The sponsor has presented plans to address these impacts to ensure that the proposed project will upon implementation of the specific agreed measures, comply with the host country laws and regulations and the World Bank/IFC environment and social policies and the environmental, health and safety guidelines. The information about how these potential impacts will be addressed by the sponsor is summarized in the paragraphs that follow.
Corporate environmental, social, and health and safety management systems: While the sponsor is sensitive to environmental, social development and occupational health and safety aspects of its operations, management of these aspects is not based on an overall management system. The company recognizes the need for such a system and will, within a timeframe to be agreed with IFC, develop and implement an environment, social and occupational health and safety (ESHS) management system applicable across the Companies.
National and local government permitting requirements: The company is required to obtain a “Consent to Establish” form from the local Pollution Control Board (PCB) in each of states where a new project is proposed. The sponsor has Consent for the Birsinghpur site and has applied for such Consent for its Sechi site. The company’s management team has confirmed that it will be applying for the consent for the remaining two sites in HP after signing the revised Implementation Agreements. Further, though the Birsinghpur site has Consent to Establish, it does not have an authorization under the Hazardous Waste (Management and Handling) Rules 1989, as amended. The sponsor will verify the need for such an authorization with the PCB, given the nature of its operations; if required, the authorization will be obtained in a timely manner.
Dam safety: OP 4.37 applies only to the Bhandardara dam, which is the source of flow for both Bhandardara I and II (BH-I and BH-II) and was originally constructed for irrigation purposes. Completed in 1926, the dam wall is approximately 75 meters high and the structure includes two spillways. The Government of Maharashtra owns and controls the dam; the two hydroelectric plants were added in the last 20 years (BH-I has been operating since 1986 and BH-II since 1999). The sponsor took over the BH-I plant from the GOM in 2001, and won the bid for BH II in 2004, the assets of which it anticipates receiving by September 2005. Although it has been operating without a major incident for some 70 years, in 1969 a crack was detected in the dam wall, two years after a major earthquake in the region, and an extensive program of investigations, repairs and monitoring activities undertaken to remediate the situation. In accordance with OP 4.37, the lenders have engaged an independent engineer to review the safety of the dam. Submission of a dam safety report acceptable to IFC, including any recommended mitigation and monitoring measures, will be made a condition of first disbursement.
Potential impacts on downstream users: The project involves setting up of three run-of -river plants in HP. For each, diversion of water will be from the weir to the powerhouse, involving a distance of approximately 1-2 km. Under the terms of its concession agreements, the company is required to maintain at least 10% of normal flow through the weir at all times. At Panwi and Melan, there are few houses within the stream section where water will be diverted, and no material impact on users is therefore anticipated. At the Sechi site, however, there is a village (Samej) with about 200 people living in the vicinity of the weir, and part of the village lies in the section where diversion of water is planned. The stream water may minimally be used for small scale agriculture, washing and cleaning. Drinking water is provided through a Public Health Department pipe from a mountain spring. The sponsor has already estimated the peak water requirement of the villagers in the area where water will be diverted and is confident that the minimum 10% statutory flow requirement will be adequate to meet the needs of all local users. At Birsinghpur, the plant uses thermal power plant outtake and downstream users are not affected. At BH-I and BH-II, the flow levels are controlled by the GOM irrigation authorities who release water at Bhandardara dam in accordance with agricultural demands downstream. Neither of these facilities currently operates at optimal efficiency owing to the pattern of irrigation releases followed by GOM.
Land acquisition, compensation and physical and/or economic resettlement: The proposed power houses and associated facilities in HP are planned predominantly on forest land leased from the Government. However, some private land also will be acquired for these facilities. None of these acquisitions will result in physical resettlement as defined under OD 4.30. If future acquisition results in any loss of livelihood opportunities, the sponsor has agreed to provide acceptable compensation and rehabilitation, consistent with WBG guidelines, to the affected individuals.
Community consultation and disclosure: The sponsor has already held a number of formal and informal consultations with members of communities in the vicinity of the greenfield sites in HP, in particular with villagers of Samej. The company will continue to update the community on its work at Sechi, particularly prior to commencement of construction work, in accordance with WBG guidelines. The sponsor will make records of such consultation available to IFC, including details of how it has addressed any concerns raised in the consultation process.
Site access during construction and operation: Access to the Sechi construction site is by a State road. Access to Panwi site is through a bridge from the national highway. Another bridge, nearing completion, will provide access to Melan site. At the time of IFC’s site visit, these sites could only be accessed via a ropeway across the Sutlej river. The sponsor will sequence activities at these sites in phases to ensure that appropriate and safe access for movement of labor and materials is maintained at all times. The sponsor will construct and maintain appropriate pathways to enable access to the powerhouse and associated facilities. Where there is a loss of public access as a result of construction or operation activities, the sponsor will provide crossovers for use by local communities.
Community environment, health and safety during both construction and operation: The sponsor will ensure that there is minimal impact on community environment, health and safety, during both the construction and operation phases. Specifically, the sponsor will ensure that its employees and construction contractors ensure the following:
- Provision of appropriate barriers and lighting at excavation sites, especially where such sites are close to community habitations, community buildings and/or gathering places.
- Use of controlled blasting where community habitation/individual dwellings are within a 1-km radius of the blasting site. The sponsor has indicated that it intends to minimize or eliminate the need for blasting wherever possible. In the unlikely event that blasting at night is required, the company will obtain an express consent from the local community.
- Ensuring the stability of all structures and slopes in the vicinity of construction sites that may be impacted by blasting, excavations or movement of heavy equipment.
- Storage of excavated earth, rubble and other construction waste in a manner that does not impact dwellings, community buildings and/or gathering places.
- Training of all earth moving equipment operators and truck/tipper drivers in safe and defensive driving and development of a materials movement plan to ensure that vehicular movement during construction has minimal impact on life patterns of nearby communities.
- Requiring that all trenches, canals and pits in the vicinity of community structures, individual dwellings, schools and traditional access pathways be covered.
- Consideration of potential noise impacts as a criterion for selection of electro-mechanical equipment for the proposed plants and in design of the powerhouse. Once the plants are operational, the company will undertake benchmark testing of ambient noise levels to demonstrate compliance with WBG and PCB requirements. During construction, the sponsor will require contractors to undertake monitoring of noise levels in relevant areas (e.g., in proximity to diesel generator (DG) sets, compressor, breakers and other such equipment) to demonstrate compliance with WBG and relevant PCB guidelines. Where required, the sponsor will require contractors to comply with these requirements.
- During construction, requiring contractors undertaking construction work to (a) ensure that DG set emissions comply with GOI limits; and (b) undertake appropriate measures to minimize fugitive emissions from blasting and storage and/or transport of excavated earth/other construction material.
- Depending on the duration of the construction phase at each of the greenfield sites, requiring contractors to undertake dust control measures such as sprinkling of water on access roads and excavated earth, to ensure that ambient air quality complies with WBG guidelines.
Provision of housing, hygiene facilities, water, and power (including fuel storage) during construction and operation: The sponsor will ensure that appropriate facilities for laborers and materials are provided during both the construction and operation phases. In this regard the sponsor will provide, or require its contractors to ensure, the following:
- At construction sites and labor camps, provide all basic facilities including accommodation, toilets, washing and cleaning water, potable drinking water, and cooking fuel, so laborers do not impact vegetation in the region for fuel wood.
- Ensure that potable water is available for drinking purposes and spring water for washing and cleaning purposes in the operations phase.
- Although no process effluents are likely to be generated in the operations phase of the plants, sanitary waste water will be treated to meet WBG requirements prior to discharge. During construction, the sponsor will ensure that sanitary waste water is treated and disposed through septic tanks and require contractors to comply with WBG and PCB guidelines in cases where construction waste water is discharged to surface water bodies.
- During both construction and operation, require that all employees and contract labor be provided environmental and occupational health and safety training and appropriate PPE before they commence working and actively enforce the use of PPE at all sites.
- In all plants, ensure that all moving parts are equipped with guards, pits have hand rails, and ladders are provided for climbing into/out of pits, and appropriate pathways are designated to ensure safe access and egress.
Hazardous materials management: The sponsor will ensure that explosives to be used for blasting are kept in an appropriately constructed and secured magazine, duly approved by regulatory agencies. At construction sites, the sponsor will require contractors to develop and deploy appropriate procedures and construct facilities for storage, handling of oils/lubricants/fuel oil and for management of spills. At operational plants, the company will construct appropriately contained facilities for storage of hazardous materials. In addition, the company will make PPE available to workers handling hazardous materials, enforce the use of PPE provided, provide training to employees handling hazardous materials, and provide washing stations in material handling areas. The company will ensure that necessary antidotes for accidental exposure are available and readily accessible. At construction sites, the sponsor will require contractors to undertake the above measures.
Fire and life safety and emergency response: The sponsor will install necessary facilities and equipment for prevention, detection and control of fire, electrocution and spills in accordance with acceptable engineering practices. The company will develop and display emergency response procedures at prominent locations in its plants, train employees on these procedures, and periodically conduct drills.
Minimization, recycling and disposal of solid and hazardous wastes during construction and operation: The sponsor will ensure that all solid wastes, excavated earth and rubble generated in the construction and operation phases are appropriately segregated and disposed of at sites identified by the local authority. The company will, however, ensure maximum reuse of excavated earth and rubble wherever possible. During construction, the sponsor will ensure that contractors construct appropriately contained facilities for storage of hazardous wastes (including waste oils, oil/grease soaked rags, empty oil/paint drums) and implement appropriate procedures for their disposal in accordance with GOI regulations. At all facilities the sponsor will construct appropriately contained storage facilities for storage of hazardous waste and comply with GOI regulations as regards their disposal.
Biodiversity conservation: Although very little vegetation will be disturbed as a result of construction or operation of any of the plants, the sponsor will plan alignments to minimize the need for felling trees. At greenfield sites, which may require some clearing to enable movement and storage of equipment and materials, the sponsor will develop a plan for post-construction rehabilitation of any areas affected by construction work. The sponsor will ensure that earth/rubble dumps at construction sites are protected against erosion during the monsoon rains.
Corporate social responsibility efforts, including HIV/AIDS awareness: The sponsor has been undertaking Corporate Social Responsibility work at each of its facilities and will in consultation with communities in the vicinity of their sites, continue their CSR initiatives. IFC will provide details of its IFC Against AIDS program to the sponsor for distribution to its employees, contractors and among nearby communities, in a culturally appropriate manner.
Timely reporting on environmental and social performance to IFC: The sponsor will submit Annual Environmental and Social Monitoring Reports (AMRs) timely within 90 days of the end of its financial year.
