The projects being implemented by Husk Power are socially and environmentally desirable and being renewable energy projects will contribute to GHG avoidance besides the several attendant benefits of making electricity available to households that have until now been without electricity. Husk Power sponsors are committed to achieving high social and environmental outcomes from their projects. Accordingly, the Company will implement 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; and IFC’s Performance Standards. 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
Husk Power, to meet regulatory requirements and complete permit applications, undertakes a very limited examination of the social and environmental impacts of its projects and operations. Husk Power’s present approach to managing social and environmental performance 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, Husk Power will implement measures, discussed here, so as to ensure that its projects and operations result in outcomes consistent with IFC Performance Standards.
In keeping with the limited nature and scale of potential risks and impacts from its projects and operations, Social and Environmental Impact Assessment (SEIA) of each project is not expected to be undertaken by Husk Power. However, the Company will undertake a third party social and environmental audit of a sample of its existing/operating facilities and will implement the mitigation measures/action plan developed based on the findings of this third party audit. Further, the Company will put in place an appropriate social and environmental management system (SEMS), consistent with IFC Performance Standards and incorporating Good International Industry Practice (GIIP). Husk Power will, under the SEMS: develop a legal register and compliance matrix to ensure full compliance with all applicable social and environmental laws, rules and regulations across all of its operations at all times; and obtain all applicable permits, consents and authorizations. Further, the Company will, as part of the SEMS, put in place standardized social and environmental criteria and procedures for: screening, mitigation and monitoring; incident and accident handling, recording, reporting, investigation and analysis; emergency preparedness and response; responsibility allocation; training and awareness; communication and consultation; audit; corrective action; management review; and reporting social and environmental performance to the Company’s Board of Directors, regulators and investors. In addition, Husk Power will, to enable effective implementation of the SEMS: detail roles and responsibilities including of key contractors and suppliers for implementation of the various elements of the SEMS; provide technical guidance, including standard screening forms, mitigation measures and monitoring procedures for ensuring social and environmental outcomes are consistent with the SEMS objectives; and develop and implement a training program on SEMS for all employees and contract workers.
Typically at each project site: the principal air emission is from the gas turbine (35 – 100 kW installed capacity); water consumption for process is about 1 KL/day; and water consumption for domestic use is 1 KL/day.. Process water and domestic water used at each project site is ground water. Process waste water (bottom ash/rice husk char) and tar tank water (from venturi/gas cleaning cum cooling water) is collected in a settling tank and recycled. Rice husk char (RHC), tar and used filter media (husk/saw dust and charcoal) are all mixed and stored on the ground. The Company will put in place facilities to store these process wastes within a contained area. Husk Power will undertake a full characterization of the process waste mix (RHC) as also the process wastewater (both char tank and tar tank waste waters separately). Husk Power will, based on the outcome of characterization of the wastes and waste water, put in place appropriate measures, if any required, mitigating adverse impacts from their handling, storage and disposal. Further, the Company will make provisions to ensure that process wastewaters (i.e. char tank and tar tank water) do not mix or overflow from the tanks.
Hazardous materials (lubricants and batteries etc), hazardous wastes (used batteries, used oils, tar, oil soaked rags/material, filters, empty oil drum/barrels, any other waste characterized as hazardous) and other wastes (packing material, metal, debris, drums/carbuoys etc.), are handled/stored or generated in limited quantities at each one of Husk Power’s project sites. The Company has in the past been disposing used batteries to local buyers and used lubricating oils to persons from local communities for timber treatment. The Company will, as part of the SEMS, put in place procedures to: (a) obtain authorization under hazardous waste rules; (b) aggregate all hazardous wastes from the various points of generation; (c) store them under segregation and containment; (d) handle them with appropriate care and personal protective equipment; and (e) disposed them off only through entities authorized to handle and dispose hazardous wastes. 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 water resources may not be expected on account of Husk Power’s projects. However, the Company’s project sites are often located in the vicinity of residences/communities. Hence, HPS will in accordance with GIIP and IFC Performance Standard 3 provisions, undertake an assessment of noise impact on the ambient at a sample of its existing facilities; where required, implement measures to mitigate the noise impact on any sensitive receptors; and incorporate appropriate measures in the screening procedure to ensure that project siting in future projects addresses potential noise impact on resident communities.
While Husk Power’s electricity generation and distribution system does not adhere to any specific conventional electricity system codes or standards, it is adequate for the application. Though the downward draft gasifier system operates in a net negative pressure environment, the Company will implement engineering, management and siting related measures to mitigate the risk of accidents/incidents that may affect the general public. Further, for communities’ resident in the vicinity of the plant and the distribution lines, the Company will implement a general awareness program detailing dos and don’ts. Husk Power will prepare and implement an onsite and offsite Disaster and Emergency Management Plan. The Company will, as part of the SEMS, implement procedures to ensure that community health, safety and security risks and impacts are identified and mitigated in accordance with IFC’s Performance Standard 4 provisions.
Typically, Husk Power’s plants and facilities are located on land leased on a willing lessee/lessor basis and involuntary resettlement is not expected on account of its projects and operations. Even though the distribution line’s footprint/impact is very small, the Company ensures that the distribution power lines are laid along existing village roads/lanes and on private land. In the event of any concern expressed by landowners or other members of the community pertaining to siting of the bamboo distribution grid poles or adverse impact on account of the distribution line alignment, these lines can be easily shifted to address the concerns. The Company will however, as part of the SEMS, put in place formal procedures to consult with affected communities and households before finalizing the project location/siting and the distribution line alignment. Husk Power will put in place procedures to identify involuntary resettlement impacts, if any, on account of its project and mitigate such impacts in accordance with IFC Performance Standard 5 provisions. Further, the Company will through the application of the screening procedure in the SEMS ensure that projects and facilities are sited/located in a manner to avoid: material transformation, degradation or impact lands and resources on which indigenous peoples (“IP” - scheduled tribes, as per Indian laws) are dependant; biodiversity rich areas including critical natural habitat, protected areas, reserve forests, breeding grounds of key species, rivers, streams and wetlands environment with aquatic or other flora-fauna, archaeological monuments and other historically, socially and culturally important sites, structures and features as well as unique natural environmental features that embody cultural values, such as sacred groves.
PS 2: Labor and Working Conditions
Husk Power has about 100 employees on its rolls. Typically for civil works and installation work at each project site, the Company engages masons and workers from the village where the facility is being set up. At each operating unit, there are 3 persons employed i.e. the operator, the lineman/electrician cum bill collector; and the husk loader. While the operator and lineman/electrician cum bill collector are on the rolls of the Company, the husk loader is a daily wage worker. Further, the operator lives on the plant premises but the lineman/electrician cum bill collector is often from the same village. The Company will upgrade the employee/worker living quarters provided at the plant premises to meet appropriate standards including ensuring access to potable water and sanitary facilities. Husk Power presently does not have documented human resource (HR) policies and procedures including formal procedures to ensure compliance with applicable labor laws. The Company will, review all applicable labor laws and IFC Performance Standard 2 provisions, and put in place structured and documented HR policies and procedures which comply with all applicable labor laws and are consistent with IFC Performance Standard 2. Labor working conditions at the Company’s gasifier supplier’s premises need to be significantly improved. Currently, Husk Power does not have systems in place to ensure/assure itself that its contractors and suppliers meet Indian labor law requirement. However, the Company will, as part of the HR policies and procedures also include procedures for ensuring that its contractors and suppliers comply with applicable labor laws.
Husk Power will as part of the SEMS put in place operation control procedures to minimize occupational Health and Safety risks for employees/workers engaged in project construction and operation. The Company will also as part of the SEMS put in place a fire safety plan, equipment and process. In the interim, the Company will, on a priority basis implement measures including: (a) extension of the engine exhaust to outside the shed in which it is housed; (b) implementing safe husk lifting equipment, staircase and husk loading/charging facilities; (c) purging of the gasifier to engine system prior to filter changing activities; (d) enforcement of use of basic personal protective equipment (PPE) including ear muffs/plugs by operator, husk loader and others on the site; (e) suitable CO monitoring program; (f) review of electrical panel safety; (g) training of operators and site personnel on electrical safety, emergency response in case of electrocution or gas exposure; and (h) display of safety signage on the premises. The Company needs to implement measures as part of the SEMS such that contractors involved in construction and key suppliers adhere to Husk Power’s occupational health and safety norms. The Company will also, before using ground water for drinking purposes, test it against the national potable water standards.
