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; and IFC’s Performance Standards. The information about how these potential impacts will be addressed by the Company is summarized in the paragraphs that follow. Further information is provided in the attached documentation.
PS 1: Social and Environmental Assessment and Management System
Simran has, with the object of implementing state of practice social and environmental management in the Company’s projects and operations, engaged a third party to assist it in developing a SEMS consistent with IFC Performance Standards. Further, to identify and mitigate impacts associated with the Project, the Company has carried out a third party ESIA in accordance with IFC Performance Standards. In addition to its own SEMS and the mitigation measures delineated in the ESIA, the Company has also contracted a Developer and an O&M contractor (Suzlon), which has in place quality, environment, health and safety management system (QEHSMS) encompassing construction and O&M activities certified to ISO 9001, ISO 14001 and OHSAS 18001 standards. The Developers QEHSMS is adequately implemented on the ground.
Project related impacts on account of both construction and operation have been assessed and mitigation measures delineated in the ESIA including those pertaining to: air quality and ambient conditions; ambient noise levels and noise including cumulative noise impact; water, wastewater and sewage; hazardous and solid waste; cultural heritage; ecological impact including flora, fauna, birds and wildlife habitat; land use; air traffic; visual effects; transportation and impact on local infrastructure; community health, safety, shadow flicker; and socio-economic. Simran will ensure that the mitigation measures delineated in the ESIA are implemented in the Project construction and operation.
No forest area will be impacted by the Project. There are conservation areas (Mundanthurai-Kalakad wildlife sanctuary, Indira Gandhi Wildlife Sanctuary, Anaimalai Wildlife Sanctuary) are at least 20 km from the project sites and reserve forests (Grass Hills forest and Oothumalai) in Tiruppur and Tirunelveli districts are all at least 5 km from the project sites. Koonthankulam bird sanctuary attracts migratory birds but is at about 50 km from the Project sites. No migratory bird routes pass through the Project site. There are no nationally or internationally endangered bird species found in the Project site. The species identified at the Project sites are IUCN least concern species except one specie identified as vulnerable. Stakeholder consultations undertaken (as part of the ESIA) with local community members, academicians, Suzlon O&M staff and anecdotal evidence (since WTGs have been in operation in this area for a decade) indicates that no bird strike incidents have been observed/reported by either the local community or wind energy project developers/operators. Also, the region is monsoon dependant and becomes dry post-monsoon and there are no large water bodies that would attract migratory birds.
While significant impact may not be expected on avifaunal species, the Company will: (a) train at least two in-house staff on undertaking bird or bat strike monitoring; (b) implement a bird strike monitoring program; and (c) if the proposed monitoring program indicates significant bird or bat strikes, consult with and implement measures recommended by ornithologists/ wildlife experts, to address the impacts including if required, a shutdown protocol and enhanced collision monitoring program.
The Company will ensure adherence to IFC Performance Standards as applicable to its project and operations by implementing the SEMS company-wide including in its subsidiaries and future projects. The SEMS will encompass all project phases from project conceptualization/planning, design, construction, operation and to decommissioning. Further, the SEMS will include procedures for: identifying social and environmental risks and impacts of the Company’s future projects and operations; undertaking appropriate social and environmental assessment (SEA) all of the projects Simran (and/or its subsidiaries) implements in future; 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 its future projects, complete a SEA and implement a SEMP including a community engagement plan, which is consistent with IFC Performance Standards.
Simran will, to enable effective implementation of the SEMS, put in place as outlined in the SEMS: a social and environmental organization with appropriate responsibility allocation; and make available adequate resources including staffing of the organization with appropriately qualified social and environmental professionals. Under the corporate wide applicable SEMS and as part of each project specific SEMP, Simran will implement procedures for: (a) consultation and engagement with affected communities in accordance with IFC Performance Standard provisions; (b) ensuring that its contractors meet relevant provisions of the Company’s SEMS and project specific SEMPs; (c) social, environmental, occupational health and safety (SEHS) training of employees and contract labor; (d) recording, investigation and reporting of SEHS incidents including those involving contractors’ labor; (e) emergency preparedness and response; (f) periodic monitoring of SEHS performance; (g) internal and third party audit; (i) management review; (j) and periodic reporting of SEHS performance to the Company’s Board of Directors, regulators and investors.
Further, Simran will, as part of the SEMS, implement procedures to ensure that: (a) the Developer and the O&M contractor implement their respective ISO 14001 and OHSAS 18001 certified management system to the Project construction and operation; (b) cumulative impacts from any proposed future developments and/or future wind projects by the Company at this site are assessed and mitigated in a manner consistent with the IFC Performance Standards; (c) implementation of the mitigation and monitoring measures for construction and operation phases delineated in the ESIA and any additional mitigation measures described here-below; (d) development and implementation of site risk management and emergency response plans; and (e) monitoring, investigation and corrective action on environmental, occupational health and safety (EHS) incidents.
PS 2: Labor and Working Conditions
Simran has engaged on its rolls one persons and plans to add about 10 employees in a phased manner, primarily to supervise the Developer and O&M contractor. Simran also adheres to Techno’s HR Policies and procedures. Techno is in the process of developing a formal HR Policies and Procedures manual, which will also be adopted by Simran. Techno’s draft HR policy and procedures manual includes policies outlining: service rules/terms of employment; working hours; leaves; retirement/separation; compensation; benefits and employee welfare; and anti-harassment. In addition to adopting Techno’s HR policies and procedures Simran will, to meet Performance Standard 2 provisions, appropriately incorporate additional procedures particularly in areas pertaining to employee grievance redress, disciplinary action, prevention of harassment, non discrimination, and communication of HR policies and procedures to staff. Working conditions are communicated to employees through their appointment letters/contracts. Further, the HR Policies will be made available on the Company’s intranet and communicated to employees during induction. Simran will ensure that all of its employees undergo periodic health check up and will ensure that the Developer/O&M contractor’s has in place a periodic employee health checkup program.
About 40 construction workers are expected to be deployed by the Developer at each of the two sites during the 6 month construction period for the Project. The O&M contractor typically deploys about 150 persons at each CMS of which about one third are contract workers and balance on the O&M contractor’s rolls. While construction workers are expected to be from outside the region, the contract workers during operation phase are expected be from the local villages. The Company will, as part of the SEMS, put in place procedures to obtain assurance that the Developer/O&M contractor meets host country labor laws. Labor accommodation will be set up during the construction phase for about 40 workers. The Company will ensure that adequate facilities and amenities are provided in the labor accommodation including: adequate living/sleeping facilities and space per person; potable water that meets national standards; toilets, washing and cleaning facilities; canteen/mess or fuel for cooking; locker/storage facilities; and facilities for management and disposal of garbage, sewage and other waste. Simran will: require the Developer and O&M contractor to implement OHSAS 18001 certified safety standards during construction and operation; and periodically review OHS performance of the O&M contractor.
PS 3: Pollution Prevention and Abatement
Ambient air quality parameters in the Project area are well within national standards. Temporary impact on ambient air quality is expected during construction phase and mitigation measures, to minimize this adverse impact, are proposed including dust suppression, covered transport of excavated earth and management of pollution from vehicular and equipment emissions. Baseline noise levels in the Project area are generally about the national standards but there are locations where night time noise levels exceed the national night time noise standards. Incremental noise level increases during construction will be temporary, restricted to day time working hours and limited to the vicinity of the noise generating source, except in case of movement of material through/near habitations or other sensitive receptors. The Company will implement measures to minimize adverse impact due to construction activities, equipment and from transportation. The noise impact assessment indicates that material noise impact on sensitive receptors is not expected on account of the Project.
River or groundwater, about 145 m3 per WTG, will be sourced for construction (including consumption at labor camps) and water consumption during operation stage will be for domestic purposes/toilet water for operation staff only. While, material impact on water sources is not expected on account of the Project both during construction and operation stages, water will be used for consumption after appropriate treatment to meet national potable water quality standards. Further, the Company will implement an appropriate rainwater harvesting program. Domestic wastewater during construction and O&M phases will be disposed through septic tank and soak pit route.
While construction will be generally avoided during rainy periods, appropriate mitigation measures to minimize erosion and water pollution will be implemented. Surplus excavated earth (from raft foundation and road work) will be used for road leveling work and for localized leveling work around WTGs. Other solid waste (particularly packing material, metal and debris) will be collected, stored and disposed off to reusers or in appropriate debris disposal areas. The Company will require the Developer and O&M contractor to ensure that hazardous material (paints, lubricants and oils etc) which are brought to the Project site and hazardous wastes (used/waste left over paint, paint and oil soaked rags/material, empty oil/paint drums/carbuoys, filters etc.) generated at site (both during construction and operation) are: stored under segregation and containment; handled/used with appropriate care and personal protective equipment; and disposed off through entities authorized to handle and dispose hazardous wastes. The Company will ensure that: transformers do not use PCB containing oils; and ozone depleting substances banned/phased out under Montreal Protocol are not used.
The Project will result in reduction of GHG emissions. In view of this, Simran will develop the Project as a clean development mechanism (CDM) project under the Kyoto Protocol and earn carbon credits from the Project. The Project is expected to result in avoidance of 288,594 tCO2e per annum.
PS4: Community Health safety and Security
Typically, as per industry norms, a distance of 7 times rotor diameter (in the downwind direction/columns) and a distance of 5 times rotor diameter (in the cross wind direction/rows) is maintained at a minimum between two WTGs. This translates to a WTG spacing of 616 m and 440 m along columns and rows respectively for the 2.1 MW turbines. The corresponding spacing for 1.5 MW turbines is 574 m and 410 m. The Project equipment, plants and infrastructure meet good industry practices. The measures to minimize community health and safety risk due to construction and movement of vehicles during construction, in particular due to heavy vehicle movement, have been delineated in the ESIA. The Company will monitor adherence to recommended measures and where required ensure appropriate material movement planning, signage, traffic control, site barricading, reflectors, and other measures to mitigate the risk of accidents for general public during construction. The sites are located in low to moderate risk zone with respect to earthquake, cyclones nd floods. The turbine design includes safeguards for storms and seismic activity.
The Project is not expected to result in community exposure to disease either due to changes in land/hydrologic other terrestrial/air quality/hydrologic regimes or through large influx of migrant labor, though some construction workers (about a maximum of 40) is expected during project construction period. The Company will implement measures including: identification clearing of any natural drains that may get blocked during construction; and periodic erosion checks. While significant topography changes are not expected the WTGs on account of the Project will impact the landscape character. However, to minimize any adverse visual impact, the WTGs in a cluster will all be of uniform size, design and shape colors.
The site is not located on any air traffic route. The Project area is sparsely populated, the landscape is flat and most of the WTGs are located at more than 400 m from the nearest habitation. In accordance with the recommendation in the ESIA, the Company will: implement a program to monitor risk of shadow flicker impact on nearby households during operation stage; and in consultation with the affected households, implement appropriate necessary mitigation to reduce or prevent shadow flicker including required provisions of curtains/blinds/screens and establish screening vegetation. Simran will as part of the SEMS prepare and implement an onsite and offsite Disaster and Emergency Management Plan for electrocution, occupational or community safety incidents, fire and other emergencies.
The Developer/O&M operator will employ security personnel during Project construction and operation. The security personnel will not be armed. However, the Company will put procedures in place to ensure 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.