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 environmental and social requirements and 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/project is summarized in the paragraphs that follow.
Site selection process used for existing and proposed new wind farms: At the location identification stage, Enercon relies primarily on wind data published by the Ministry of Non-Conventional Energy Sources (MNES). As the hub height of turbines differs from the height at which the wind data is collected, the company extrapolates MNES data to the height of the wind turbine to assess the expected generation at the site. Recently, in addition to MNES data, Enercon has also started assessing wind potential at some locations by establishing its own wind masts. Once the generation level is established, the company obtains details of the land ownership. In states like Karnataka, Rajasthan and Gujarat the land in question is largely government owned, either a declared forest land or revenue land. In case of declared forest land, companies are required to obtain an equivalent area of revenue land and transfer this to the forest department, and to pay a predetermined cost to the Government for afforestation efforts to compensate for development of roads and other infrastructure that reduce the forest cover. Companies must also pay the Forest Department to grow dwarf species in the wind farm area. In a few states such as Tamil Nadu where preferred sites are on private lands, the commercial value of the land is paid to the land owner. Private land acquisition does not involve any physical or economic displacement, as acquisition is always done on a “willing buyer-willing seller” basis. In all cases, access roads built by Enercon are for public use as well.
Environmental, social, and health and safety management systems: EIL has undertaken a number of initiatives in the areas of environmental and occupational health and safety (EHS) management. It has detailed systems in place for EHS management and monitoring, certified under ISO 9000:2000, and a strong implementation team, headed by the General Manager for Total Quality Management (TQM), who is a registered Lead Auditor for ISO 9001and 14001 certification audits, and a registered Principal Auditor for ISO 9000:2000. The Company recognizes the need to ensure that its systems are fully and effectively implemented both at its manufacturing and installation sites, and is in the process of hiring a corporate level environmental officer, who will be responsible for monitoring performance at all EIL plants and wind farms and reporting on this regularly to senior management.
National and local permitting requirements: EIL has obtained relevant consents and authorizations under more than 20 host country EHS statutes and regulations. Although the Company generates minimal hazardous wastes, it does produce used grease canisters, oil-contaminated cleaning rags, paint drums, and other items regulated under the 1989 Hazardous Waste Rules. EIL will therefore apply for an authorization for handling these wastes and notify IFC once this authorization has been obtained.
Source and volumes of water required including efforts to minimize water use: Both of the wind farms are located in extremely arid regions, where water supplies are scarce. As a result, EIL has instituted strict water conservation policies and programs. Consumption of water at each of the two sites is approximately 12,000 liters for 5-8 days, plus 200 liters per day of drinking water. Water at the Daman and Gujarat manufacturing facilities, as well as the Company’s training academy (located approximately 10 kms from the Daman plant) is obtained from borewells and purified by reverse osmosis units installed at each of these facilities. Consumption at these facilities is approximately 175,000 liters per month at Daman, The water is processed through a internal reverse osmosis (RO) plant; consumption is approximately 325,000 liters per month at the tower construction plant in Gujarat, and 250 liters per month at the training academy.
Source of power and energy, including fuel storage if applicable: The minimal power requirement for operations at both the Jaisalmer and Chitradurga wind farms is drawn from the wind-produced power being fed to the grid. Neither of these installations is equipped with a stand-by diesel generator (DG) set; therefore no fuel storage is required. Power for manufacturing plants in Daman and Gujarat is sourced from municipal sources. Both plants are equipped with standby diesel generator sets, however, for use in the event of an interruption in the supply of grid power. Fuel supplies for DG sets are stored in 10,000-liter underground tanks, which are monitored and calibrated on an ongoing basis to ensure against supply leaks, and are visually inspected annually. As part of its ISO 9001/14001 continuous improvement efforts, Enercon has an ongoing program to monitor and minimize energy consumption at its manufacturing facilities that has resulted in approximately 24% reduction in energy use at the Daman plant between the Financial Years 2003-04 and 2004-05. These efforts are ongoing at all of its facilities.
Air emissions and compliance with local and World Bank Group emissions limits: Emissions at the wind farms are negligible given that the only source of energy is wind-produced power and that neither of these installations is equipped with stand-by generators. At the manufacturing plants in Daman and Gujarat, power is normally obtained from the grid with reliance on DG sets only in the event of grid power outages. Because of the reliability of the Daman grid, EIL management has confirmed that generators are only in use approximately 40 hours per month and, as a result, total emissions are insignificant. In the concrete tower manufacturing facility at Gujarat, EIL has 3 gensets - one 125 kVa, and two 500 kVa. The 125 kVa is being operated for approximately 430 hrs in a month and one 500 kVa genset is operated for 310 hrs a month. The gensets are used as an alternative to the grid power and the additional emissions are not significant.
Ambient air quality and noise impacts on nearby receptors: As noted above, the wind farms generate no significant point source or fugitive air emissions, nor have any appreciable impact on ambient air quality. Noise impacts at the wind farms from turbines and generators have not been measured although, given their remote locations, impacts on nearby receptors are expected to be minimal. Nonetheless, to demonstrate conformance with WBG and host country norms, EIL will undertake noise testing at its facilities and provide the results of these tests to IFC.
Recycling and treatment of process effluent and waste water: No process effluents are generated at the wind farms. Sanitary wastewater is treated and disposed through septic tanks. At the manufacturing plants in Daman, no process effluents are generated and domestic waste - water is disposed through septic tanks here as well. In Gujarat, At the tower manufacturing facility in Gujarat, Enercon also uses RO water for both processing and domestic purposes. Sanitary waste water is disposed through septic tanks.
Hazardous materials management: Overall materials management and inventory control at EIL facilities is excellent. All of the technologies manufactured and used by EIL are based on its German designs, which – because of increasingly strict national and EU requirements – minimize use of hazardous inputs. Blade manufacturing utilizes several specially formulated resins, all of which are imported from the EU, primarily Germany, and none of which have hazardous constituents. At both the Daman and Gujarat plants, few hazardous materials are used in the manufacturing and assembly processes input, with the exception of small amounts of cleaning solvents used at Gujarat. These are used in small quantities and are properly disposed in accordance with relevant regulatory requirements.
Occupational health and safety programs and performance: In accordance with its TQM approach, EIL has established detailed training programs and curricula for all staff. Staff in the manufacturing plants must undergo a minimum of three months training, including health and safety training. Staff are provided with all requisite personal protective equipment (PPE) and use is strictly enforced. Medical examinations are given annually for all staff members. EIL provides medical insurance coverage for all staff and their immediate family members. The Company maintains records of all incidents and accidents and calculates monthly lost time injury (LTI) rates for each unit. Programs for assessing the causes of LTIs and for lowering LTI rates are an ongoing part of EIL’s EHS management systems. Professional training is also given high priority within EIL. The Company has established a Training Academy in Daman to train both manufacturing staff and the maintenance teams that regularly inspect and maintain the turbines in accordance with a strict schedule and terms of reference. Because teams must undergo a rigorous 6-month training course before they are able to carry out the inspection regime, this is a resource-intensive and important part of EIL’s delivery program. The Training Academy has a full-time faculty, detailed training curricula, and a system of compulsory examinations that must be passed before teams are allowed to carry out inspection and maintenance protocols.
Fire and life safety and emergency response: EIL has a program in place for training teams in firefighting and emergency ‘first responder’ skills at both its manufacturing plants and wind farms. At the Daman and Gujarat plants, fire response equipment is in place in all of the manufacturing areas and is regularly inspected and maintained. In addition, the Company conducts regular fire and emergency response drills, in coordination with local fire brigades. In its 11 years of operation, EIL has never had a major fire or emergency at any of its facilities or wind farms.
Minimization, recycling and disposal of solid and hazardous wastes: None of the resins or fibers used in blade manufacture is hazardous and, given their cost, EIL has strict waste minimization and recycling programs in place. Housekeeping in general is quite good but, in the blade manufacturing unit requires some improvement as far as the frequency with which wastes (e.g., blade offcuts and resin scrap) are swept and removed from the premises. This is the result of the fact that, as the size of turbine blades has increased over time (from the smaller E-33 and E-40 designs, to the E-48 design that is currently used for new installations), crowding in the blade construction unit at Daman has increased. While EIL has taken steps to rationalize the work flow, passageways between major units and equipment are, in some cases, quite narrow. Any scrap left lying in these areas, even for short amounts of time, increases the likelihood of an accident or injury. EIL will look into additional ways to improve the situation in this part of its operations and will report to IFC quarterly on these efforts.
Biodiversity conservation: Both the Rajasthan and Karnataka wind farms are located in remote, arid locations with little indigenous vegetation or wildlife. Although not required to do so under Indian national laws, EIL commissioned an independent Environmental Impact Assessment (EIA) for the Jaisalmer wind farm. Mitigation measures recommended in the EIA have largely been implemented. During the site visit, however, it was observed that housekeeping and litter control at the Jaisalmer wind farm requires significant improvement, as litter from both construction, operations and maintenance activities is strewn around the project site. This concern has been conveyed to the EIL site manager for Jaisalmer, who is in the process of establishing an improved housekeeping regime for the site. A similar clean-up program will be established at the Chitradurga wind farm.
Involuntary resettlement and potential economic displacement: As noted in the discussion of site selection, EIL has never had a situation involving involuntary resettlement or economic displacement as a result of its wind farm siting process. IFC has provided EIL with a copy of its Involuntary Resettlement guidelines and the Company has agreed to abide by its provisions in the event that such a situation arises in future.
Corporate social responsibility efforts, including HIV/AIDS awareness: EIL has built new access roads and rebuilt local schools, clinics and temples in the vicinity of its wind farms and manufacturing plants. The Company played a catalytic role in the development of the Daman light industrial area in the mid-1990s, an area that now provides employment to hundreds of local villagers. At both the Rajasthan and Karnataka wind farms, EIL has generated employment for local villagers, to provide security and other support services to these installations. IFC has provided details of its IFC Against AIDS program to the Company.
Timely reporting on environmental and social performance to IFC: EIL will submit Annual Environmental and Social Monitoring Reports (AMRs) within 90 days of the end of its financial year.
