22 mars 2019

Cette publication concerne le projet M-KAT, une centrale solaire PV de Total Eren située au Kazakhstan. Elle est publiée dans le cadre de la politique d’information publique de la BERD (Banque Européenne pour la Reconstruction et le Développement).



1       Project Description

The European Bank for Reconstruction and Development (EBRD or the Bank) are considering providing financing to the SPV MKAT Green LLP (the Company) for the construction and operation of a 100MWac solar photovoltaic power plant M-KAT (SPP) in Zhambyl Region. The Project aims to provide renewable electrical energy for the region whose development is hindered by energy deficit. The environmental and social analysis confirmed that the Project is category B in accordance with the Bank’s Environmental and Social Policy, and impacts from the project are expected to be site-specific or short term.

Figure 1 Showing M-KAT solar power plant and its surroundings. The 2.5m wide unpaved passages between the panels will connect to the paved internal roads shown in brown. Project components written in white. Social constraints shown in green.

The SPP will have 373 113 sun-tracking PV panels, 40 inverters and 30 substations that are connected to the high voltage substation from where a 12km 220kV powerline will run to a transit national network substation. An open switch unit will be constructed at this substation. The plant is expected to generate 229 000 MWh/year for the designed 25 years of the operation.

The 489ha land plot allocated for a solar power plant, 10m x 3.7km access road and 16m x 11km powerline corridors have been leased for 49 years. The open redistribution unit 30x160m area has been acquired for ownership.  For the powerline route, agreements with 5 land tenants (4 local farms and an Almaty based company) have been achieved through one off payments. Only one farmer has recently developed part of his and the neighbour land (48ha) to grow fodder crops.  The other land has not been used or developed by the tenants.

During construction both potable and technical water will be brought in tanks from Alga village well that can accommodate the estimated need of 400m3 for the whole construction period. Sewage from 100-200 construction workers will be generated over 12 months of construction. It will be collected into a 6m3 concrete well with sealed bottom. The well will be emptied by the Shu wastewater treatment facility tank truck. Both, the sump and well will be used during the operation period by four specialists, 3 cleaners and 3 guards.

Figure 2 Overview map. Project components are shown in white. Social constraints are shown in green.

Under the national legislation the project is classed as category 4 – low hazard. Its environmental health safety and social performance will be controlled at the regional level. The feasibility study has been approved by the State Technical Expertise and the preliminary EIA has been approved by the State Environmental Expertise. The company plans to develop an EHS and social management system that includes engagement of the project stakeholders.


2       Project Benefits, Impacts And Impacts Mitigation Measures

Environmental and social issues associated with the construction of a Category B (2014 ESP) project are site specific and can be readily assessed and mitigated. An independent assessment has confirmed that the technology is state-of-the-art and in line with good international practices and that the Company has the capacity to implement the Bank’s Performance Requirements (PRs).

The Project is not located near to sensitive receptors or protected areas and will have no impact on biodiversity and natural resource use. In Kazakhstan, reduction in pastures is the usual impact from a utility-scale solar plant. Here, despite fencing large part of traditionally used by the locals pasture, the impact is considered to be low for two main reasons: 1. The fenced area is poorly vegetated grassland that is used only in spring and beginning of summer and 2. The locals consider non-intensive husbandry as hard and risky business with marginal profit and would readily change to a proper job or intensive husbandry with the livestock being kept indoors. The livestock is kept by many in two adjacent villages and in the suburbs of Shu but the numbers are small and increase is only natural.

The operation will require few low skilled workers that are likely to be employed from Alga or Shu. Several skilled workers may be brought in from elsewhere at the beginning but with time, it is likely that the locals can qualify for the skilled work positions. There will be no increase in the local traffic as the only regular supply will be water and a tank truck is expected to do only 3-6 hulls a month.

The main benefit from the plant operation will be more reliable supply of power and partial reduction of energy deficit in the region. A minor long term benefit may be from encouragement of the Alga and Shu school graduates to obtain appropriate education to qualify for an electrician position at the plant. For this within its Corporate Social Responsibility Program the Company will review the possibility of grants provision for talented pupils.

A long term benefit will be from making an example of renewable energy source profitability that may encourage other developers to invest in similar projects elsewhere and by this reduce the contribution of traditional fuels to the global warming.


2.1       Water Resources

Potable and technical water will be brought in tanks from Alga village well that can accommodate the estimated need of 400m3 for the whole construction period. As little amount is used, effects on Alga village well will be negligible. Waste water will be stored in 36m3 underground concrete sump. Sewage will be collected. For the construction period 158m3 of sewage is expected to be generated. The well will be emptied by the Shu wastewater treatment facility tank truck.

There will be no fuel storage at site. A small risk of localized ground and groundwater contamination with oil is possible during the motor equipment refueling or if waste oil drums are overturned or punctured during construction. This will be reduced by arranging spills containing storages and through usage of trays under refueling connections.


2.2       Landscape and Visual Impact

Visual impact will not be significant as the site appeared not to have any aesthetic value to the interviewed residents. The SPP would represent a change from an empty field with small waste heaps and scattered plastic bags to a landscape with 2.2m high inclined dark grey plastic panels and white containers behind a 2m mesh fence. Depending on the distance, it will be seen from all sides as a 0-2m high grey massive. The area has no vintage points from which a panorama with the entire plant can be observed. The most sensitive place for visual impact from the plant is 1.3ha Sauytbek graveyard located 270m west of the SPP fence. SanPiN 2.2.1/ specifies sanitary protection zone for rural area graveyards as 50m. Taking analogy from landscape protection of cultural heritage sites [1] where 250m zone applies, it could be assumed that there will be no visual impact on the graveyard visitors. With time the graveyard may propagate towards the plant but the irrigation channel would stop it 100m from the fence. Whoever is to set the new graves, he would be aware of the plant presence and would have an option to burry at the larger Alga graveyard.

Three farmers 0.8km east of the panels will not see them behind the trees that grow along Kuigen-Sauytbek channel. The passersby along the Sauytbek-Alga road will see the panels at 0.6km distance at the eye level. Providing that the plant is not associated with loss of pasture land or irrigation water (as is shown above to be the case), the viewers are likely to be either indifferent to the change or have a positive association with this source of renewable energy.

The panels do not reflect sunlight and cannot blind the drivers and the mentioned viewers. Impact on birds from collision with the panels (so called ‘lake effect’) is considered to be negligible because the panels surface is texturised and covered with anti-reflective coating.


2.3       Local Traffic, Road Safety, Noise and Vibration

There will be no impact from noise dust and vibration from the equipment and materials transfer to the site. Most of it will be brought to the railway spur 400m from the access road starting point. The 3.7km access road passes a dormant material base on its way to the SPP. There are no housing or other enterprises on the way.  It is expected that no more than one truck will pass along the road each 15 min.

There will be no obstacles or risks to the local drivers or damage to the road surface. The entry to the Oktabrsiaya Street from the spur will be to the right without crossing the upcoming traffic lane as the street allow only the right turn there. After the U-turn the trucks will slip to the right onto the project assess road. The road police assistance may be required for arrangement of oversize equipment trucks turn left on the street entry. This street span has no residential houses, schools, play grounds etc. and the traffic intensity is relatively low.

Caterpillar pneumatic hammers that ram the panel polls into the ground may generate up to 110 dB(A) pulse noise at source. Because the ground is soft and porous, each hammering session will be short. The wind will deflect direct propagation of this noise to the houses. Noise from the heavy earth moving equipment and trucks is expected to be below 85dB(A) at source. The area is flat and thus will require minimal earthwork. This noise will dissipate to the background level at about 100m from this equipment. Noise from the other equipment e.g. cranes and forklifts will be considerably lower.

There will be no significant traffic noise or air pollution during SPP operation.


2.4       Impacts to Existing Infrastructure and Public Services

The operation will require few low skilled workers that are likely to be employed from Alga or Shu. Around 50 imported skilled construction workers are expected to be hosted in various accommodation in Shu that is expected to comply with the EBRD Minimum Accommodation Requirements. These imported workers will mainly be men, but their presence in Zhalagash and at the isolated site will have no gender related impact. Use of Illegal, forced or child labour will be controlled by the local labour protection inspector and immigration police and thus the associated impact is unlikely. The Company plans to include this prohibition in the construction contract and include relevant checks in the internal audits. The contractors’ health and safety environmental and social performance will be controlled through various plans and procedures and regular audits.


2.5       Consistency with Policy, Law and Other Plans

To date the project is consistent with the State policy towards promotion of renewable energy sources, legal requirements and other plans for the area of influence. It fulfils the main strategic plan to bring the renewables share in the country energy production to 3% by 2020 but also to provide additional power for further economic development of the region.


2.6       Social Management Plans, Mitigation and Compensatory Measures

Stakeholders will have access to up-to-date information on the project and grievance mechanism. Stakeholder engagement will be maintained by the Community Liaison Officer (CLO) according to the plan for the project duration. The effectiveness will be monitored and the plan updated as needed. The CLO will ensure that the groups identified as vulnerable to the SPP impact are evaluated and monitored at least once year and the most appropriate ways of engaging them in the decision making process are used.

A Corporate Social Responsibility Program (CSRP) aimed at helping the local community will be developed and agreed with Alga and Sauytbek Public Governance Council. It will use 4 criteria to select the projects: 1. Fit the allocated for CSRP budget; 2. Do not overlap with the State programs; 3. Have sustainable benefits and 4. Benefit the local community without bias to a particular group or person. For instance, making shading shelters at the meeting ground of the Sauytbek school to protect children from strong sun, helping the Alga school to provide heating to the one story classrooms once the school is connected to gas, or financing the school graduates obtainment of an appropriate for the need of the plant education can be reviewed as options.

The degree of support will depend on the financial standing of the Company. Although the Company tax contributions will not be retained locally, it will allow the central authorities to allocate larger portion of the State Budget to the town needs proposed by the local council in its Socio-economic Development Program.


3       Impacts Monitoring

Construction will be monitored through weekly checking adherence to the named above plans and mechanisms. During the operation, monitoring will be conducted monthly. Annual reports on environmental and social performance will reflect the plans implementation progress.  The reports will be checked against the legislative and the EBRD performance requirements. Monitoring is to be carried out until the loan is repaid.

This Non-Technical Summary and Stakeholder Engagement Plan (SEP) will be published prior to the Project approval by the Bank. The SEP provides a mechanism for the consideration and response to further comments. It describes the Company approach to interacting with the stakeholders, including the general public, and the disclosure of relevant information with respect to the Company operations and the project.

The CLO will ensure that the grievance mechanism is available to all stakeholders, involves an appropriate level of management and addresses concerns promptly, using an understandable and transparent process that provides feedback to those concerned without any retribution. The CLO will register the comments or grievances and control the grievance handling process. Grievances can be left in the mailboxes located on the information board at the rural area and town councils or sent by mail or via e-mail. The EBRD website will also act as a platform to receive comments. This mechanism does not limit the public’s rights to use the conventional routes to place grievances and the available legal system.

Further information can be obtained from the Community Liaison Officer Mrs. Yuliya Allakhverdiyeva, Tel.: +7 705-292-9251, E-mail: ayulena@gmail.com

[1]     Article 2.5 and 2.10 of the Rules for determining the site protection, constraining construction and landscape protection zones around the history-cultural heritage sites and for the mode of the zones use. Government of RK  #1218 from 28.10.2011.


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