While all Performance Standards are applicable to this investment, IFCs 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.

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
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources

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 wind farm is located on government land which is not of economic value. Baisara village is ~ 2 km from the nearest WTG location and Rajgarh village is ~ 0.50 km from the nearest WTG location of the Project. The WTGs are not less than 0.5km from informal settlements. Only small areas are required for each turbine and there will be no involuntary resettlement or economic displacement. The land required for the turbines has been leased from the government by IRL and will be sub-leased to the Company for approximately 20 years. PS5: Land Acquisition and Involuntary Resettlement is therefore not expected to be triggered by the project.

PS 7: Indigenous Peoples - Lands and resources on which Indigenous Peoples are dependent (PS7) are not expected to be impacted by the Project.

PS 8: Cultural Heritage - Cultural heritage (PS8) is not expected to be impacted by the Project.

The Project has been categorized as Category B according to IFC’s Environmental and Social Review Procedure. Accordingly, IFC’s proposed investment is such that adverse environment and social (E&S) risks and impacts are limited, site specific and may be readily mitigated by adhering to generally recognized performance standards, guidelines or design criteria. The Company will manage its environmental and social performance in accordance with applicable local laws and regulations and international standards, including IFC PS.

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 Assessment and Management System:

BEL has a corporate Social, Environment Health and Safety Management System (SEHSMS), dated May 2010 that is consistent with Indian regulatory requirements, IFC Performance Standards, World Bank Group (WBG) EHS General Guidelines, ISO 14001 and OHSAS 18001. It sets out the procedures for BEL to assess and manage social, environmental, health and safety issues at each phase of their activities. The SEHSMS specifically relates to BEL’s hydropower activities and will be upgraded to reflect the requirements for wind power projects. In the case of this project, LNJ Power Ventures Ltd will ensure that its contractor has procedures in place that are compliant with its corporate ESMS and will ensure that the contractor adheres to the IFC Performance Standards through construction and operation.



IRL’s ESMS is materially compliant with the IFC Performance Standards, WBG General and sectoral EHS guidelines and adequately addresses the Environmental Management Plan outlined in the ESIA. The system sets out the purpose, scope, management responsibility, performance criteria and management activities for: legal and other requirements; hazards and risks; the management program; training; communication; documentation; emergency preparedness and response; monitoring; and reporting. IRL shares its environmental and social systems and policies with its sister company IWL.



Identification of Risks and Impacts:

Although the Government of India does not require environmental impact assessment for wind farms, IRL commissioned an ESIA for the 300MW Dangri wind farm in 2012 (of which this project is a component). That ESIA appropriately assessed potential impacts and identified appropriate avoidance and mitigation measures consistent with IFC Performance Standard requirements. A rapid biological assessment identified that the impact on birds and bats are low risk.



Management Programs:

As part of the ESIA, an ESMP was prepared to promote good engineering practices during both construction and operation phases of the project. It sets forth: (i) measures to mitigate adverse impacts that result in outcomes consistent with IFC PSs; (ii) monitoring requirements for ensuring the mitigation measures are implemented effectively and in a timely manner; (iii) organizational resources for carrying out the measures; (iv) an implementation schedule for these activities; and (v) an appropriate monitoring and reporting framework to ensure that the plans are implemented. It includes actions to manage air quality, noise, land and water environment, visual impacts, waste management, occupational health and safety, protect security and safety of the local community as well as a monitoring program for bird and bat mortality; and air noise, water and soil quality monitoring. IRL has provided evidence of the implementation of the ESMP, including programs to manage noise, dust and gaseous emissions, waste management, traffi
c safety, occupational health and safety and community health and safety. These programs are implemented through a hierarchy of health, safety, environment and social impact management procedures that will be applied throughout construction and operation.



Organizational Capacity and Competency:

The Company will appoint an owner’s EHS staff who will be responsible for supervising and monitoring EHS management by the contractor. This staff will also undertake consultation with local community stakeholders and implement the local community grievance redressal mechanism and will report to the BEL EHS Department Head. The BEL HSE management plan includes a training protocol that provides standard training modules as well as needs-based programs.



IRL has appointed an appropriately qualified site safety, health and environment committee consisting of five staff who will be responsible for EHS management throughout construction and operation of the wind farm. IRL has also appointed a Liaison Team which will ensure appropriate stakeholder engagement is undertaken during construction and operation of the wind farms.



Monitoring and Review:

The Company EHS staff will be responsible for monitoring environment, occupational health and safety and social performance throughout construction and operation of the wind farm. Periodic reporting will be made to the Corporate HSE Department. IRL will report to the Company on a monthly basis regarding on site EHS activities and will submit environmental accounting reports every six months.



The IRL Site-In-Charge is responsible for creating an HSE monitoring plan which is implemented through formal audits and regular inspections. Risk-assessment and incident reporting is undertaken on an ongoing basis and any non-compliance is reported to the HSE Head and immediate corrective action and preventive steps taken.

The Company will employ up to 3 people who will supervise the contractor during construction and operation of the wind farm. The Company staff will be employed under the same working conditions as those staff employed by BEL, which are compliant with Indian Labor and Factory Laws and IFC Performance Standards. The Company will not employ child or forced labor, will require their contractors to ensure that child and forced labor is not permitted and has procedures for monitoring and reporting on practices on site.



IRL has around 70 staff. The IRL Human Resources (HR) Policy Manual incorporates policies on working hours, wages, overtime, compensation and benefits, non-discrimination and equal opportunity, contract labor, security, disciplinary procedures, code of conduct, leave, transfer and relocation, training, travel and employee welfare, a policy enabling collective bargaining, and a grievance mechanism for workers, in line with PS2. IRL does not employ child or forced labor and site entry/exit procedures prohibit entry of contractors’ staff under 18 or over 58 on to the site. All contract staff are required to be registered by the contractor and must produce photographic identification upon entry.



Occupational Health and Safety (OHS):

BEL is committed to providing a safe and healthy work place for all personnel. The Company will contractually require IRL to comply with its “EHS Requirements for BEL (Guidelines to Contractors)”. This document details the process by which the contractor shall manage HSE while carrying out the works under contract. The contractor will be required to undertake works in accordance with IFC Performance Standards. The contractor is required to undertake training of all personnel on site, perform job hazard analysis, provide appropriate personal protective equipment (PPE), convene daily tool box meetings, prepare a fire plan and emergency response plan and report and investigate any incident, near miss or hazard occurring at site. The Contractor’s EHS plan will be submitted to the Company for approval prior to commencement of work. The Company site representatives will monitor site work and ensure that work is performed in accordance with the EHS plan and will perform formal and informal EHS inspections on a routine basis. The contractor will also formally report monthly on compliance issues, including EHS incidents or accidents.



The IRL HSE policies and procedures encompass safe work practices and procedures, training, toolbox talks, work permit system, incident reporting, recording and investigation, site rules and regulations and HSE rules, crane safety, working at heights and vehicle safety, enforcing the use of personal protective equipment, the observation of traffic safety protocols, training and awareness for employees, emergency response plan implementation, making available ambulance and first aid facilities and ensuring access to doctors or other medical. IRL requires contractors to implements
its HSE obligations and includes such obligations in the contract documents. To date, there have been no reported incidents during construction at IRL’s Dangri site.



IRL has detailed policies and procedures for worker’s accommodation and avoidance of child labor, and worker’s conditions and terms of employment.

During construction and maintenance a number of PS3 impacts will require management. Dust emissions during construction activities and movement of vehicles on unpaved roads will be managed primarily by limiting the speed of vehicles, taking measures to minimize windblown dust from stock piles of excavated materials and monitoring dust emissions during high wind periods. Given the arid environment of the wind farm, every precaution to minimize dust emissions will be taken through good management procedures and water spray dampening will be used where all other measures have been exhausted.



Waste water will be discharged into a septic tank and there will be no discharges to the ground water. In order to minimize erosion, surplus excavated earth will be used for access road construction.



Hazardous materials such as oil and paint, lubricating and hydraulic fluids will be stored on site and a limited amount of hazardous waste will be generated. Hazardous materials and wastes will be stored and disposed of in line with international best practice and national regulatory requirements. General waste such as unused metals, packaging, plastic, paper and food waste will be recycled and reused as far as possible. Once the project is operational there will be limited pollution risk from the project due to closed systems used within the turbines and limited site activities; periodic oil and fluid changes of geared equipment will be conducted and waste oils/fluids will be disposed of at designated sites.

Community Health and Safety:



The main risk to communities relates to the transport of heavy equipment and parts on local roads. The speed limit of vehicles will be limited, trucks transporting heavy equipment will be mobilized at night, and drivers will have a valid driving license and appropriate training. The ESHS staff on site will be responsible for notifying the communities and verifying that contractors enforce mitigation measures.



With regard to noise impacts, the closest receptors are located not less than 500m from the nearest turbine. Predicted incremental increase in noise levels is not expected to exceed 3dB(A) during the operational phase and will comply with IFC guidelines. During construction, noise levels at these settlements may rise to 60dB during daytime for short periods of excavation.



In terms of visual impacts, the site is an open, flat, degraded desert landscape. The turbines are of uniform color and have non-reflective paints that blend with the natural landscape. While the site will add a number of structures to the landscape, the scale and distance from populated areas is unlikely to impact sensitive receptors.



Security Personnel:

IRL will be responsible for security at the site and has a detailed guideline which outlines the criteria for selection of security agencies, including the need for police verification for each security personnel deployed at the site, training in fire fighting, emergency evacuation and first aid. It stipulates the requirement for training in the use of force and firearms and appropriate conduct toward workers and affected communities including a procedure that 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 project area is a dry and semi-arid landscape and vegetation is degraded. The majority of the faunal species found during the ESIA ecological survey were common throughout the State of Rajasthan, there were no endemic or threatened species present in and around the project area. There was no presence of endangered species such as the Great Indian Bustard, and the nearest protected area is the Desert National Park, 60km away. Roosting colonies of bats are located 50km from the site; there are no wetlands in or around the site and migratory routes are broad and not restricted over the project site. Consequently, the impact on avifauna was predicted to be low.



As standard practice, the operational phase management program will include bird strike monitoring, surveying for carcasses and prompt removal to avoid attracting raptors. Where necessary, bird surveys will be undertaken in peak seasons to determine the need for additional mitigation measures.

The IRL Liaison team consulted local village representatives prior to land allocation by the government agency. Public consultation meetings were arranged with village representatives on a mutually agreed date and place to explain the nature of the project, seek the views of the stakeholders, and identify opportunities for employment or local contracting. In February 2012, as part of the ESIA for the 300MW wind farm consultants met with local village representatives, who indicated their expectations of beneficial impacts such as employment, improved access roads and consistent power supply. A few consultees expressed concern that the noise from the turbines would scare their cattle but were satisfied that this had not been an impact elsewhere.

Going forward, both the Company and IRL will undertake further stakeholder engagement. At the neighboring villages, the Company will discuss the Project activities and its potential impacts on them and distribute additional copies of the ESIA summary in local language. In addition, the Company will establish a Grievance Mechanism, which will monitor and report on any issues throughout the construction and operational phases, in line with BELs policies. This stakeholder engagement will ensure that the communities, including any informal settlers, are adequately consulted, their concerns or interests taken into account and appropriate necessary mitigation agreed and implemented. The Company also intends to carryout CSR activities in the Project area and will consult and discuss with the village Panchayat about the issues related to the local area development and approach to facilitate sustainable development of the Project area.

Throughout the construction process an IRL Liaison Team, which consists of staff employed from the local community, will engage with the local communities and resolve grievances through discussions with village elders. IRL has a guideline on complaint resolution procedures that indicates mechanisms for public consultation, the process of liaising with local communities during construction and operation, including how specific complaints related to noise, shadow flicker and electromagnetic interference will be addressed and a complaint resolution process. To date there have been no grievances presented by local stakeholders at IRL’s Dangri site.

The Company will disclose this ESRS locally at Villages Rajgarh and Bhaisara; Tehsil Pokran in Jaisalmer, Rajasthan.

Broad Community Support is not applicable for this project

Current client performance is aligned with applicable Performance Standards and EHS Guideline requirements. No ESAP is required.