Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697752610464.pdf (Georgia)
Environmental Solutions ER2M LLC LESC E&S Monitoring Report 4 for Dariali HPP, December 2016 Environmental and Social Action Plan Dariali Hydropower Plant, Operations Phase Number Requirement Source of requirement Schedule/Deadline Performance Indicators and Reporting PR1: Assessment and Management of Environmental and Social Risks and Impacts 1.1 Prepare and submit reports on E&S performance (“E&S Reports” or “ESRs”).
PR1 ‐ Quarterly summaries of ‐ Agreement on formats for quarterly and annual reports ‐ Submission of ESRs in agreed format ‐ Disclosure of ESR or agreed summary on DE website performance, beginning 60 days after turbine 1 commissioning ‐ Annual detailed ESR: draft on 15 March, final 30 days after EBRD review/comment ‐ Frequency and formats may be modified by mutual agreement 1.2 1.3 Maintain qualified professional to manage/ oversee Health, Safety, and Environment (HSE) training and performance and maintain the position Finalize ESMS, including management plans and relevant O&M procedures/ manuals, so as to meet the substantive requirements of ISO14001 and OHSAS 18000.
Relevant plans and procedures that are part of the ESMS include: ‐ Instructions for Maintenance of Dariali Hydro Technical Structures PR1 ‐ Maintain: throughout ‐ Retention/replacement of qualified operation professional ‐ Notify Lenders of any change in status ‐ Proposed replacement CV to be provided for Lender non‐objection PR1 ‐ Resolve inconsistencies and conflicts: March 15, 2017 ‐ ESMS approved and in place: ‐ ESMS updated with all relevant plans ‐ Records maintained in accordance with ESMS requirements June 2017 ‐ ESMS certified under ISO9001 & 14001, OHSAS18001: TBD ‐ ESMS implemented: ‐ ESMS certified ‐ Summary and highlights of performance in ESRs ‐ Summary of ESMS review and revisions included in ESR Page 1‐2 Environmental Solutions ER2M LLC LESC E&S Monitoring Report 4 for Dariali HPP, December 2016 Environmental and Social Action Plan Dariali Hydropower Plant, Operations Phase Number Requirement Source of requirement Schedule/Deadline Performance Indicators and Reporting ‐ Occupational Health and Safety Plan, including emergency response plan ‐ Adaptive Management Plan ‐ Reinstatement Plan & Terrestrial Biodiversity Plan ‐ Waste Management Plan 1.4 Review ESMS against E&S performance and update as needed PR1 continuously throughout operation ‐ ‐ ‐ Review: annually ‐ Update: as determined necessary by reviews or Lenders 1.5 Review OHS and waste plans approved by authorities against plans prepared for Lenders and resolve conflicts and inconsistencies PR2: Labour and Working Conditions 2.1 Maintain worker accommodations to meet EBRD guidance (Workers’ accommodation: processes and standards, September 2009) ‐ ESMS reviewed annually against performance ‐ ESMS revised/renewed as needed ‐ Results of review, and revisions if needed, reported in annual ESR ‐ Goal: Plans reviewed and consistent ‐ Inconsistencies and conflicts identified and resolved PR1 ‐ Review and identify inconsistencies: February 15, 2017 ‐ Resolve inconsistencies: ‐ Report to Lenders summary of resolved March 31, 2017 issues and any
 remaining conflicts PR2 Continuously ‐ Goal: accommodations meet standards ‐ Quarterly inspections of accommodations ‐ Inclusion of inspection reports, and remedial actions taken, in annual ESRs Page 1‐3 Environmental Solutions ER2M LLC LESC E&S Monitoring Report 4 for Dariali HPP, December 2016 Environmental and Social Action Plan Dariali Hydropower Plant, Operations Phase Schedule/Deadline Performance Indicators and Reporting Number Requirement 2.2 Implement Occupational Health and Safety Plan, including periodic reviews and revision.
Conduct Root Cause Analysis after every lost‐time incident and fatality.
Source of requirement PR1, PR2 ‐ Implementation: Continuously ‐ Review Plan: annually ‐ Revise Plan: as needed ‐ Root Cause Analysis and report: 30 days after incidents 2.3 Maintain worker grievance mechanism PR2 Continuously and as required PR3: Pollution Prevention and Resource Conservation 3.1 Implement the Waste Management Plan, including relevant requirements of O&M procedures for clearing the trash rack and managing floating and non‐ floating waste in a way that does not involve downstream discharge PR1, PR3 Continuously ‐ Goal: zero fatalities and lost‐time incidents, all workers trained, training records up to date ‐ Report fatalities and serious injuries immediately ‐ Report OHS statistics in ESRs ‐ Root cause analyses completed as required ‐ Plan reviewed on annual basis and revised as needed ‐ Workers aware of GRM ‐ Grievances resolved quickly ‐ Worker grievances and resolutions listed in ESRs ‐ Goals: zero major spills, minor spills cleaned up within 24 hours ‐ Hazardous materials managed in accordance with WMP ‐ Records up to date ‐ Report major spills immediately ‐ Report waste generation, reuse/recycle, and disposal in ESRs Page 1‐4 Environmental Solutions ER2M LLC LESC E&S Monitoring Report 4 for Dariali HPP, December 2016 Environmental and Social Action Plan Dariali Hydropower Plant, Operations Phase Number Requirement PR4: Community health, safety, and security 4.1 4.2 Erect and maintain fences, barriers, and other means to prevent public access to dangerous and unstable areas.
Post signs at locations potentially open to public access Add procedure for inspection of safeguards to the Instructions for Operation and Maintenance of Dariali HPP Hydro Technical Structures as needed.

Disseminate information on public safety, including off‐limits areas.

This could include open houses for schools and local officials and community members, presentations in public schools and other open fora.
Source of requirement PR4 Schedule/Deadline Performance Indicators and Reporting Erect: as weather permits, no later than June 30, 2017 Inspect: as required by Instructions Maintain: throughout operation ‐ Fences, barriers, signs, and other protective measures erected ‐ Inspection and maintenance: as required to prevent access to dangerous and unstable areas PR4, PR10 Disseminate information: ‐ Report on actions taken to protect public open houses and presentations as specified in revised SEP (see requirement 10.1) safety ‐ Report immediately any incidents that compromise public safety ‐ Report all incidents of unauthorized access in ESRs PR6: Biodiversity protection and sustainable management of living natural resources 6.1 Implement the Adaptive Management Plan, including training of local specialists and transfer of responsibility from Blue Rivers to local participatory monitoring over time PR6 As specified in AMP and agreed with Lenders ‐ Monitoring program implemented as specified in AMP and December 2016 Blue Rivers report ‐ Highlights of implementation summarized in ESRs, including data on fish migration/movement Page 1‐5 Environmental Solutions ER2M LLC LESC E&S Monitoring Report 4 for Dariali HPP, December 2016 Environmental and Social Action Plan Dariali Hydropower Plant, Operations Phase Number Requirement 6.2 6.3 6.4 Identify and recruit suitably educated/trained individual(s), possibly from local school system, to lead and participate in future fish surveys.
Maintain Blue Rivers contract through at least 2017, and have them lead and/or supervise 2017 surveys At all times, maintain total discharge through the environmental gate, spillway gates, and fish pass no less than 2.54m3/sec Source of requirement Schedule/Deadline Performance Indicators and Reporting PR6 Prior to replacement of Blue Rivers ‐ Individual(s) identified and determined to be suitable by Blue Rivers ‐ Monitoring reports provided with ESRs PR6 Extend: prior to end of Q1 2017 ‐ Blue Rivers under contract through at least 2017 PR6, AMP Continuously 6.5 Maintain flow of 0.7m3/sec through the fish pass at all times PR6, AMP Continuously ‐ Discharge maintained as required ‐ Website to report summary data on discharge rates at least monthly ‐ Report continuous discharge rate in ESRs ‐ Report immediately if discharge rate falls below 2m3/sec for more than 24 hours in any season, or for more than four continuous hours during trout migration season ‐ Discharge maintained as required ‐ Website to report summary data on discharge through fish pass ‐ Report continuous discharge rate in ESRs ‐ Report immediately if rate is less than 0.6m3/sec or more than 0.8m3/sec for more than 24 hours in any season, or for Page 1‐6 Environmental Solutions ER2M LLC LESC E&S Monitoring Report 4 for Dariali HPP, December 2016 Environmental and Social Action Plan Dariali Hydropower Plant, Operations Phase Number Requirement Source of requirement Schedule/Deadline Performance Indicators and Reporting 6.6 6.7 Implement relevant sections of the Terrestrial Biodiversity Action Plan: ‐ BAP A1.4, implement the reinstatement plan for 5 years and/or until goals of A1.4 are met ‐ BAP A1.5, A1.6: monitor habitats ‐ BAP B.1, C1.1: Restrict hunting, ban poaching ‐ C2: install & maintain bird breeding platforms/boxes Continue implementation of the Reinstatement Plan until vegetation on disturbed areas is self‐sustaining for at least three years.
Place hay to encourage seed germination, continue repairing as needed until grass cover exceeds 85% of ground surface.

Protect from livestock as needed.
more than four continuous hours during trout migration season ‐ PR6 ‐ Terrestrial As required by BAP (most are annual) ‐ Staff trained as specified in BAP ‐ Habitat and fauna monitored as specified BAP in BAP ‐ Report on implementation prepared and submitted as part of ESR PR6 ‐ Re‐seed or place hay on ‐ Goal: 75% grass cover on all disturbed disturbed areas: spring 2017 and thereafter until grass is re‐established ‐ Monitor and repair until vegetation is self‐sustaining for at least three years areas ‐ Sources of hay identified ‐ Hay brought to site and spread, possibly with protection with fencing as needed.
‐ As needed, place hay in successive seasons and years until grass is re‐ established Page 1‐7 Environmental Solutions ER2M LLC LESC E&S Monitoring Report 4 for Dariali HPP, December 2016 Environmental and Social Action Plan Dariali Hydropower Plant, Operations Phase Number Requirement 6.8 Implement all recommendations in Blue Rivers December 2016 report, as modified or supplemented by future monitoring reports Source of requirement Schedule/Deadline Performance Indicators and Reporting PR6 ‐ As provided in Blue Rivers recommendations ‐ Recommendations implemented ‐ Report deviations from recommendations in ESR PR10: Information Disclosure and Stakeholder Engagement 10.1 Revise the January 2016 Stakeholder Engagement Plan to reflect comments from Lenders PR10 ‐ Revise: within 30 days of comments ‐ Implement: continuously throughout operation ‐ Final SEP incorporates changes based on Lender comments, including regular public updates on E&S actions, including the various E&S plans (terrestrial BAP/reinstatement plan, reforestation plan, AMP, waste plan, OHS plan 10.2 Implement the final SEP, including the agreed grievance mechanism PR10 ‐ Implement SEP: throughout ‐ Goals: effective stakeholder engagement operation ‐ Resolve grievances per mechanism: within timeframes and timely grievance resolution ‐ Highlights of stakeholder engagement reported in ESRs ‐ Updates on E&S actions provided on DE website and otherwise disseminated ‐ Lists of stakeholder grievances and resolutions included in ESRs Page 1‐8