While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the proposed investment will have impacts which must be managed in a manner consistent with the following Performance Standards:
PS 1: Social and Environmental Assessment and Management System;
PS 2: Labor and Working Conditions;
PS 3: Pollution Prevention and Abatement; and
PS 4: Community Health, Safety and Security

Purchase of private land is on a willing seller – buyer basis. Both private and government land were primarily used for grazing. Since contiguous land is not being purchased including on account of proposed projects and the Company will ensure continued access for grazing, no involuntary resettlement (physical or economic) is expected as a result (PS5). There are no internationally endangered avifaunal species in the Project area, no adverse impact on nationally specified avifaunal species expected nor are any forest/protected areas being impacted by the Project. Hence, material adverse impact on biodiversity (PS6) is not expected on account of the Project. For the purposes of PS7 (Indigenous Peoples) and PS8 (Cultural Heritage), no material degradation and adverse impact is expected on land resources on which indigenous peoples are dependent nor is any cultural heritage expected to be adversely impacted. There are three religious structures (temples) of importance to local communities in the vicinity of the Project site but these are not expected to be adversely impacted.

The proposed IFC loan to the Project is a Category B project because a limited number of specific environmental and social impacts may result, which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. Potential impacts in construction activities besides being mitigable are likely to be limited to project site; short term; and not expected impact environmentally sensitive areas. Further, it is possible to readily design and implement engineering and management measures to mitigate adverse impacts during construction and operations. The Company will manage its environmental and social performance in accordance with applicable local laws and regulations and international standards, including IFC’s Performance Standards on Social and Environmental Sustainability.

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.

PS1: Social and Environmental Assessment and Management System
NRPPL, in accordance with the provisions of its SEHSMS related to wind power projects, has carried out a third party environment and social impact assessment (ESIA), to identify and mitigate Project related risks and impacts in a manner consistent with IFC Performance Standards. The Company also engaged a third party expert to carry out a rapid biological assessment, to assess the risk of any significant adverse impact on avifauna due to the Project. In addition to the mitigation measures delineated in the ESIA, ReGen has in place environment, health and safety management system (EHSMS) encompassing construction and O&M activities certified to ISO 14001 and OHSAS 18001 standards.

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; visual effects; transportation and impact on local infrastructure; community health& safety; shadow flicker; labor influx and socio-economic. NSL Wind will ensure that the mitigation measures delineated in the ESIA are implemented in the Project construction and operation. The ESIA has also considered cumulative impacts from existing and proposed turbines particularly those that will be located within 1.5 km of Virali and Chilarwadi villages (the Project affected villages).

No forest area will be impacted by the Project. The Project site is at safe distances from conservation areas/protected areas/World Heritage sites, such as Chandoli National Park (100 km), Koyna Wildlife Sanctuary (87 Km), Kas Plateau (90 Km), Radhanagari Wildlife Sanctuary (150 Km) and Mayani Bird Sanctuary (10 Km). There are no major wetlands with high bird activity in the immediate vicinity of the Project site. Nor is the site in close proximity of internationally known sites for birds, bats or biodiversity. Project site falls in low bird activity (water birds and raptors in particular) and low intensity migration routes of large bodied birds. Moreover, no roosting, feeding or breeding habitats of any threatened bird species are reported from the Project site. However, 2 roost of common bat species i.e. Indian Flying Fox were identified but at a reasonable distance from the Project site. Carcass searches in the vicinity of existing operating turbines have not indicated collisions. Overall, there is a low risk of bird hits and mortality at the Project site.

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; (c) monitor the two identified bat roosts for their presence and population for 3 years from Project commissioning; (d) implement a program to identify any other bat roosts, particularly presence of endemic species, if any; and (e) if the proposed monitoring program indicates significant bird or bat strikes or collision risk, complete a one year bird study and 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: applicable provisions of its corporate SEHSMS; and mitigation, monitoring and management measures outlined in the ESIA. NSL Wind will, put in place as outlined in the ESIA, a social and environmental organization with appropriate responsibility allocation. The Company 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 requirements of the Project environment and social management plans (ESMPs); (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 NRPPL, the Company’s Board of Directors, regulators and investors.

Further, NSL Wind will implement procedures including contractually requiring ReGen to: (a) implement its ISO 14001 and OHSAS 18001 certified management system to the Project construction and operation; (b) implement the mitigation and monitoring measures for construction and operation phases delineated in the ESIA and any additional mitigation measures described here-below; (c) develop and implement site risk management and emergency response plans; (d) monitor, investigate and implement corrective action on environmental, occupational health and safety (EHS) incidents during construction and operation; and (e) periodically report its SEHS performance to NSL Wind during construction and operation phases.

PS2: Labor and Working Conditions
NSL Wind has engaged on its rolls 4 persons, 4 persons are deputed from NRPPL and plans to add another 2 employees in a phased manner, primarily to supervise ReGen. The Company adheres to NRPPL’s HR Policies and procedures. NRPPL’s HR Policies and procedures are being further upgraded to incorporate the findings of a third party review of their implementation in NRPPL’s operations. The upgraded HR Policies and Procedures consistent with IFC Performance Standards will be implemented in the Company. The Company’s HR Policies will be made available to all employees through NRPPL (as also the Company’s) intranet, and communicated to employees during induction. NSL Wind will ensure that all of its employees undergo periodic health check up and will ensure that ReGen has in place a periodic employee and worker health checkup program.

About 25 workers will be required during operation phase while a maximum of 300 workers are expected during peak construction phase of 6-8 months. While construction workers are expected to be from outside the region, the contract workers during operation phase are expected to be from the local villages. During construction and O&M stage, ReGen is expected to share workers and other resources with its other projects as well. The Company will put in place procedures to obtain assurance that ReGen meets host country labor laws both during construction and operation phases. Labor accommodation will be set up during the construction phase for about 250 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. NSL Wind will: require ReGen to implement OHSAS 18001 certified safety standards including the measures delineated in the ESIA during construction and operation; and periodically review OHS performance of ReGen during construction and operation phases.

PS3: 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 within the national 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 (including cumulative impact from turbines within 1.5 km of the villages), indicates that material noise impact on sensitive receptors is not expected on account of the Project.

River or groundwater, about 450 m3 per day at peak construction (including consumption at labor camps) will be sourced through authorized water suppliers. Water consumption during operation stage is expected to be limited and will be for domestic purposes/toilet water for operation staff only. Material impact on water sources is not expected on account of the Project both during construction and operation stages. The Company will ensure that the, 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. However, a package type sewage treatment plant will be set up in the labor camp for treatment and reuse of camp sewage and wastewater.

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 the turbines. Excavated top soil will be: stored separately to protect grass spores that may be present; and will be spread on embankments and leveled unpaved areas for grass/shrub regeneration. Other solid waste (particularly packing material, metal and debris) will be collected, stored and disposed off to re-users or in appropriate debris disposal areas. The Company will require ReGen 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, batteries, used hydraulic oil 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.

PS4: Community Health, Safety and Security
The Project equipment, plants and infrastructure meet good industry practices. The sites are located in moderate risk zone with respect to earthquake and low risk of floods and cyclones. The turbine design includes safeguards for storms and seismic activity. Overall, road and access infrastructure in the area is good and significant pressure on infrastructure is not expected due to the Project and other proposed wind farm developments. Further, ReGen will share resources, labor and infrastructure (e.g. T-line) between several of its projects to minimize impact. 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, deployment of traffic marshals, traffic control, site barricading, reflectors, and other measures to mitigate the risk of accidents for general public during construction.

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 construction worker are expected for a limited period during project construction. The Company will nevertheless require ReGen to have measures in place to identify and mitigate risk of community exposure to disease due to influx of labor. The Company will implement measures including: identification and clearing of any natural drains that may get blocked during construction; and periodic erosion checks. While significant topography changes are not expected the turbines on account of the Project will impact the landscape character. However, to minimize any adverse visual impact, the turbines in a cluster will all be of uniform size, design, shape, colors and will use non reflective paint.

The Project area is a table top hill, with flat landscape and no habitation on the top. The Company will allow normal movement of goats and sheep in most part of the site. However, NSL Wind will ensure that all transformers are fenced and cables insulated to avoid any electrical hazards. All community functions in the neighboring temples will continue and NSL Wind will also improve the existing access infrastructure to these culturally important sites as required. The nearest village is at about 700 m from the Project site and at about 100 m lower elevation. All turbines will have a minimum set off of 500 m from the tabletop hill edge at locations close to habitation/villages and vegetation will be planted on the slope to the villages at 100 m lower elevation. Turbines in the vicinity of the three temples, will maintain an offset of more than 700 m. While shadow flicker impact is not expected, 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. The site is not located on any air traffic route. NSL Wind and/or ReGen will prepare and implement an Emergency Management Plan for electrocution, occupational or community safety incidents, fire and other emergencies.

ReGen will employ about 20 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 abusive conduct; 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 land agency has, prior to purchase of land for the Project, carried out well attended consultations meetings in each of the three villages (Puklewadi, Chilarwadi and Virali) in 2008. In these consultation meetings a project brief was explained and questions from members of the community addressed. Subsequently, a No Objection Certificate was obtained from each of the three village panchayats (elected local self government institutions). Further, the ESIA consultants have, as part of the ESIA process, consulted with various stakeholders, panchayat members, land sellers, and members of the three village communities. The concerns and expectations expressed by the local communities have been addressed in the ESIA and the Company will, in consultation with the affected community, develop and implement a community development plan. A community engagement plan has been outlined in the ESIA for ongoing engagement with the neighboring community, which the Company will implement. Further, a community grievance redress procedure, as outlined in the ESIA, will be further detailed and implemented by the Company. This grievance redress procedure will be communicated to the affected communities and implemented prior to start of construction at site.

The Company will locally disclose the social and environmental information including the ESIA for the Project at the following locations:

Panchayat Office,
Chilarewadi Gram Panchayat,
Taluka Man, District Satara
Maharashtra

Any queries and/or comments about the Project may be directed to:

NSL Renewable Power Private Limited
NSL Icon, 4th Floor, Banjara Hills
Road No 12, Hyderabad – 500 034