Kukinia Wind Farm, Poland. Stakeholder Engagement Plan (SEP)

Kukinia Wind Farm, Poland Stakeholder Engagement Plan (SEP) September 2012

Kukinia Wind Farm, Poland 313267 TRD EFR 1 A http://pims01/pims/llisapi.dll/open/1513028341 September 2012 Stakeholder Engagement Plan (SEP) September 2012

Content Chapter Title Page 1. Introduction & Project Summary 1 2. Regulatory Requirements 3 2.1 National and European Regulation 3 2.2 EBRD Requirements 3 2.3 RP Global Corporate Communication Principles/Policies 3 3. Identification of Stakeholders and Communication methods 4 4. Consultation and Disclosure Programme 6 4.1 Information Disclosure 6 4.2 Consultation Programme 7 5. Public Grievance Mechanism 8 6. Company Contact Information 9 Appendices Błąd! Nie zdefiniowano zakładki. Appendix A. AWK sp. z o.o.grievance Mechanism Błąd! Nie zdefiniowano zakładki. Stakeholder Engagement Plan September 2012

1. Introduction & Project Summary The Kukinia Wind Farm (the Project) is currently being developed by AWK Sp. z o.o. (the Project Company), a special purpose vehicle belonging to RP Global Austria (the Sponsor). The Project has received the national permits in Poland and is seeking finance from the European Bank for Reconstruction and Development (EBRD). The Project will be completed via a multi-contract arrangement with a WTG Supplier and Balance of Plant (BoP) Contractor. Enercon GmbH (Enercon) will supply the Wind Turbine Generators WTGs, foundation design and will provide Operation and Maintenance (O&M) services for the first 15 years. The BoP contractor will be Eltel Networks Olsztyn S.A (Eltel) who will be responsible for construction of the 110/30kV Project substation, a short 110kV overhead line (OHLs) from substation to existing OHL, 30kV cable installation, roads and hardstand works. Energa Operator SA (Energa) will supply the grid connection. The Project will be located in the coastal region of northwest Poland in the Zachodniopomorskie Province in six clusters. The terrain is undulating, consisting mostly of open farm land with adjacent trees. There are some significant areas of mature forestry in close proximity to the Project site and a number of small settlements are located nearby. The Project is located in close proximity to two Natura 2000 areas and three of the WTGs are to be located inside one of these areas. An overview of the Project s location is illustrated in Figure 1.1. Figure 1.1: Kukinia Wind Farm Site Location Source: Mott MacDonald Limited Public consultation and disclosure activities were undertaken during preparation of the national Environmental Impact Assessment (EIA) in 2008. In accordance with Polish regulations at the time there was no requirement to hold a public meeting so no such meetings were carried out. Rather, the EIA consultation consisted of disclosure of the EIA documentation in the offices of the Dygowo and Ustronie Morskie Communes for a period of 21 days. Subsequent to the EIA stakeholder engagement activities the Project Company has held informal discussions with local communities and disclosed information via signposts in the local communes prior to construction commencing. The Sponsor also has a website (www.rp-global.pl - Project Kukinia) where information about the project will be disclosed in the future. In the early autumn of 2012, information on the project status was presented at two local harvest festivals in Dygowo commune on 9th September and in Ustronie Morskie commune on 16th September 2012. 1

This Stakeholder Engagement Plan (SEP) is designed to promote the project s approach to stakeholder engagement going forwards. It will be available (and any subsequent updates) at the Sponsor s website and at the following locations; Dygowo Commune Contact Wójt Gminy Dygowo Marek Zawadzki Przewodniczący Rady Gminy Jerzy Leszczyński Postal Address Urząd Gminy Dygowo ul. Kolejowa 1 78-113 Dygowo Telephone Number 94 358 41 95 Email Contact wojt@dygowo.pl Ustronie Morskie Commune Contact Wójt Gminy Ustronie Morskie Jerzy Kołakowski Przewodniczący Rady Gminy Krzysztof Grzywnowicz Postal Address Urząd Gminy w Ustroniu Morskim ul. Rolna 2 78-111 Ustronie Morskie Telephone Number 94 351 55 35 Email Contact wojt@ustronie-morskie.pl 2

2. Regulatory Requirements 2.1 National and European Regulation The Project EIA and consultation activities were conducted in 2008 in compliance with the Polish Environmental Protection Act of 27 April 2001 (EA 2001) and the national permits were granted. At this time, the EA 2001 was in the process of being amended by the Polish Act on the Provision of Information on the Environment and its Protection, Public Participation in Environmental Protection and Environmental Impact Assessments of 3 October 2008 (EA 2008). The EA 2008 was passed to align Polish law with the following two pieces of European regulation which have specific consultation requirements that EA 2001 was not aligned with: UNECE Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters (known as the Aarhus Convention, 2001, to which Poland became a signatory on 25 June, 1999 and ratified it on 15 February, 2002); and European Commission (EC) Directive 97/11/EC, which was an amendment to Directive 85/337/EEC. At the time of undertaking the EIA consultation activities the project was compliant with national regulations (EA 2001). Current and future consultation associated with the project will now have to be fully compliant with current Polish and European regulations (EA 2008 and Directive 97/11/EC respectively). As previously stated, EA 2001 did not require public meetings for project such as this and they were generally never conducted. EA 2008 includes a greater emphasis on public participation and contains the Article 36 which states: The administration authority competent to issue the decision may conduct an administrative hearing open to the public. Typically, for wind farm Project in Poland such as this, this option is used and public meetings are held to disclose information about the project and the environmental and social assessment process and to collect stakeholder comments. This SEP is designed to promote the project s compliance with these current requirements. 2.2 EBRD Requirements EBRD is committed to promoting environmentally sound and sustainable development in accordance with its Environmental and Social Policy (May 2008) and the subsequent Performance Requirements (PR). EBRD sets out their stakeholder engagement requirements in the following documents: Environmental and Social Policy (2008); Public Information Policy (2008); and PR 10 Information Disclosure and Stakeholder Engagement (2008). EBRD considers public consultation and stakeholder engagement as an on-going process, to be started at the earliest stage of the environmental and social assessment process, and to be continued throughout the entire life of the EBRD-financed project. This SEP is designed to promote the Project s compliance with EBRD requirements. 2.3 RP Global Corporate Communication Principles/Policies In addition to meeting national, European and EBRD requirements, this SEP will be aligned with corporate external communication principles/policies that RP Global (Project parent company that AWK Sp. z o.o takes its policies from) has committed to producing. 3

3. Identification of Stakeholders and Communication methods The Project s stakeholders that have been preliminarily identified are presented in Table 3.1 below, as well as analysis of the best ways to engage with them according to the media that they are likely to use and be most comfortable with. Table 3.1: Identification of Stakeholders and Communication Methods Stakeholders Population Communication details Proposed Media Internal Stakeholders Project Company Employees (outsourced) Enercon (main construction subcontractor) Workers Trade Unions: AWK SP. Z.o.o is not aware of any members of staff belonging to trade unions, but they are not prohibited from joining, and if identified in the future, they will be incorporated into this SEP. External Stakeholders Villages, within a radius of 2 km: 22 Weekly/monthly internal reports and meetings 35-40 Daily tool box meetings, fortnightly safety meetings, internal bulletin boards NA at present Collective bargaining agreements. Annual meetings or meetings following the request from either party. Stojkowo 220 Head of Commune Urząd Gminy Dygowo Gąskowo 360 Address: ul. Kolejowa 1, 78-113 Dygowo tel. 94 358-41-95 e-mail: ug@dygowo.pl www.dygowo.pl Rusowo Kukinia 370 80 Head of Commune Urząd Gminy Ustronie Morskie: Address: ul. Rolna 2, 78-111 Ustronie Morskie Villages, within a radius of 5 km: tel. 94 35 15 535 E-mail: sekretariat@ustronie-morskie.pl www.ustronie-morskie.pl Ustronie Morskie 2,080 Head of Commune Urząd Gminy Ustronie Morskie (contacts as above) Dygowo 1,615 Head of Commune Urząd Gminy Dygowo (contacts as above) Sensitive local populations: to date none have been identified, but if they are identified in the future (for example schools situated on the route of construction traffic), they will be incorporated into this SEP. Large towns, within radius of 25 km: NA at present The most suitable means of providing information to each specific group (e.g. talks in local schools, newsletters) will be determined if and when such groups are identified and this SEP will be updated. 4 None. None. None. Notice boards within villages, communes and Gmina Ośrodek Kultury (Cultural center) in Ustronie Morskie Commune Email notices sent to nominated commune contact Notice boards within villages, communes and Gmina Ośrodek Kultury (Cultural center) in Ustronie Morskie Commune, Commune s web site Email notices sent to nominated commune contact As stated in communications column.

Stakeholders Population Communication details Proposed Media Kołobrzeg 47,130 Urząd Miasta Kołobrzeg Commune Address:ul. Ratuszowa 13, 78-100 Kołobrzeg Tel. 0-94 355-15-00 E-mail:urzad@um.kolobrzeg.pl www.kolobrzeg.pl Koszalin 109,248 Urząd Miasta Koszalin Commune Regional Centre: Zachodniopomorskie Province NGOs: Ogólnopolskie Towarzystwo Ochrony Ptaków (OTOP) (Polish NGO related to birds protection) Ogólnopolskie Towarzystwo Ochrony Nietoperzy (OTON) (Polish NGO related to bats protection) Zachodniopomorskie Towarzystwo Przyrodnicze Env protection Address: ul. Rynek Staromiejski 6-7, 75-007 Koszalin Tel. 0-94 348 86 17 E-mail: um.koszalin@um.man.koszalin.pl www.koszalin.pl 1,693,072 Regional Environmental Authority: Regionalna Dyrekcja Ochrony Środowiska w Szczecinie, Address: ul. Władysława Andersa 34, 75-950 Koszalin secretariat.szczecin@rdos.gov.pl Tel. 091 43 05 200 National Address: ul. 1-go Maja 5A, 72-603 Świnoujście, National Zachodniopo morskie Provincial Tel. +48 503 036 977 Email: pomorze_ zachodnie@otop.org.pl www.otop.org.pl Address: Dziekanów Leśny, 05-092 Łomianki Tel. 022 751 30 46 Email: oton@sylaba.poznan.pl www.oton.sylaba.pl Address: ul. Wąska 13, 71-415 Szczecin Tel. +48 602 667 272 Email: zto@eko.org.pl www.ztp.org.pl Email notices sent to nominated town contact Email notices sent to nominated contact Annual reports / Company website disclosure: www.rp-global.pl Project Kukinia This SEP and the above table are considered to be live, and will be updated on an ongoing basis by the Titus Foellmer or Alan Konarski of RP Global as new stakeholders are identified throughout the Project implementation. 5

4. Consultation and Disclosure Programme 4.1 Information Disclosure The Project Company will disclose a range of information to ensure that stakeholders are well informed about the Project and potential environmental and social impacts throughout the lifecycle of the Project. In some cases stakeholders will have the opportunity to comment on specific items disclosed, and the public grievance mechanisms will be available to stakeholders throughout the life of the Project. These disclosure activities are presented in Table 4.1 below. Table 4.1: Public Consultation and Disclosure Programme Information to be disclosed Timeframe Communication / media tool Internal Stakeholders Workers grievance mechanism Human resources and Environment, Health and Safety (EHS) policies and procedures Employment terms and conditions External Stakeholders Company s environmental and social policy Non-technical summary of this Project which will summarise how impacts will be managed Project schedules provided to directly affected / vulnerable stakeholders Public grievance mechanism Annual Report including a summary of environmental and social impacts, health and safety performance, implementation of external grievance mechanism. From the commencement of project activities. From the commencement of project activities. From the commencement of project activities Published on Company website by end October 2012 Timeframes to be determined see section 4.2. Immediately for works already commenced Three months prior to start of construction of other components. From the commencement of project activities. Internal newsletter Bulletin board Training sessions Intranet As above. Included in contracts Website: www.rp-global.pl Website: www.rp-global.pl Hard copies provided to local government offices to be made available for public viewing at the offices Public meetings (see section 4.2) Website: www.rp-global.pl Signposts at project locations Meetings with land owners And communes Website: www.rp-global.pl and contact details in Section 6 of this report. Opportunity for stakeholder comment Workers (including non-employees) can lodge grievances at any time throughout their employment on the Project None. None None Annually. Website: www.rp-global.pl None EIA documentation Lifetime of Project Website: www.rp-global.pl None Stakeholders will be able to submit comments for a period of 21 days before finalisation using the contact details in Section 6 of this report. Regular contact is maintained between AWK representatives, land owners and communes, who can comment at any time. Public can lodge grievances at any time throughout the lifecycle of the Project 6

4.2 Consultation Programme The stakeholder engagement activities primarily relate to disclosing information and facilitating the receipt of worker and public grievances as per the previous sub-section. However as noted in Section 2.1, some additional consultation activities are also required to ensure compliance with national and European regulations. These activities will include the public meetings to present a non-technical summary (NTS) of the Environmental and Social Action Plan (ESAP) as well as construction schedules. In the autumn of 2012 meetings will be held in: Dygowo Commune, at Gminny Zespół Oświaty i Kultury w Dygowie (Cultural Centre) ul. Kolejowa 1, 78-113 Dygowo and; Ustronie Morskie Commune, at Gminny Ośrodek Kultury (Cultural Centre), ul. Nadbrzeżna 20, 78-111 Ustronie Morskie These meetings are currently being planned and specific dates will be included in this SEP once they have been finalised. Future meetings will be arranged if and when significant project impacts are realised or scheme design or construction schedules differ significantly from that already disclosed. Meetings will be held in a culturally appropriate manner with consideration of literacy levels and the needs and concerns of vulnerable stakeholder. At the meetings stakeholders will be invited to comment on the Project and their opinions and concerns will be fed back into the ESAP. The meetings will be advertised once on the web site as noted in Section 3 21 days in advance. The meetings will be open to all of the public; however, the attendance of local community members and vulnerable stakeholders will be targeted through the distribution of leaflets and signage in the commune offices of the local villages. 7

5. Public Grievance Mechanism AWK Sp. z o.o has an established grievance mechanism which is included in full in Appendix A and summarised in this section. The grievance mechanism has been established to enable the local inhabitants raising the concerns/grievances in most accessible way directly to AWK sp. z o.o. There are three routes to submit grievances according to the phase of the project and nature of the grievance: Concerns/grievances related to the construction of the project damage from building works in particular; Concerns/grievances related to the maintenance and operation of the existing wind farm malfunctions in turbines work, noise etc; and Other concerns/grievances. These three grievance mechanisms are summarised in Table 5.1 below. Table 5.1: Grievance mechanism type Overview of Grievance Mechanism 1. Concerns/grievances related to the construction of the project 2. Concerns/grievances related to the maintenance and operation of the existing wind farm 3. Other concerns/grievances. Response / acknowledgement Timeframes Acknowledgement - 7 days; response: 30 days Negotiated compensation to be paid within 30 days of agreement. In the case of malfunction, immediate acknowledgement to arrange a meeting at specific location to investigate. In the case of damages, Acknowledgement - 7 days; response: 30 days. Negotiated compensation to be paid within 30 days of agreement. Acknowledgement - 7 days; response: 30 days; if longer, valid reason must be provided within 30 days Responsibility Community Liaison Officer: Tomasz Wójcik Technical Operation Officer: Tomasz Pawłowski Country Manager:Tomasz Zelek Contact details to submit grievance Phone: (+48) 515 053 423 e-mail: t.wojcik@rpglobal.com. Phone: (+48) 515 044 914 e-mail: t.pawlowski@rpglobal.com Phone: 507 079 780 e-mail: t.zelek@rpglobal.com The grievance mechanisms and form (see Appendix A) will be made available on the Project website (www.rp-global.pl) from the end of October 2012. Grievance forms can then be submitted to the company contact details provided in Table 5.1 above. All concerns/grievances, also in written form, can be directed to the office of the Company provided in section 6 of this SEP. Stakeholders can also submit grievances through representatives of the Commune authorities and if stakeholders are not satisfied with the response or compensation offered they are free to pursue the matter through the courts. A grievance log will be maintained by the Company s office, with the Country Manager having primary responsibility for ensuring the records are up to date and accurate. The grievance log is a database for entering information about each grievance related to the projects and activity of the Company registered verbally or in writing (by post or e-mails) and/or on a notification form for purposes of keeping track of the concerns/grievances handling. It will include complainant full name and contact information, together with a description of grievance and date of its occurrence. The stakeholders are allowed to have their name kept confidential which does not deprive their right to pursue the matter in the courts. Targets for monitoring how the grievance mechanism is implemented (e.g. response rate being in accordance with the committed timetable) will be developed by AWK Sp. z o.o to enable the performance of the grievance mechanism to be monitored and the SEP amended if required. 8

6. Company Contact Information In addition to the specific contacts provided for different types of grievances in section 5 of this report, all general comments, queries and grievances can be submitted to: Attention: Tomasz Zelek, Country Manager Company: AWK Sp. z o.o. Postal Address: Al. Wojska Polskiego 70, 70-479 Szczecin, Poland Telephone: 91 43 22 580 E-mail address: hq.szczecin@rp-global.com 9