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; and
• PS 2: Labor and Working Conditions

Projects being developed by POWERGRID will result in impacts which will have to be managed in a manner consistent with PS1, PS2, and one or more of the following Performance Standards:

• PS 3: Pollution Prevention and Abatement;
• PS 4: Community Health, Safety and Security;
• PS 5: Land Acquisition and Involuntary Resettlement;
• PS 6: Biodiversity Conservation and Sustainable Natural Resource Management;
• PS 7: Indigenous Peoples; and
• PS 8: Cultural Heritage.

While POWERGRID’s individual transmission line projects typically have limited social and environmental impact (typically Category B), several of the projects to be implemented by POWERGRID have a large geographical spread, voltages above 400 kV, large substations, and it is reasonable to assume that some of the project transmission lines may pass through forest areas. Due to the broad scope of the proposed corporate investment, it cannot be completely ruled out that implementation of some of the projects by the Company may result in potentially significant adverse social and environmental impacts. Hence, IFC is treating this as a category A investment according to IFC’s procedure for Environmental and Social Review of Projects. This is consistent with the categorization of the “Fifth Power System Development Project” (# P115566) by The World Bank.

The proposed loan is not targeted at any of POWERGRID’s specific assets but is being provided to the Company to partly fund its capital investment program. In such investments, IFC expects that the Company will have in place social and environmental management systems to ensure that the Company’s projects and operations, including the projects and operations of POWERGRID controlled subsidiary companies will be consistent with IFC Performance Standards.

The key risk and issue related to this Investment is efficacy of POWERGRID’s environment and social assessment processes and corporate social, environmental, health and safety management system (SEHSMS). In the context of the Investment, the key social and environmental risks and impacts include: the impacts on households due to restrictions/constraints in the proposed RoW for Transmission Lines; land acquisition for substations; crop damage and loss of trees during construction and maintenance; community consultation and engagement; labor working conditions including employee and contract labor health and safety; impacts to soil, air and water during construction and operation including management of hazardous materials and hazardous and other wastes; employee and community health and safety impact during construction and operation including effects from electromagnetic field; and impacts on terrestrial and aquatic habitat during construction and operation of projects to be implemented by the Company.

POWERGRID has presented plans to address these impacts to ensure that the proposed Investment will upon implementation of the specific agreed measures, operates in a manner consistent with the environmental and social requirements including: the Government of India (GoI) laws and regulations; POWERGRID’s social, environmental, occupational health and safety management system (SEHSMS); 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

POWERGRID has implemented an integrated quality, environment, occupational health and safety management system (IMS) to manage its facility operations that is certified to International Standards Organization (ISO) 9001 for Quality Management, ISO 14001 for Environmental Management, and OHSAS 18001 for Occupational Health and Safety. The Company has also obtained SA 8000 certification for its human resource and labor management policies and practices. . The Company will ensure that it operates in a manner consistent with IFC Performance Standards and will obtain assurance on its effective implementation through independent third party audits of the ISO 14001 and OHSAS 18001 certified IMS and SA 8000 certified HR processes, and audit of the ESPP by their Independent Expert Committee. Further, POWERGRID has implemented Environment and Social Policies and Procedures (ESPP) covering all of its projects, which is consistent with The World Bank Social and Environmental Safeguard Policies (“Safeguard Policies”). The ESPP lays down a framework for identification, assessment and management of environmental and social risks and impacts associated with POWERGRID’s projects based on the avoidance, minimization and mitigation principle and hierarchy. The ESPP framework includes procedures for: (a) Screening and Identification of Risks (from environmental receptors, social receptors and other stakeholders); (b) avoidance of risks (including criteria and procedures for alternative routing); (c) mitigation of risk through impact management, implementation of Good International Industry Practices (GIIP), adequate compensation to affected stakeholders, public consultation and disclosure, and grievance redress; (d) monitoring, reporting, evaluation, feedback, management review and corrective action; and (e) responsibility and resource allocation including an organization structure for management of social and environmental (“S&E”) risks

POWERGRID carries out environment and social assessment (ESA), commensurate with the associated risks and impacts, for all projects it undertakes. The need for level of detail to be included in the ESA is established as part of the screening and scoping exercise, which is undertaken at the time of project feasibility report preparation. The ESA process is designed to: ensure compliance with applicable laws including national laws for implementing international environmental agreements ratified by the GoI; identification and mitigation of trans-boundary impacts particularly in case of projects that traverse more than one country; and meet the requirements of The World Bank Safeguard Policies. The ESA process is suitably linked to the project cycle so that the ESA outcome appropriately informs the feasibility studies, route and site surveys, project design, social assessments, government approvals and project implementation scheduling. The ESA results in the development of an Environmental Assessment and Management Plan (EAMP) and Social Assessment and Management Plan (SAMP) setting forth: (a) measures to mitigate adverse impacts, (b) monitoring requirements for ensuring the mitigation measures are implemented effectively and in a timely manner; (c) organizational and financial resources for carrying out the measures; (d) an implementation schedule for these activities; and (e) an appropriate structure including provisions for penalties to ensure plans are implemented. In cases where scoping determines that a detailed ESA need not be undertaken e.g. where sub station is not proposed or where alignment is not expected to pass through forests, the Company will include, in the construction contracts, a detailed set of standardized mitigation measures based on Good International Industry Practices and evaluate contractor performance against compliance with these measures. POWERGRID will disclose this standard set of mitigation measures together with the ESPP through its website.The ESPP has also delineated an Environmental and Social Risk Framework (ESRF) that outlines the process for S&E risks identification, prioritization, selection of mitigation & management options; and responsibility allocation.

POWERGRID undertakes an analysis of alternative route options (at least 3 alternate alignments) for Transmission Lines and locations for sub stations (SS) during screening and scoping, in consultation with relevant environmental and social staff in POWERGRID. The criteria used to compare alternative Transmission Line routes and substation (SS) sites include an initial assessment of impacts, feasibility of mitigating the identified impacts, capital and recurrent costs, consideration of institutional, training and monitoring requirements associated with each alternative as well as the “no action” alternative. The criteria used by POWERGRID in transmission line route planning addresses several key social and environmental aspects including: (a) easy approach and accessibility for construction and maintenance with access available during both dry and rainy season; (b) economy of route and minimization of angle points; (c) avoidance of wildlife sanctuaries, national parks, reserved forests, high tree areas, archaeological monuments, places of worship and cremation; (d) avoidance of mining, defense establishments and other sensitive areas like air ports and aircraft landing approach; (e) avoidance of densely populated areas, large habitations, expanding villages and towns, planned development zones and non agricultural land with development potential; (f) minimization of steep sloping terrain, areas prone to soil instability, flooding and landslides, marshy land, river bed and low lying areas; (g) minimization of rail, river, stream, road, power line and communication line crossings; (h) avoidance of areas with gardens, nurseries, plantation etc.; and (i) avoidance of local community assets like playground schools, places of worship. POWERGRID relies upon modern techniques to optimize its route selection including maps, walk over survey, aerial photographs, GPS markings, satellite imagery processing, field checking and detailed survey.

To ensure implementation of the SEHSMS, the Company has put in place an appropriate organization comprised of an Environment and Social Management Department (ESMD) at the corporate level headed by a General Manager, supported by five environmental and social specialists and who reports to the Director Projects . In each of the nine regions, a separate Environmental and Social Management Cell (ESMC), headed by a Deputy General Manager or Chief Manager is responsible for managing environmental and social activities and ensuring coordination with ESMD. Further, at the project site level, the project/site head selects and deploys personnel with relevant background and those trained in implementation of the ESPP, to form a core group called the Environmental and Social Management Team (ESMT). The ESMT is directly responsible for implementing the Environment Assessment Management Plan (EAMP) and Social Assessment Management Plan (SAMP) and undertaking day to day monitoring of EAMP and SAMP implementation. POWERGRID engages a suitable external agency to implement the SAMP but the Company monitors all Resettlement and Rehabilitation (R & R) measures; prepares periodic monitoring reports on status of EAMP and SAMP execution; and annually reviews the performance of environmental and social management measures. Annual review of effectiveness of ESPP implementation is undertaken by an Independent Committee of Experts; and has also published a Sustainability Report (FY 2008-09) based on Global Reporting Initiative Guidelines.

To ensure that the organization for ESPP implementation is effective, POWERGRID has identified skill requirements covering skill/expertise required for: conducting ESA of projects; environmental mitigation and management; risk assessment and management; compliance with GoI and regulatory requirements; monitoring, internal auditing and process review. The resources with appropriate/relevant skill requirements are allocated to the various organizational units including the ESMT, ESMC, ESMD and the Engineering and Corporate Planning Departments. The Company has in place a program for staff development and training in ESPP, S&E policy, environmental assessment and management, risk assessment and management, and environmental management planning covering corporate HQ and regional HQ levels. POWERGRID implements a EHS training program for contractors and contract workers deployed on POWERGRID’s project and operating sites.

The Company, as part of the ESPP, implements: a monitoring and reporting framework; procedures for internal and external audit to obtain assurance on implementation of project specific EAMP, SAMP & RAP, the IMS and the ESPP; and management review to enhance IMS and ESPP effectiveness. The contracts awarded by POWERGRID include provisions that require the contractor to comply with labor laws, adhere to safety norms, and implement the mitigation measures detailed in the EAMP and SAMP.

The EAMP and SAMP are integrated with the construction, operation and maintenance activities and is monitored by ESMD on a monthly basis in association with the Corporate Monitoring Group (CMG). CMG is charged with the responsibility of monitoring all projects and reports to Director Projects of POWERGRID. POWERGRID senior management is apprised of the results on the EAMP and RAP monitoring for each project through a monthly report. Further, the Company has established a Committee of External Experts to provide ongoing advice on its implementation of the ESPP at the corporate level and in specific high risk projects.

Pollution Prevention Measures

POWERGRID’s SEHSMS includes procedures to avoid or minimize adverse impacts on human health and the environment by avoiding or minimizing pollution from its projects and operations including measures to abate emissions that contribute to climate change. The mitigation measures together with other Standard Operational Procedures implemented by the Company, contains numerous detailed provisions that are comparable to Good International Industry Practices including those contained in the applicable WBG EHS Guidelines. While the primary source of energy at POWERGRID’s installations is grid electricity, at some locations and particularly construction sites, diesel generator (DG) sets may be provided for backup power. The principal point source of air emissions at such locations are the stacks attached to the DG sets. POWERGRID ensures that DG set emissions (though these are for standby operation only) meets WBG/IFC norms. On account of POWERGRID’s operations no material long term increment in ground level concentration of suspended particulate matter (SPM), respirable particulate matter (RPM), Sulphur di-oxide (SO2)and Oxides of Nitrogen (NOx) as also noise levels is expected. The Company provides acoustic enclosure for DG sets as per host country regulations. The Company ensures that any cleaning chemicals and refrigerant used in air conditioning system as also the fire extinguishers gases, comply with the Ozone Depleting Substances Rules set by the GOI under Montreal Protocol requirements. None of POWERGRID’s power transformers use oils containing poly-chlorinated biphenyls (PCBs). POWERGRID has procedures in place to test and monitor PCB presence in transformer oils and ensures that these remain within accepted limits. The Company as part of the ESA details adequate measures to minimize fugitive emissions to air and to mitigate air quality as also ambient noise level impacts during construction.

There is limited process water requirement (for thyristor cooling) during operation and there is a limited short term demand expected at each tower construction section. There is no process waste water generation. However, water is required for domestic consumption in sub stations and in relatively higher quantities (about 25 to 50 m3/day) at substations where employee housing is provided. Typically groundwater is used for domestic consumption and the Company ensures that drinking water complies with GoI standards. Domestic waste water is generated at sub stations, which is discharged through septic tank and soak pit. Septic tank sludge and domestic garbage from employee housing is disposed through authorized agencies at designated municipal disposal and dump sites. The Company in future proposes to build remotely controlled sub stations which will avoid building colonies within sub stations, which is expected to further reduce impacts on land, soil, water and air environment. However, at construction sites, higher volumes of sanitary effluent are generated from labor camps. The Company will ensure that contractor makes available appropriate sanitation facilities such that sanitary wastewater is not discharged untreated into surface water bodies or on land. POWERGRID is also implementing a companywide rainwater harvesting program.

Hazardous wastes generated on the Company’s sub-station premises include spent transformer oil, lubricants, dielectric containing waste equipment, oils from DG set & breakers, batteries, gaskets/other maintenance wastes, oil filter and used oil & chemical drums/carbuoys. The Company’s practices relating to handling and disposal of hazardous wastes are consistent with applicable laws. All transformers have oil trap (concrete) or oil sump pit. No herbicides/ Pesticide/ insecticides are being used. Only manual weeding is undertaken. During construction, the Company requires contractors to develop appropriate procedures and facilities for storage and handling of oils, lubricants and for management of spills including provision of temporary secondary containment facilities. The Company segregates and stores scrap as also other waste material, in designated areas both during construction and operation.

To prevent loss of top soil during construction as also to prevent sedimentation of surface water bodies, POWERGRID, where required, implements erosion control measures including among other measures: slope stabilization (rip/rap); avoidance of excavation during monsoon/rainy season; pit water discharge in a manner to avoid sedimentation of water bodies and wetlands; segregation and separate stockpiling of top soil; and spreading back of the topsoil after completion of work. Rocks and other construction waste disposal at pre-selected sites or are reused in backfilling, slope stabilization or stream banks.

POWERGRID uses breakers that contain SF6, a greenhouse gas with a very high global warming potential. The Company has a program in place to: minimize SF6 loss/leakage to atmosphere; and recycle and reuse SF6. Further, POWERGRID continues to endeavor to reduce GhG intensity of its operations through system efficiency improvements and have commenced the process of quantifying the avoided GHG emissions.




Community Health and Safety Protection Procedures

POWERGRID as a corporate policy adheres to internationally recognized standards (Indian Standards, British Standards, IEEE and IEC standards) in design and construction of facilities, laying of transmission lines, support infrastructure and in selection of equipment. Further, the Company endeavors to avoid habitations and densely populated areas while selecting route alignment. Alignments are generally sited 10-15 km away from major towns, whenever possible, to account for future urban expansion. Moreover, the Company adheres to clearance norms prescribed in Indian Electricity Rules and has developed clearance norms for: (a) clearance above ground for lowest conductor; (b) vertical clearance from buildings; (c) horizontal clearance from buildings; (d) minimum clearance between lines crossing each other; and (e) minimum clearances prescribed for live equipment in outdoor sub stations. A review of POWERGRID’s designs indicates that phase to phase and circuit to circuit clearances are consistent with practices used in line clearances throughout the world. The values used by POWERGRID are in the middle range of those used throughout the world and are expected to provide satisfactory performance. In particular conductor to ground clearances meet or exceed the requirements of the National Electrical Safety Code, American National Standard Institute.

A study carried out by the Central Power Research Institute on POWERGRID lines indicated that the EMF about one meter above ground near a 400 kV single circuit transmission line ranges from 3-7.2µT in the RoW as compared to acceptable norm of about 100 µT. The Company, prior to charging/commissioning of a Transmission Line, issues public notices and pamphlets to inform local communities of the key risks as also dos & donts to be observed. The above awareness creation measures together with engineering controls like line tripping, clearances, regular patrols and distance from habitation are in place to address community safety. To prevent hazards to aircraft, POWERGRID provides aviation markers, night-lights for easy identification of towers in notified/selected areas.

POWERGRID ensures that project contractor adopt good SEHS practices during construction. The Company ensures that the project contractors: train equipment operators and drivers in safe driving techniques; develop a materials movement plan to ensure that vehicle movement during construction has minimal impact on normal life patterns of nearby communities; undertake appropriate measures to reduce fugitive emissions from storage and transport of excavated earth and other construction material; restrict night time activities and when required, to low noise generating activities; and use construction equipment with appropriate noise mufflers/provision for attenuation of noise.

POWERGRID requires its contractors to ensure that to the extent possible, members of local community are employed as construction laborers. However, in light of skill requirements, an influx of labor, though for relatively short duration is expected during the project construction period. The Company requires that appropriate amenities/facilities for migrant labor compliant with national law are provided by the project contractors during construction. In pursuit of its continual improvement objective, the Company will endeavour to adopt best practices on amenities/facilities implemented by international companies, through it’s contractors in a phased manner. POWERGRID’s projects are not expected to exacerbate community exposure to disease due to changes in land/hydrologic or other terrestrial/air quality/hydrologic regimes. The Company, in design and development of large sub stations, implements measures to ensure minimal disruption of natural drainage pattern and where unavoidable, implements appropriate mitigation measures including culverts/diversion of storm water flows. However, the Company will require the project contractor, where relevant and applicable, to implement measures to minimize risk of community exposure to disease due to influx of large pool of laborers.

POWERGRID engages security personnel through Directorate General Resettlement (DGR) (an organization under Ministry of Defence, Govt. of India) empanelled security service providers. While at most locations, security personnel are not armed, at some locations armed security personnel are deployed through DGR only. Further, Central Industrial Security Force (a GoI security organization for securing government and public undertaking facilities) is deployed only at a few high risk locations. In pursuit of its continual improvement philosophy, POWERGRID will review and update its security arrangements, if required, as per Security Personnel Requirements under IFC Performance Standard #4.

Social Entitlement and Compensation Procedures

The Company is committed to minimizing Resettlement & Rehabilitation (R&R) in all its projects by appropriate siting of sub stations (SS) and Transmission Line (T-Lines) by to the extent possible: minimizing land take for Sub stations ; using government land; scheduling project construction work to accommodate crop harvesting; and locating SS away from sensitive areas. To date only two parcel of homestead land has been acquired by the Company resulting in physical displacement of two household. POWERGRID undertakes social screening and scoping for transmission lines (T-Lines) and substations (SS) to identify socially sensitive areas, issues and management measures, as well as to identify alternate alignment and location options. Alternative site assessment is carried out to identify T-Line routes and SS sites that: require a minimum of land acquisition; minimize other impacts on Project Affected Persons (PAPs); and avoidance of populated (urban and rural) areas, natural forest and plantations in route alignment and for the location of SS. The Company is not required to acquire land for its Transmission Lines and Transmission Towers (TTs), and permits cultivation to continue beneath the Transmission -Lines and Transmission Towers during operations.

Typically, POWERGRID acquires about 15 – 40 hectares of land for sub-stations. The Company prefers to acquire government land for substations. In case of non-availability of government land, the Company acquires private land (resulting in involuntary resettlement), and at times also purchases land through willing seller-buyer transactions (i.e. without involuntary resettlement). However, POWERGRID does not acquire Right of Way (RoW) as it is temporarily required only for laying, occasionally for operation and maintenance of transmission lines. RoW required along the route alignment is: 27 m, 35 m, 52 m, 46/52 m and 64-85 m wide strip of land for 132 kV, 220 kV, ±500 HVDC, 400 kV double circuit/single circuit and 800 kV transmission lines respectively.

In RoW for T-Line, while ownership of land vests with the land owner, the land owners forgo the right to: (a) build permanent structures anywhere within the safety area of the RoW; (b) plant tall trees or undertake plantation activities within the RoW, except if using short height trees; and (c) divert land under tower footing from past use. Where the land within RoW is used for agriculture, the land owners may continue to cultivate the land after the T-Line has been strung. However, where the land is used for tree plantations (fruiting or of timber variety), the land owners are required to plant only dwarf variety or low height trees within the RoW. In requiring RoW, POWERGRID adheres to host country requirements of prevalent Indian Telegraph Act and The Electricity Act. The act provides for payment of tree loss and crop loss compensation, which the Company provides.

The Company endeavors to minimize involuntary resettlement beginning with an avoidance strategy. Where complete avoidance is not possible, POWERGRID has, as part of the ESPP, developed an entitlement framework to, as applicable, mitigate adverse social and economic impacts from land acquisition or restrictions on affected persons’ including informal settlers’ use of land by: (i) preferring land for land where feasible, in particular where tribal (IP) communities are impacted; (ii) providing compensation for loss of assets at replacement cost, transition support & income generation support as relevant,; (iii) replacement or enhancement/augmentation of impacted common property resources to deliver equivalent functionality; (iv) ensuring that resettlement activities are implemented with appropriate disclosure of information, consultation, and the informed participation of affected communities; and (v) improve or at least restore the livelihoods and standards of living of displaced persons. The Company as part of the ESPP provides informal settlers compensation for structures and transitional benefits including transport and cash also towards livelihood restoration. While it does not offer security of tenure as part of the compensation package, the Company as a policy endeavors to avoid physical displacement through appropriate siting of sub stations, minimization of land acquisition and in selecting Transmission Line right of way alignment. This is evidenced in the fact POWERGRID operations since 1998 and construction of several thousand cktKm of T-lines has resulted in physical displacement of only two households. So long as the Company continues to strictly adhere to the philosophy of preferring avoidance of physical displacement, the incidence of informal settler physical displacement will remain very low.

The Company has prepared a Social Entitlement Framework (SEF) under which: (a) a preliminary assessment is carried out for Sub Stations at the stage of site/land selection (to assess total land required, its location, current land use pattern, likely persons to be affected, and government body that has jurisdiction to acquire such land); (b) Land Acquisition Census & Assessment for SS is undertaken; (c) Social Assessment and Management Plans (SAMPs) are prepared for both T-Lines and SS covering social survey & review, compensation and other rehabilitation measures with special focus on marginalized & vulnerable groups as also impacted host communities; and (d) where there are 40 or more PAPs, a Rehabilitation Action Plan (RAP) is prepared, which details entitlements consistent with National Policy on R&R 2007, for each affected family/person. Typically, where 40 or more households are affected the SAMP is prepared by en external agency otherwise SAMP is prepared by in-house experts. Further, to monitor RAP implementation a committee is formed constituted of POWERGRID representatives, representatives of local government authorities, Panchayat (elected representatives), PAPs and NGOs. The Company has procedures requiring that RAP implementation be completed within 12-15 months of commencement of project execution and that acquired land be taken over by POWERGRID only after full compensation has been paid to PAPs. The Company also has a process to review outcome of SAMP and RAP implementation 18 – 24 months after completion of SAMP and RAP implementation.

To calculate tree and crop compensation values, POWERGRID conducts tree enumeration, including species and yield estimates as well as a detailed survey of existing crops, general crop patterns, seasonal variations and the nature and extent of yield/hectare. The Company however does not enumerate hybrid or short growth trees as the T-Line can be laid without having to cut such trees by use of normal tower extensions. The trees and/or crop likely to be damaged is identified and documented jointly with the land owner. The compensation amount for damage to crops or loss of trees during construction (and during maintenance) is determined by local revenue department in consultation with forest department for timber yielding and horticulture department for fruiting trees. The crop compensation value is arrived at based on the: (a) crop yield; and (b) recent market price of the produce in organized whole sale markets like Agricultural Produce Market Committee (APMC).

In case of loss sustained on account of felling of fruiting trees when land is acquired for SS, the Company, in consultation with the horticultural department, develops for each of the species encountered in the region, a compensation framework based on: (a) balance productive life of the tree (limited to a maximum of 8 years); (b) the expected fruit yield during the balance life; (c) price obtainable for the fruits based on recent prevailing prices in organized wholesale markets; (d) total obtainable timber from the tree over its productive life; (e) price obtainable for the timber; and (f) cost incurred by the tree owner, which is deducted from the compensation paid. In case of trees with only timber yield the farmer is allowed to take away the timber and compensation, as determined by the Forest Department based on girth and height of the tree, is also paid.

Biodiversity Conservation Procedures

POWERGRID endeavors to minimize adverse impacts on biodiversity and natural environment by: (a) economizing on the requirement for land for civil structures and reducing the width of the required RoW; (b) planning the T-line alignment to avoid protected areas including wildlife sanctuary, national parks, biosphere reserve and other sensitive areas such as ecologically sensitive areas (ESA), coastal regulation zone (CRZ) areas, no development zones, conservation reserves, community reserves, critical tiger habitats and critical wildlife habitats, elephant reserves, tiger reserves etc; (c) minimizing footprint and RoW in reserved forests and other deciduous scrub forests, gardens, nurseries, high tree areas, plantations; (d) avoiding or minimizing footprint in erosion prone areas, mountains and geologically sensitive areas; and (e) minimizing river, stream and canal crossings and footprint in wetlands.

Further, even at screening and scoping stage, desk reviews undertaken (forest atlas, Survey of India maps) specifically to identify potentially sensitive areas and subsequently field verification (including use of GPS & GIS tools) of all such areas identified is carried out. Effort is made to locate sub stations and T-lines on agricultural land and/or modified habitat. However, in some cases due to the location of generation projects/substations particularly in hydro projects, it becomes very difficult to totally avoid protected and other sensitive areas. In such cases, besides minimizing the length of T-Line through such areas, other special measures to minimize impact are implemented such as using extra tall (80 to 140 m tall) towers, using single pole towers and using multi-circuit T-lines. This is in addition to implementing any measures required as per the protected area management plan. Due to its efforts, POWERGRID has succeeded in reducing forest land as a percentage of total RoW from 6% to 1.1% between 1998 and 2010. Currently, forest land constitutes 3.12% of total RoW with the Company.

In cases where protected forest areas or areas with rich biodiversity or ecologically sensitive areas are affected, the Company and/or the Wildlife Warden of the area, prepare a detailed impact assessment and delineate mitigation measures including measures to avoid or mitigate habitat fragmentation, edge effect and intrusion of invasive species. Amongst other measures, POWERGRID requires: hand clearing; minimizing lopping, felling and opening up of canopy; transportation of tower material by head loads into forests; maintaining only a 3 m wide strip for O & M and permitting regeneration of vegetation in the two other strips; not creating any access roads or paths during construction but using only existing paths and field bunds for movement of material to the extent possible; manual stringing; avoiding bird nesting sites, flyways and significant bird habitat; provision of bird guards; providing funds (based on net present value of forest land diverted) for compensatory afforestation; use of leg extension and revetments that prevent soil erosion near the tower in erosion prone areas.

Sophisticated relays and breakers are provided in the substation, to break the circuit within milliseconds. To prevent fires in the forest areas fire lines are provided; planting of native fire resistant species or planting of native dwarf species, if considered appropriate, by the impact assessment are provided; felling, pollarding and pruning of trees is carried out for electrical clearance. The storage of hazardous materials and wastes within forest areas is avoided; and close supervision of construction activities is undertaken by Forest Officials.

Indigenous Peoples (IPs) Protection Procedures

The Company, as mentioned above, adheres to the general principle, though not limited to Indigenous Peoples (IPs) alone, of: avoiding socially sensitive areas of human habitations and cultural significance; and paying special attention to marginalized and vulnerable groups to secure their inclusion in overall public participation. Till date, POWERGRID has successfully demonstrated avoidance policy except at one location, and is committed to continue this avoidance policy, subject to technical feasibility. With respect to the rights and welfare of forest-dependent communities, POWERGRID does not acquire any land for the construction of T-Lines and does not acquire forest land for construction of sub-stations. In situations where avoidance is not possible, additional benefits are provided to IPs affected by the project. Further, the ESPP provides for preparation and disclosure of a Tribal Peoples Development Plan (TPDP). POWERGRID through implementation of the ESPP is committed to ensuring that: Indigenous (Tribal) people do not suffer adverse effects during the development process; they receive culturally compatible social and economic benefits; and that the Indigenous Peoples are consulted in a culturally appropriate manner, and that consultation is free from undue influence and results in broad community support.

POWERGRID as part of the initial scoping and preliminary assessments establishes/determines whether indigenous peoples will be affected by a proposed project. POWERGRID’s projects are not expected to result in physical displacement of IP communities. However, the Company has procedures to ensure that where adverse impacts are expected on IP communities, a detailed social assessment is undertaken.

A Tribal People Development Plan (TPDP) is prepared if significant adverse impacts are expected on IPs. POWERGRID will prepare a TPDP if: a) there are significant adverse impacts on customary rights of use and access to land and natural resources; b) negative impacts on the socio-economic and cultural identity of tribal communities; c) impacts on health, education, livelihood and social security status; and d) any other impacts that may alter or undermine indigenous knowledge and customary institutions. If impacts are not significant, specific additional actions supporting IP communities will be integrated into RAP instead. The Company is committed to: pursuing the land for land option as the preferred option for affected tribal families; and resettling them close to their natural habitat so that they can retain their ethnic, linguistic and cultural identify, in the event physical resettlement is required. While the ESPP procedures outlined above are generally equivalent to IFC Performance Standard on Indigenous Peoples (PS7), IFC’s definition of IPs under PS7 has a broader coverage than that of the ESPP. Further, although the World Bank has determined that this ESPP is equivalent to the Objectives and Operational Principles of OP 4.00 with regards to Indigenous Peoples, until such time as POWERGRID undertakes a project in a tribal area, requiring the preparation and implementation of a Tribal Peoples Development Plan, the World Bank will continue to rely on OP 4.10 for any World Bank-supported POWERGRID projects that affect Indigenous Peoples, While the equivalence of ESPP to PS7 can be fully established upon implementation of the ESPP in the event of impact on IPs, residual impact may be expected to remain limited in view of the Company’s commitment to: as far as practicable avoid impact on IPs including their land and resources; minimize land take and resource conversion; ensuring adherence to legal and regulatory requirements pertaining to scheduled tribes; and effectively implement ESPP’s provisions for IPs and Vulnerable groups.

The Company has procedures in place to ensure: that the TPDP is prepared in consultation with the IP communities (both affected and those living in the vicinity of the project area); and their active involvement in the planning, development, implementation and monitoring of all TPDP and community development plan (CDP) activities. The Company will require that professionals with adequate knowledge and experience of working among tribal groups/IPs lead the engagement and consultation with affected tribal communities. TPDP implementation will be internally monitored by the Company’s ESMC and ESMT, with the assistance of a person with tribal development experience, who will report on a quarterly basis to the Corporate ESMD.


Cultural Property Protection Procedures

There is inherent flexibility in POWERGRID’s projects in Transmission line routing and sub station site selection. POWERGRID has procedures in place that leverage this flexibility to avoid areas of cultural significance through route selection criteria that avoid: (i) the monument of cultural or historical importance; and (ii) all resources of archaeological, paleontological, historical, architectural, religious (including graveyards and burial sites), aesthetic, or other cultural significance within the purview of the its policies and procedures. During screening and scoping cultural and historical sites/areas are identified through documents and map reviews, consultations with Archeological Survey of India, consultation with neighboring communities, non government organizations and spot verifications. In situations where cultural heritage that are not covered under relevant laws, may be affected, POWERGRID will, where required, engage specialists ; and implement mitigation measures as recommended including measures to enhance the cultural property; and in any case has in place a chance find procedure.



PS2: Labor and Working Conditions

POWERGRID has about 9500 employees and in addition, a large number of contract workers (several thousands) are also engaged in its project sites. The Company has in place documented Human Resource Policies and Procedures for its employees comprised of: Service Rules (covering amongst other aspects working hours; leave; compensation; benefits and employee welfare; protection of company assets etc); Conduct, Discipline and Appeal Rules; Disciplinary Procedure; Employee Grievance Procedures; Recruitment Policy; and other rules relating to gratuity, pension, insurance, travel allowance etc. The HR Policies and Procedures are publicly available through the Company’s website and any changes and updates are notified through circulars on notice boards. Workers of the Company are covered by employee unions. The Company is committed to comply with the GoI requirements and laws on Equal Opportunity, Non Discrimination and Affirmative Action. Contractors are required by the Company to ensure adherence to applicable labor laws. The Company continues to strengthen its HR management practices and has put in place a Whistleblower Policy. POWERGRID will continue to review its HR policies and practices to identify opportunities for improvement relating to employee grievance redressal and contractor compliance assurance process.

POWERGRID manages occupational health and safety (OHS) in operations through a OHSAS 18001 certified occupational health and safety management system. POWERGRID has embedded occupational health and safety (OHS) in project design, and in operational and maintenance procedures, which includes a work permit, tag out/lock out and other operational control procedures consistent with Good International Industry Practices. The Company as part of its operational control procedures implements an Emergency Response Plan (EPR) carries out awareness training and also mock drills for emergency preparedness. The Company also provides detailed guidance as part of the IEAR, on safety procedures including a detailed safety checklist to be followed during construction. Safety requirements are embedded in construction contracts. Construction contracts detail penalties to be imposed on the contractor in the event of accidents as also breach of prescribed safety norms. The Company has a safety structure in which safety officers are in place in all the nine regions and at the corporate centre. Further, the Company requires deployment of qualified safety staff by construction contractors; and has a periodic safety audit program in place. Safety processes include daily safety drill led by Gang leader /supervisor before start of work, issue of Personal Protective Equipment to workers, testing of lifting tools and tackle, availability of first aid box and training to workers are part of “Safety Plan”. The Company in pursuit of continual improvement is in the process of further strengthening its OHS procedures including carrying out a diagnostic of its accidents and incidents, implementing recommendations based on diagnostic findings, and strengthening critical activity risk assessment and oversight procedures. Further, while POWERGRID has a program on employee OHS training including for contract workers, opportunities for further improving the training program will be availed including development and implementation of programs covering awareness, skills, knowledge, attitude, practice etc. to be imparted at suitable frequency either by the Company or by its contractors in a manner duly approved by POWERGRID. The Company has an incident reporting, investigation and corrective action procedures including for contract labor engaged on project sites.

POWERGRID has, over the years since the ESPP was first prepared, carried out extensive consultations on the ESPP at various stages of its development. Large scale consultation was undertaken as part of the major upgrade of ESPP in 2005 and 2009. The ESPP in its present form has been arrived after the above said consultations which included national consultation, four regional workshops and a national workshop involving in all about 450 individual participants including PAPs, community representatives, social organizations, government agencies, concerned citizens and international financial institutions. Notices were published in English and regional vernacular languages. Further, POWERGRID, as part of the ESPP development process, obtained inputs from an independent committee (IC) constituted by the Company consisting of eminent environmentalists, social scientists and representatives of multilateral funding agencies. The World Bank carried out stakeholder consultations to obtain feedback on the SDR. Final updated versions of both, the ESPP and the SDR, have been available for public review at POWERGRID website since April 2009.
Public consultation is an integral part of the planning and execution of a project at POWERGRID, with special emphasis to secure participation of marginalized and vulnerable groups. The Company is committed to ensure timely provision of information to affected communities and addressing community inputs, feedback, expectations, concerns and grievances. POWERGRID consultation and disclosure process includes various community engagement activities at different stages of the project cycle with due documentation of engagement events. The community engagement activities include: public Meetings at various locations along proposed Transmission Lines and in the vicinity of Sub Stations; informal small group meetings along proposed Transmission Line route; distribution/display of information brochures and pamphlets; setting up of public information office at operating field offices; interactions during local planning and site visits by POWERGRID staff; responding to public inquiries; press releases inviting comments; project coordination and grievance committees; PAP appointed or elected ombudsman or representative; and public disclosure of project related information. PAPs are consulted during monitoring by the Social and Environmental Officer at the SS site, by the District Administration, locally elected officials, NGOs and ultimately by the Grievance Redressal Committee .
In case of IPs, the TPDP will be prepared in consultation with the IP communities (both affected and those living in the vicinity of the project area). Consultations with IPs will meet the requirements of free, and prior informed consultation. The Company will implement procedures to: (i) establish and maintain an ongoing relationship with the Indigenous Peoples affected by a the Company’s project; (ii) foster good faith negotiation with and informed participation of Indigenous Peoples when projects are to be located on traditional or customary lands under use by the Indigenous Peoples; and (iii) respect and preserve the culture, knowledge and practices of Indigenous Peoples. The TPDP itself is required to include a strategy for participation of the IP communities including mechanism defined with the assistance, and in consultation with indigenous peoples, for their participation in the decision-making process throughout project planning, implementation, monitoring and the evaluation cycle. The Company will ensure that tribal institutions and organization in the affected area will also be involved in implementing the TPDP and resolving any disputes that may arise. Any community development plans to be implemented in the area by POWERGRID will be implemented with the active involvement of affected IP communities. The TPDP will be prepared and disclosed in the local language in a culturally appropriate manner to the affected IP communities before its implementation. The Company will obtain prior agreement of Indigenous Peoples in case any commercial development of their cultural resources or knowledge is proposed to be undertaken.
Disclosure channels include making available project information in public information office at site, use of local media (including at least one in the local language), through website, physical displays of POWERGRID’s facilities, information brochures and pamphlets, and through local site visits by staff for meetings. The Company posts the IEAR, SAMP & RAP on its website during the project development process, discloses these documents at the public information office at the project site offices and discloses these in the local language in cases where RAP is prepared. However, in all projects IEAR and SAMP provisions are explained to affected communities in the local language. Consultations are undertaken during ESA, social survey and after RAP preparation POWERGRID staff meet with affected people to inform them of the land acquisition details, proposed resettlement and rehabilitation measures, and compensation packages. RAP is discussed in open public meeting in the affected community. Consultation may be conducted in the form of a public meeting or by displaying information at designated places. Additionally, POWERGRID shares all social and environment information with the public or any interested persons whenever such information is sought.

To facilitate consensus building among PAPs, POWERGRID encourages PAPs to elect or appoint a trusted ombudsman or representative. Further, as part of the Company’s Social Entitlement Framework (SEF), a Grievance Redressal Committee (GRC) is established comprising representative from POWERGRID, representatives of local authorities, PAPs, Gram Panchayat or other well-reputed persons as agreed with the local authorities and PAPs. PAPs are informed about the existence of the GRC during the consultation process and are advised to approach the Chair or the Company’s project site office to seek grievance redress relating to land acquisition or R&R. The GRC is convened within 15 days of receipt of any grievance.

POWERGRID also has an active Corporate Social Responsibility (CSR) program in place under which it undertakes community development activities for communities’ resident in the vicinity of its facilities. The CSR activities include providing basic infrastructure, rain water harvesting, tree plantations, relief and restoration work during natural calamities, promoting social and cultural activities, providing education to poor children, organizing health awareness/check-up camps, sponsoring local fares/ festivities/ sports activities , etc

Specific project IEARs, SAMP, RAP and FEAR are made available to the affected communities at the respective project sites.

The Company has made available the ESPP and will disclose this ESRS document on its website.


Any enquiries and/or comments about the Project may be directed to:
Name: Ms. Seema Gupta
Designation: General Manager (Corporate Planning)
Address: ‘SAUDAMINI’, Plot No. 2, Sector-29. Gurgaon – 122 001 (Haryana)
Tel: 91 124 2571700-719 EPABX - 2709
Fax: 91 124 2571959
e-mail:mailto:sgupta@powergridindia.com. Website. http://www.powergridindia.com.