While all Performance Standards are applicable to this investment, IFC's environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFC's investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards.

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security

If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards.

PS 5: Land Acquisition and Involuntary Resettlement - The proposed project will be located on arid undeveloped land devoid of human settlements and with few shrubs & trees. Since the project land was bought by Sun Edison in a willing seller/willing buyer basis, PS 5 – Land Acquisition and Involuntary Resettlement is not applicable.

PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources - PS 6 is not applicable since the project is not located in sensitive modified or critical habitats and will not affect ecosystem services. The ecological survey conducted within a 10 km radius of the project site confirmed sparse vegetation cover and the absence of unique or ecologically significant flora and fauna. The closest park, the Desert National Park at Lodurva dist- Jaisalmer, is located 75 km distant from the project site.

PS 7: Indigenous Peoples - Since there are no communities in the Project area that would be considered as ‘Indigenous’ as defined by the World Bank Group, PS 7 - Indigenous People does not apply.

PS 8: Cultural Heritage - There are no known archaeological or historic sites within the project site’s boundaries, proposed right of way or the immediate vicinity of the project site; thus PS8 - Cultural Heritage does not apply.

The proposed investment is a Category B project because the potentially limited environmental and social impacts that may result from constructing and operating the solar power generation and transmission facilities can be avoided or mitigated by adhering to generally recognized good practices and design criteria.

The Company has presented information and plans that will seek to address environmental and social risks and impacts in accordance with the Indian laws and regulations, the IFC Performance Standards on Social and Environment Sustainability, the applicable elements of the World Bank Group (WBG) General EHS Guidelines, and the attached Environmental and Social Action Plan (ESAP.)

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Environmental and Social (E&S) Assessment

For purposes of assessing the impacts of the project, as established in the Company’s corporate EHS management system, Sun Edison engaged SAN Envirotech Pvt. Ltd. (SEPL), a leading Environmental consultant firm to conduct an Environmental and Social Impact Assessment (ESIA) and a community engagement process. The ESIA developed is consistent with the IFC PSs. Once the transmission line route is finalized, Sun Edison will assess and identify the associated impacts and mitigation, in accordance with the IFC PS requirements. Copy of this assessment will be submitted to IFC once completed but prior to the commencement of the installation as indicated in the ESAP.



Environment, Health, Safety (EHS), Social Management Program and Organization

Environmental and social sustainability are at the core of SunEdison’s corporate mission and vision and the Company’s management is committed to adopting and implementing a robust Environmental, Social, Health, and Safety Management System (ESHS-MS) for the project based on the Indian regulations; IFC’s Performance Standards; relevant WBG Environmental, Health and Safety (EHS) Guidelines; and SunEdison’s corporate ESHS-MS. The ESHS-MS will be designed in line with internationally recognized ESHS-MS standards (i.e. ISO 14000 and OHSAS 18000) and will include (a) procedures for identifying social and environmental risks and impacts; (b) development and implementation of environmental and social management plans (ESMP); (c) monitoring and internal audits; and (d) development and implementation of a Community Engagement Framework (CEF.)



To ensure sound EHS contractors performance, the Company has developed detailed procedures including contractual clauses about EHS compliance, use of personnel protective equipment, work permits, report of incidents/accidents, compliance with local labor laws, etc. In addition, construction contractors will be contractually required to have on-site OHS supervisors for their operations and the Company will conduct periodic EHS performance evaluations to the contractor to assess its EHS performance.

The Company has dedicated qualified personnel to handle the EHS aspects of its operations. The company has a Global ESH Lead at corporate level that will be supported by a local ESH Manager responsible for the project operations. The company will designated a qualified person to lead its community program to handle the project impacts to the communities as well as the community outreach initiatives to be implemented in the vicinity of its operations. As needed, the company will also hire environmental consultants, to conduct studies, monitoring, audits, etc.



Training, monitoring, and reporting

SunEdison will periodically conduct EHS training for all its own employees and contractors on aspects such as safety audits, job related risks, hazardous materials, fire prevention, proper use and disposal of residues and products, etc. S
unEdison will develop dedicated training programs for all new employees as well as in-house and off-site training for first responders.



The company will establish a monitoring program to assess the EHS performance of its operations including ambient noise, ambient air, water quality, number of accidents/incidents, etc.

The Company will submit annual environmental and social performance reports to regulators, lenders and investors.

Human Resources Policy and Management

Sun Edison will develop its project-level Human Resources (HR) Policy and Procedures based on the corporate existing SunEdison’s Employee Handbook, the IFC PS2 requirements, as indicated in the ESAP. The HR Policy and Procedures will specifically include provisions related to non-discrimination and equal opportunity, wages and benefits, no engagement in forced or child labor, grievance mechanism and adequate working and living conditions. These procedures will be appropriately communicated to all employees. The Company will also implement a Contractor Monitoring Procedure in accordance with relevant labor laws and IFC PS2, as indicated in the ESAP.



The Company will establish a worker’s grievance mechanism defining the channels available to submit the grievances (i.e., mail, phone, verbal report to immediate supervisor/reporting authority; etc.) The grievance mechanism, which is part of the HR policy, will be communicated to all employees. The company will maintain a database with information regarding grievances outcomes.



It is expected that the proposed project will generate about 300 jobs during construction. The majority of non skilled workers are anticipated to be locally hired from the surrounding villages. Any skilled worker not from the surrounding villages will be accommodated in existing local housing facilities nearby with necessary travel arrangements. The project will generate approx. 20 employees during the operation phase which will live in the nearby communities.



Occupational Health and Safety (H&S)

The Company will establish an H&S management system based on the SunEdison’s corporate H&S management system which includes a zero accident policy. Key safety measures will include: ear protection when workers noise exposure is 85 dB (A) or more, equipment enclosures and buffers wherever noise levels are above 90 dB (A), preventive equipment maintenance, planning daytime activity for heavy vehicles and construction machinery activity, etc. The Company will also focus on the prevention of risks related to work at height, work with live power lines and equipment, fire, exposure to chemicals, exposure to electromagnetic fields, etc. The Company will provide and make compulsory the use of personal protective equipment (PPE.)

The design of the project is based on established state-of-art and worldwide applied technologies whose performances are both predictable and well proven in operation, so that no significant variations are expected to be found between predicted and actual performance in the field.



The water requirements for the project, which are not significant, will be provided by tankers from a nearby local supplier. The construction phase will require water for human consumption and the operation phase will require water for the cleaning of the solar panels and for domestic use.



The construction phase will generate only domestic sewage. Wastewaters to be generated during operation include panel washing, and domestic wastes. For the panel cleaning, the project will use a wiping method and sprinkler system. The wastewater generated will be diverted to a collection tank to settle dust particles and reuse the clean water for the cleaning of the panels and irrigation within plant premises. This will minimize water consumption during operation phase. Minimal amounts of wastewater resulting from the clean up wastewater falling on the ground beneath the PV Modules will not need to be treated in advance since it just contains the material removed from the panels.



Sun Edison will install a storm water management system around the project site, and will put in place appropriate facilities for collection, treatment and disposal of sewage (septic tank and soak pit) both during construction and operation phases. The project will not alter the drainage patterns of the area by elevating the land or blocking or altering natural drainage channels. 

The main source of emissions (SO2, NOX and particulate matter) during the construction phase relates to the movement of equipment and vehicles. Prevention measures during this phase will include sprinkling of water on roads, periodic checks for proper vehicles and equipments maintenance. The impact on the air quality during the operation phase is very limited since the operation does not generate air emissions.



The project will make a direct contribution towards increasing the use of renewable energy thus reducing generation of CO2 and other greenhouse emissions. The project will reduce the generation of nearly 30,000 tonnes of CO2 per year. It is also anticipated that the project will be registered under the Clean Development Mechanism.



The main noise sources during construction will relate to the operation of machinery and vehicular traffic. To minimize the impact, the work will be carried out during daytime hours, preventive maintenance equipment will be conducted, construction schedules will be optimized and vehicular traffic will be routed away from the nearest settlement. Equipment generating noise during operation will be enclosed to reduce noise to levels in accordance with the IFC requirements.



The solid waste to be generated during construction includes domestic, recyclable, and construc
tion waste. Domestic and construction waste will be transported to a municipal landfill, the recyclable waste (i.e., paper, plastic, glass, scrap metal, etc.) will be properly segregated, stored in designated waste bins/containers, and sold to local recyclers. No toxic and/or hazardous materials will be used in the construction other than diesel oils for vehicles, which will be properly handled. The contractors will be contractually required to undertake effective measures for proper waste handle. Potential hazardous materials, if any, such as arsenic, cadmium and silicon to be developed during operation, will be sold to e-waste recyclers approved by the Rajasthan State Pollution Control Board (SPCB.) Used batteries will be recycled back to the original supplier. The Company will not use PCB transformers, ozone depleting substances, or banned/phased out substances.

The project will have low negative impacts to the communities. Any potential induced influx to nearby areas resulting from the construction phase will be due to the expectation of new employment opportunities. However, it is anticipated this impact will be temporal given the short duration of the construction phase which will take approximately 3 months. In addition, the contractor will provide transportation for its workers who will be living in nearby communities. Traffic volumes to transport workers, equipment and materials to the construction site are not estimated to the considerable and the Company along with the contractor will establish the optimum transportation routes, the traffic management measures, and appropriate site access provisions that will reduce impacts.



Sun Edison will develop the emergency response plan for the construction and operation phases, as indicated in the ESAP. The plan will also include the communication to and training of the communities related to response to emergencies. As part of its emergency response planning, Sun Edison will have trained emergency response personnel at all times, and it will involve the local authorities in the development of the emergency response planning.



Sun Edison will hire only unarmed private security and vigilance personnel and will not require any support of Indian public armed forces. The Company will implement security policies and procedures commensurate to the project risks and will conduct training for the private security personnel to ensure appropriate conduct with neighboring communities.

Given that community engagement is a key pillar of SunEdison’s Corporate ESHS Policy, the Company conducted a consultation process with the community of the Village of Ugras, Taluka: Phalodi, District in Jodhpur as part of the ESIA process on September 8, 2012. The community was notified in advance prior the public consultation meeting. During the public consultation, the attendees learned about the project and its potential impacts and proposed mitigation; and provided their views about the project. The community welcomed the project and asked for the Company’s commitment to generate employment possibilities as well as to providing some social benefits such as a medical facility, access to drinking water, and sanitation facilities.

Sun Edison has designed a procedure to receive, register, redress, and monitor grievances as part of its ESHS for the project. This procedure has been designed to be easily accessible, efficient, and to respond to the grievances in a culturally appropriate way. The complaints will be handled by the local Community Liaison Officer (CLO) to be appointed for the project. For the construction phase, the contractors will develop and implement grievance mechanisms to address any issues raised related to the contractors’ activities. Sun Edison will supervise the effective resolution of grievances raised during this phase.

Community relations staff will meet periodically with nearby community members and municipal authorities. As part of the project, Sun Edison will also prepare an Stakeholder Engagement Plan, as indicated in the ESAP, including (a) stakeholder identification and analysis, (b) disclosure contractor responsibilities in relation to community relations during the construction program, (c) identification of relevant information for local disclosure including results of local hiring plan, (d) communication of emergency plan procedures, and (e) community grievance management system that will be communicated and accessible to communities and should include the procedures to disseminate the availability of the grievance mechanism by the communities.

As part of SunEdison’s corporate social responsibilities, the Company will conduct various CSR events during the project such as free community health screening, or planting of replacement tree saplings.

Client’s contacts:
Name: M.R.Mohan Ram
Title: Project Manager
Village: Ugras
Gram panchayat: Khara
Tehsil: Phalodi
District: Jodhpur
State: Rajasthan
PIN CODE: 345 023
Phone: +91 95 662 80541

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
Submit a copy of the Stakeholder Engagement Plan including (a) stakeholder identification and analysis, (b) disclosure contractor responsibilities in relation to community relations during the construction program, (c) identification of relevant information for local disclosure including results of local hiring plan, (d) communication of emergency plan procedures, and (e) community grievance management system that will be communicated and accessible to communities and should include the procedures to disseminate the availability of the grievance mechanism by the communities	12/31/2012 12:00:00 AM	Completed	Completed	12/30/2012 12:00:00 AM
Submit copy of the Contractors Monitoring Procedure to be established by Sun Edison	12/30/2012 12:00:00 AM	Completed	Completed	12/28/2012 12:00:00 AM
Submit copy of the Employee Handbook,based on Sun Edison HR Policy, to be implemented bases on the IFC PS2 requirement	12/31/2012 12:00:00 AM	Completed	Completed	12/20/2012 12:00:00 AM
Submit copy of the Emergency Preparedness and Response Plan for both construction and operation to be implemented	12/31/2012 12:00:00 AM	Completed	Completed	12/31/2012 12:00:00 AM
Submit copy of permit(s) issued by the Rajasthan Pollution Control Board for project (a) construction and (b) operation	12/31/2012 12:00:00 AM	Completed	Completed	12/28/2012 12:00:00 AM
Submit copy of the transmission line impact assessment and mitigations	03/30/2013 12:00:00 AM	Completed	Completed	03/20/2013 12:00:00 AM