Galnaftogaz Wind Fand E&S Due Diligence and ESIA Gap Analysis - AVGroup

Galnaftogaz Wind Fand E&S Due Diligence and ESIA Gap Analysis

Client: EBRD, IFC

The EBRD, jointly with the IFC and other co-lenders, considered providing finance to a private developer for the development of a greenfield wind power plant (WPP) in west of Ukraine. To support this financing, a comprehensive Environmental and Social Impact Assessment (ESIA) aligned with national legislation and international lender requirements (including EBRD ESRs and IFC Performance Standards) is required. AVG was commissioned to conduct a detailed review of all associated E&S documentation against the applicable requirements, perform site verification (adapted for martial law security constraints), and determine the suitability of the documentation for public disclosure. The ultimate goal of the assignment is to deliver a comprehensive Gap Closure Plan and a targeted Environmental and Social Action Plan (ESAP) to guide the project toward full compliance.

Project phases and tasks:

01
Phase 1: Review existing documentation

Evaluate the current ESIA, associated management plans, and the Project as a whole against Applicable E&S Requirements (including EBRD ESRs and EU Directives).

02
Phase 2: Identify gaps and risks

Assess deficiencies in the existing documentation and formulate recommendations to resolve them within a structured Gap Closure Plan.

03
Phase 3: Confirm disclosure readiness

Verify that the final package of E&S documentation is fit for public disclosure according to the project’s categorization and applicable wartime restrictions.

04
Phase 4: Develop assessment documentation

Draft a comprehensive Environmental and Social Action Plan (ESAP) reflecting the additional, descriptive, and distinctly separate actions required to align the Project with Applicable E&S Requirements following ESIA disclosure.

05
Phase 5: Evaluate stakeholder engagement

Determine the extent of meaningful consultation, review the ESIA disclosure process, and observe consultation activities alongside the Lenders to ensure inclusivity and effectiveness.

Key results:

  1. Completed Initial Review & Desktop Study: Conducted a comprehensive kick-off and desk-based review of all provided documentation (ESIAs, ESMPs, RAPs, permits) to establish a baseline of the Project’s current compliance status against national laws, EU Directives, and Good International Industry Practice.
  2. Delivered Summary of Initial Findings: Executed a detailed analysis of environmental/social baseline data, labor practices, contractor management, OHS protocols, cumulative impacts, and stakeholder inclusivity (especially regarding vulnerable groups and IDPs), documenting material risks requiring further assessment.
  3. Conducted Site Verification: Executed a targeted site visit, led by senior E&S specialists and supported by national experts, to validate desk-based findings, observe OHS practices, assess environmental sensitivities, verify the effectiveness of grievance mechanisms, and evaluate contextual/security risks.
  4. Finalized Assessment Report: Delivered a comprehensive report summarizing the Project’s status regarding Applicable E&S Requirements, highlighting any areas of non-compliance, and evaluating potential impacts.
  5. Developed Gap Closure Plan & ESAP: Created a practical Gap Closure roadmap prioritizing deficiencies and allocating responsibilities. Simultaneously, produced a standalone ESAP containing a sequenced set of descriptive and discrete actions—avoiding the consolidation of distinct technical requirements—with clear timelines to achieve full compliance prior to and following financial close.
  6. Facilitated Final Alignment: Integrated feedback from the Lenders and the Company, delivered key findings presentations, and provided a finalized E&S documentation package confirmed to be compliant, fit for disclosure, and ready for ongoing E&S management.

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