As outlined in PS1, for each project that CSAIL develops, a full ESIA that meets the requirements of the Performance Standards and with supporting implementation documents will be required as part of IFC's financing conditions.  This includes screening for PS6 and the production of biodiversity action plans or similar to ensure that, where indicated, the required outcomes of PS6 are met. 

The analysis below relates to the asset already under development (TGF) and the two hydro sites that were visited as part of the appraisal.

Protection and Conservation of Biodiversity:

CSAIL?s TGF project (a 50MW wind farm project in Sindh Province) under construction is in the Jhimpir Wind Corridor located about 8 to 15 km north of the Kheenjar Lake Wildlife Sanctuary, a designated Ramsar wetland and Important Bird Area.  The E&S assessment document (Initial Environmental Examination, July 2010) prepared for TGF concluded that the project site is not a migratory route and thus there will be no effect on birds of the area, and its proposed Environmental Management Plan (EMP) therefore does not include a bird impacts monitoring for operational phase.  Based on IFC?s appraisal of other two projects by other developers in the Jhimpir Wind Corridor conducted in 2010 (Zorlu Pakistan #29251 ESRS), and 2013 (Metro Power #33496 ESRS), and monitoring results from Zorlu Pakistan (which is under operation), no significant impacts on birds by other wind farm projects in the Jhimpir Wind Corridor have been observed.  The monitoring and analysis has been under taken in collaboration with the World Wide Fund for Nature (WWF) Pakistan.  CSAIL will consult with the developer of Zorlu Pakistan and through that, with WWF Pakistan and other stakeholders as required to ensure that the operational plans for TGF include procedures or other measures to minimize the impact of bird populations.  (ESAP Action No. 9).

CSAIL is planning to develop a 100MW wind farm project (Wind Eagle Limited, or WEL) in the same Jhimpir Wind Corridor.  In conducting the detailed ESIA for this second project, CSAIL will review the cumulative impacts of both TGF and WEL and propose initial operational phase bird monitoring programs, as a precautionary principle (ESAP Action No. 9).

CSAIL?s two current proposed hydro power projects (720 Karot and 1,100MW Kohala) will be developed on Jhelum River.  Initial review indicates that neither of these projects is located in an ecologically sensitive or protected area.  The closest one identified is Machiara Reserve (National Park) located in Neelum Valley, several kilometers away from Kohala site.  IFC has invested in one hydro project upstream on the Jhelum (Star Hydro #26229 ESRS) and one downstream (Laraib Energy #28010 ESRS).  CSAIL?s updated ESIAs of Karot and Kohala will address potential impacts of Machiara Reserve and any other areas of biodiversity significance in line with IFC Performance Standard 6.

Management of Ecosystem Services:

Both Karot and Kohala HPPs will be run-of-river, whereby inundation upstream of the dam is approximately for 27 km for Karot and for 6 km for Kohala.  Both divert from and discharge back to the Jhelum River.  Based on the current design, Karot HPP will reduce the river flow for about 0.7km between the intake and discharge points, whereas Kohala HPP will reduce river flow for about 60 km between the intake and discharge.  Considering the significant length of affected river for Kohala and also that its affected river reach includes a large city with a population of 700,000 and other villages on the 60km stretch, a careful determination of guaranteed ecological flow is important to minimize adverse impacts of the Kohala project on the ecosystem services of the Jhelum River..

Both projects had preliminary proposed ecological flow levels set as part of the feasibility studies prior to CSAIL?s involvement in the projects.  CTGC?s team of hydropower experts visited Kohala and Karot sites in December 2013, and advised CSAIL to carefully review the current preliminary proposed ecological flow levels taking into consideration of cumulative impacts of multiple projects developed on Jhelum River and other relevant studies ongoing, as described in the paragraph below.  

Pakistan Water and Power Development Authority (WAPDA) is constructing the Neelum Jhelum Hydroelectric Power Plant project (969 MW) diverting water from Neelum River and discharging to Jhelum River, and, as such, the cumulative impact assessment of Neelum Jhelum HPP and Kohala HPP will affect the determination of ecological flow for Kohala.  In a broader context, the recent final order of December 20, 2013 by Permanent Court of Arbitration or ?PCA? (http://www.pca-cpa.org) on the issue of Indus Waters Kishenganga will also need to be considered in the ecological flow determination for the Kohala HPP since that order by PCA may also affect the river flow regime of both Neelum and Jhelum rivers.  Finally, the results of the current study by the Government of Pakistan and International Union for Conservation of Nature (IUCN) on Strategic Environmental Assessment for hydropower projects as part of National Impact Assessment Program (http://www.niap.pk) will need to be taken and integrated in the Kohala ESIA and supporting documentation. 

In accordance with Pakistan EIA regulations, CSAIL will update the ESIAs for both Karot and Kohala HPPs based on the revised design specifications with proposed minimum ecological flows, and submit them to relevant environmental authorities for approval.  CSAIL is now committed to conduct the ESIA for these projects, as well as for future hydro projects, to ensure that ecological flow determination is adequate in line with not only Pakistan EIA regulations, but also IFC Performance Standards and Good International Industry Practices (GIIP).