planned project milestones, i.e. commencement and completion of the construction works. Commencement of the construction works will depend on availability of project financing by the lenders. Consultations with the internal stakeholders will follow the current routine of the GB Radzyń 401 company. These will include, among others, regular meetings of the project management team with the company management as well as exchange of information between the employees involved in the project development. Information on the project milestones will be published in advance on the company website at to be available for the public and non-governmental organizations. Moreover, the disclosure information package which will comprise: Non-technical summaries; A list of the administrative decisions related to the project Annual project-related reports will be made available for the public review at the commune authorities offices. Copies of the administrative decisions will be available from the company upon written request, however, without any personal data of individuals who participated in the administrative procedures. Also, upon written request a copy of environmental impact assessment reports will be made available. Should any issues be raised by the stakeholders, the company management will react accordingly in the shortest possible time. Below there is a summary of consultation activities that the company will undertake as part of the Engagement Plan: PL ENVIRON Stakeholders Engagement Plan Stakeholders: Consultation, communication method and objective Proposed milestones Responsibility Directly or indirectly influenced by the Program Residents of places where investment works will be implemented Company and local administration websites. Direct contacts initiated by residents. Commencement and completion of the construction works and in reaction to submitted grievances during and after the investment process. The Company. Commune administration Land owners of investment sites Company and local administration websites. Direct contacts with residents. Commencement and completion of the construction works and in reaction to submitted grievances during and after the investment process. The Company. Commune administration Company employees Intranet Meetings Continuously In line with existing routines. Commercial organizations Power distribution system operator and regular mails. Meetings. On as needed basis during the project lifetime. Company Management, Project Managers. Administrative Stakeholders Ministry of Economy Ministry of Transport, Engineering and Marine Economy Formal letters In accordance with the requirements of administrative procedures Company and project management. Ministry of Environment Energy Regulatory Office /Urząd Regulacji Energetyki/ Exchange of During the project lifetime, following legal requirements. Company Management RDOS /Regional Directorate of Environmental Protection/ Submission of monitoring reports. Mail exchange. Meetings. After completion of the construction works. Company Management. Environmental Specialist PL ENVIRON Stakeholders Engagement Plan State Labor Inspectorate /Państwowa Inspekcja Pracy/ Consultation meetings information, exchange of During the project lifetime, following legal requirements. Company Management Construction Inspectorate /Inspektorat Nadzoru Budowlanego/ Consultation meetings information, exchange of Continuous process during construction works and commissioning. Project Managers. Sanitary Inspectorate Exchange of During the project lifetime, following legal requirements. Project Managers Province Marshals Notifications, formal letters, submission of information on use of the environment. During the project lifetime, following legal requirements. Project Managers. Environmental Specialist Local government administration Consultation meetings information, exchange of Continuous process - in accordance with the requirements of administrative procedures Project Managers Road Administration Consultation meetings information, exchange of During the construction works. Project Managers Police Consultation meetings information, exchange of Fire Brigade Consultation meetings information, exchange of Non-Governmental Organizations NGOs birdlife associations local and international, local ecological NGOs Company website, information meetings, and answers to direct questions, complaints or. Continuous process - in accordance with the requirements of administrative procedures Continuous process - in accordance with the requirements of administrative procedures During the project lifetime Project Managers Project Managers Project Managers. Environmental Specialist PL ENVIRON Stakeholders Engagement Plan Organizational Stakeholders Construction companies Equipment suppliers Security companies In accordance with agreements between the company and construction companies, equipment suppliers and security companies. Before commencement and during construction works. Project Managers Lenders
