The Company 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 including: the host country laws and regulations; IFC’s Performance Standards; and the World Bank Group (WBG)/IFC 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. Further information is provided in the attached documentation.
PS 1: Social and Environmental Assessment and Management System
The projects to be undertaken by Azure Power are socially and environmentally desirable and being renewable energy projects, will contribute to GHG abatement. Azure Power’s management is committed to adopting and implementing state of practice social, environmental, occupational health and safety management system (SEHSMS) for its projects and operations. The Company has articulated a Health, Safety and Environment Management System (HSEMS) for the operations phase. The HSEMS has as yet not been implemented but the Company will implement it within 3 months of commissioning of the first generation unit (1MW) at Awan village in Punjab state of India. The HSEMS has a focus on safety aspects and includes procedures for: risk identification; compliance with regulatory requirements; development and implementation of management programs; incident and accident handling, recording, reporting, investigation and analysis; emergency preparedness and response; responsibility allocation; training and awareness; communication and consultation; monitoring, recording, reporting and documentation; audit; corrective action; and management review.
Azure Power’s present approach to managing social and environmental performance addresses some of IFC Performance Standard provisions but does not cover all the various relevant and applicable aspects contemplated in the IFC Performance Standards. As part of the Action Plan agreed with IFC, Azure Power will implement measures, discussed here, so as to ensure that its projects and operations result in outcomes consistent with IFC Performance Standards.
The Company will ensure adherence to IFC Performance Standards as applicable to its project and operations by putting in place a company-wide (applicable to it and its subsidiaries) management system that integrates social, environment, occupational health and safety (SEHSMS) performance .The SEHSMS will: (a) encompasses all project phases from project conceptualization/planning, design, construction, operation through to decommissioning; (b) incorporate IFC’s Performance Standards; and (c) will ensure that Azure Power’s project outcomes are consistent with IFC Performance Standards.
The Company will, as part of the SEHSMS, put in place procedures for: identifying social and environmental risks and impacts of its projects; undertaking appropriate social and environmental assessment (SEA) all of the projects it (and/or its subsidiaries) implements; development and implementation of social and environmental management plan (SEMP); and development and implementation of a community engagement plan (CEP), which is consistent with IFC Performance Standards. The Company will, prior to commencement of construction work on the Project, complete a SEA and develop a SEMP including a community engagement plan, which is consistent with IFC Performance Standards. Further, the Company will, as part of an action plan agreed with IFC, provide to IFC an audit report: on conformance of the existing/under construction solar power plant with IFC Performance Standards provisions; and delineating, based on the audit findings, measures to be implemented to meet IFC Performance Standard provisions.
The Company will, to enable effective implementation of the SEHSMS, put in place a social and environmental organization and make available adequate resources including staffing of the organization with appropriately qualified social and environmental professionals. Under the corporate wide applicable SEHSMS, Azure Power will implement procedures for: (a) engagement with affected communities in accordance with IFC Performance Standard provisions; (b) ensuring that contractors meet relevant provisions of the Company’s SEHSMS; (c) SEHS training of employees and contract labor; (d) recording, investigation and reporting of SEHS incidents including those involving contractors’ labor; (e) periodic monitoring of SEHS performance; and (f) periodic reporting of SEHS performance to the Company’s Board of Directors, regulators and investors.
Site specific pollution prevention and mitigation measures associated with each project will be identified and addressed through the SEA and SEMP process. The Company will, as part of its SEHSMS, develop procedures to ensure that the environmental impacts associated with its (including subsidiary companies) projects and operations, are managed in accordance with IFC’s Performance Standard 3 (PS 3) provisions. While the scale of impacts at each location will depend on the scale of the project proposed at each site, material impact on ambient air quality and noise levels may not be expected at the Company’s project sites. However, temporary impact on ambient air quality and noise levels may be expected during construction. Water usage may be material for construction water and also during operation for panel washing, particularly in large scale projects (in addition to domestic consumption during construction and operation). The Company will address any adverse impacts on ambient conditions and water resources through site specific SEMP.
Hazardous materials (lubricants, transformer oils, dielectric containing material, paints, batteries etc), hazardous wastes (used oils, waste/residual paint, oil/paint soaked rags/material, filters, empty oil/paint/chemical drum/barrels etc) and other wastes (packing material, metal, debris, cement bags, drums/carbuoys etc.), may be handled/stored or generated in material quantities during construction in particular and also to a limited extent during operation. Wastewater generated will primarily be panel washing water during operation phase, and domestic sewage during construction and operation phases. The Company must ensure that: transformers do not use PCB containing oils; ozone depleting substances banned/phased out under ozone depleting substances rules are not used; and use of pesticides, if any, should be in conformance with Performance Standard provisions. The Company will, through procedures in the SEHSMS and through implementation of the site specific SEMP address these aspects and mitigate the impacts.
The Company uses equipment and infrastructure that meet good industry practices. The Company will, as part of the SEHSMS, implement procedures to ensure that community health, safety and security impacts are identified and mitigated in accordance with IFC’s Performance Standard 4 provisions. The Company will, as part of its SEHSMS, put in place procedures to minimize the risk of exacerbation of community exposure to disease due to influx of labor or due to changes in land/hydrologic or other terrestrial/air quality/hydrologic regimes. The Company will provide or ensure that its contractors provide medical facilities and implement a periodic health check up program for its employees and the construction workers. Further, the Company will ensure that: in the labor camp appropriate facilities and amenities are provided including housing, toilets, washing and cleaning water, potable drinking water and cooking fuel; treated sanitary waste water meets IFC/WBG requirements prior to discharge; and potential host community impacts on account of influx of labor are assessed and managed.
The Company will, as part of the SEHSMS and based on the SEA outcome, put in place appropriate measures including: material movement planning; barricading of excavated areas; safety signage; illumination; and other measures to mitigate the risk of accidents for general public during construction. In transmission line route planning, the Company will take into account risks and impacts including: electrocution; electromagnetic interference; aircraft navigation safety; and visual amenity, as applicable. Further, for communities’ resident in the vicinity of the transmission line, the Company will implement a general awareness program detailing dos and don’ts to minimize electrocution risk. The Company will need to prepare and implement an onsite and offsite Disaster and Emergency Management Plan.
Further, the Company will put in place procedures under the SEHSMS to ensure that its contractors adopt good EHS construction practices consistent with Azure Power’s SEHSMS, in particular ensure that: its employees and the contractors use appropriate personal protective equipment and adopt safe work practices; vehicle/material movement during construction has minimal impact on daily life patterns of nearby communities; appropriate measures to reduce fugitive emissions are implemented; night time activities are restricted to low noise generating work; and ambient air quality as also noise levels are periodically monitored in potentially affected communities/villages, and implement mitigation measures where required.
The Company employs security personnel and will implement procedures for ensuring that: past records of security personnel employed are screened; security personnel have clear objectives and permissible actions laid out; security personnel are trained in avoidance of human rights violations; security incidents are recorded, investigated and corrective action implemented; bona fide complaints against security personnel are investigated and appropriate disciplinary actions are implemented; and there is a grievance mechanism for aggrieved members of community or employees, in the event of a violation of the code for security personnel.
The Company will, as part of the SEHSMS, develop and implement procedures such that land acquisition resulting in involuntary resettlement, in all projects undertaken by the Company and/or its subsidiary companies, is in accordance with IFC’s Performance Standard 5 provisions. The right of way for transmission line is usually acquired by the state transmission utility under eminent domain. The Company will put in place procedures to ensure that impacts due to involuntary right of way acquisition, restrictions in land use for associated facilities like Transmission Lines, access roads or pipelines, are mitigated in accordance with PS5 provisions. Further, the Company will, as part of the SEHSMS also lay down procedures for paying compensation to affected farmers, in the event of crop loss during construction or operation phases. The Company will, prior to commencement of construction work on the Project, identify and mitigate involuntary resettlement related impacts in accordance with IFC Performance Standard 5 provisions.
The Company has obtained 13 acres of panchayat (elected local self government institution constituted of representatives elected from the village) land (community land) on long term lease for the project currently under implementation. The Company has obtained permission through a resolution from the village panchayat. The lease was subsequently approved by the district authorities and the state government. The transmission line for evacuating power from the plant is 2.9 km long, includes 9 m high poles and the minimum ROW acquired is 6.5 m. Loss of land to each pole would be a fraction of a square meter and the restriction on landuse due to ROW acquisition is limited (as farmers are permitted to continue cultivation within ROW after commissioning of the T-Line). The Company will: assess impact in accordance with Performance Standard 5 provisions including on account of the transmission line and compensation due to affected households; and in consultation with the affected households, implement a mitigation plan, which is consistent with Performance Standard 5 provisions.
In cases, where the project is likely to materially transform, degrade or impact lands and resources on which indigenous peoples (“IP” - scheduled tribes, as per Indian laws) are dependant, the Company will, as part of the SEHSMS, implement procedures to identify and mitigate all identified impacts on IPs. The Company will ensure that the S&EA is undertaken in accordance with the provisions of IFC’s Performance Standard 5 & 7 and mitigation plans achieve outcomes consistent with IFC Performance Standard 7 provisions.
Azure Power will, under the SEHSMS and in accordance with IFC’s PS6 provisions, develop and implement procedures, to minimize and mitigate impacts on bio-diversity, particularly when its project sites are located in, pass through or are in the vicinity of: (a) critical natural habitat; (b) protected areas including wildlife sanctuary, national parks, reserved forests, breeding grounds of key species and archaeological monuments; and (c) other eco-sensitive areas like marine environment, rivers, streams and wetlands with aquatic or other flora-fauna. Further, Azure Power will, under the SEHSMS and in accordance with PS 8 provisions, develop and implement a chance find procedure including for finds of archaeological (prehistoric), paleontological, historical, cultural, artistic, and religious values, as well as unique natural environmental features that embody cultural values, such as sacred groves.
PS 2: Labor and Working Conditions
The number of employees and contract workers to be engaged on site during construction and operation is a function of the scale of the project. The Company will, within a timeframe agreed with IFC, put in place structured and documented HR policies and procedures, which are consistent with IFC Performance Standard 2 provisions. Further, the Company will, as part of the HR policies and procedures also include procedures for ensuring: (a) contractor compliance with applicable labor laws; and (b) that basic amenities and facilities to be made available to workers, as mandated by applicable labor laws, are provided for in project design and implementation.
The Company has articulated a Health, Safety and Environment Management System (HSEMS) for the operations phase. The HSEMS has as yet not been implemented but the Company will implement it within 3 months of commissioning of the first generation unit (1MW) at Awan village in Punjab state of India. The Company needs to expand the scope of its existing HSEMS to the construction phase and ensure that: workers are provided and use personal protective equipment (PPE); safe work practices are adopted; safety training program are in place particularly for workers involved in dangerous activities; an EHS induction training for all new labor (including contract labor) entering a project site; potable quality drinking water is made available; sufficient number of toilets/urinals are provided at site; rest shelters and other basic amenities are made available; accident and incidents are investigated and corrective actions implemented; and labor camps have appropriate facilities and amenities.
