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

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

The project land is being secured through Governmental concessions (mainly the Concesión de Uso Oneroso – CUO) which are anticipated to be fully granted by the end of May 2013. The Company will provide evidence of the land use authorization to IFC as indicated in the ESAP. Since there is no associate involuntary displacement or land acquisition, PS 5 – Land Acquisition and Involuntary Resettlement is not applicable.

PS 6 - Biodiversity Conservation and Sustainable Natural Resource Management is not applicable since the project is not located in sensitive modified or critical habitats and will not affect ecosystem services.

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

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

Located on an arid, deserted, undeveloped land devoid of human settlements, the proposed investment is a Category B project because the potentially limited environmental and social impacts that may result from constructing and operating the solar power generation and transmission facilities can be avoided or mitigated by adhering to generally recognized good practices and design criteria. The Company has presented information and plans that will seek to address environmental and social risks and impacts in accordance with the Chilean laws and regulations, the IFC Performance Standards on Social and Environment Sustainability, the applicable elements of the World Bank Group (WBG) General EHS Guidelines, and the attached Environmental and Social Action Plan (ESAP.)

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

Environmental and Social (E&S) Assessment

For purposes of assessing the impacts of the project, as established in the Company’s corporate EHS management system, the Company engaged a leading environmental consultant firm to conduct an Environmental Impact Assessment (EIA) under the methodology of a “Declaración de Impacto Ambiental” (DIA), as required by the Chilean environmental authorities, and a community engagement process. As the installation of the transmission line is an integral part of the project Environmental Impact Declaration (DIA) presented to the authorities for approval, a single permit will be granted for both the plant and the transmission line.



The Company is currently finalizing the selection route for the project transmission line. Details of the route as well as impacts and mitigations will provided to IFC as indicated in the ESAP. Once decided will apply to the Chilean government authorities for the authorization for right-of- way use and once obtained, it will submit copy to IFC as indicated in the ESAP.



The general landscape can be characterized by flat surface covered by scarce vegetation of which there are four native species and twelve endemic species. None of those are in either vulnerable or endangered condition. However since they are unique of this ecosystem, the Company is committed to preserve those. There are two creeks that traverse the site and in its vicinity there are found a reptile and a mammal species, both in endangered stage.



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

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



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



The Company has dedicated qualified personnel to mana
ge the EHS impacts of its operations. SunEdison has a Global ESH Lead at corporate level that will be supported by a local ESH responsible for the project operations. To follow-up the day to day operations the Company will be supported by a qualified EHS environmental firm. Engagement with communities, as well as the community outreach initiatives to be implemented in the vicinity of its operations, will be handled by a designated qualified person who will be supported by a local social NGO. In addition, as needed, the company will also retain environmental consultants, to conduct studies, monitoring, audits, etc.



Training, monitoring, and reporting

SunEdison will periodically conduct EHS training for all its own employees and contractors on aspects such as safety audits, job related risks, hazardous materials, fire prevention, proper use and disposal of residues and products, etc. SunEdison will develop dedicated training programs for all new employees as well as in-house and off-site training for first responders. The company will establish a monitoring program to assess the EHS performance of its operations including ambient noise, ambient air, water quality, number of accidents/incidents, etc. The Company will submit annual environmental and social performance reports to regulators, lenders and investors.

Human Resources Policy and Management

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



The Company will establish a worker’s grievance mechanism defining the channels available to submit the grievances (i.e., mail, phone, verbal report to immediate supervisor/reporting authority; etc.) and will maintain a database with information regarding grievances outcomes.

It is expected that the proposed project will generate approximately 250 jobs during the construction peak. The majority of non-skilled workers are anticipated to be locally hired from the surrounding villages. The project will generate approximately on average and peak a workforce of 10 and 20 jobs respectively during the operation phase. It is anticipated that the workers will live in the community closest the project site and that the Company will be responsible for their transportation. As indicated in the ESAP, the Company will provide details of the housing arrangements which are anticipated to comply with IFC PS2.



Occupational Health and Safety (H&S)

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

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



The water requirements for construction, cleaning of the solar panels and for domestic use will be provided by tankers from a nearby local supplier. Bottled water will be used for human consumption for both construction and operation phases and it will be supplied by licensed authorized local providers. The project will not alter the drainage patterns of the area by elevating the land or blocking or altering natural drainage channels. The construction materials will be obtained from approved quarries.



The construction phase will generate only domestic sewage. The operation phase will generate domestic waters and discarded panel washing water. The domestic wastewaters to be generated will be collected and treated in septic tanks. The sludge produced will be removed by an authorized specialized company and the treated wastewater will be used for irrigation within the project site. The project will use pressurized water for panel cleaning and the minimal amounts of wastewater resulting from the cleanup will fall on the ground beneath the PV Modules and will not need to be treated since it just contains the material removed from the panels. 

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



The project will make a direct contribution towards increasing the use of renewable energy thus reducing generation of CO2 and other greenhouse emissions. The project will reduce the generation of approximately 123,500 tonnes of CO2 per year.



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



The solid waste to be generated during construction includes domestic, recyclable, and construction waste. Domestic and construction waste will be transported to a municipal landfill, the recyclable waste (i.e., paper, plastic, glass, scrap metal, etc.) will be properly segregated, stored in designated waste bins/containers, and sold to local recyclers. No toxic and/or hazardous materials will be us
ed in the construction other than diesel oils for vehicles, which will be properly handled. The contractors will be contractually required to undertake effective measures for proper waste management. SunEdison will directly manage the final disposal of discarded PV cells with the support of MEMC as the producer of those. As needed, it will obtain all required authorizations for its handling and transportation. The Company will not use PCB transformers, ozone depleting substances, or banned/phased out substances.



The company will develop a biodiversity management plan to address the mitigations on the flora as well as fauna species found on the site. Once it has decided the route for the transmission line, the Company will assess potential impacts and as appropriate establish biodiversity management measures to ensure that any potential impact to vegetation will be properly handled.



The Company has established measures to prevent spills or soil contamination during either construction or operation phases. It is requiring the EPC contractor to establish rigorous measures to handled vehicle and machinery maintenance, collection, storage, disposal of hazardous wastes, etc.

The project will have minor impacts to the communities. Any potential induced influx to nearby areas resulting from the construction phase will be due to the expectation of new employment opportunities. However, it is anticipated this impact will be temporal given the short duration of the construction phase which will take approximately6 months. In addition, the contractor will provide transportation for its workers who will be living in nearby communities. Traffic volumes to transport workers, equipment and materials to the construction site are not estimated to the considerable and the Company along with the contractor will establish the optimum transportation routes, the traffic management measures, and appropriate site access provisions that will reduce impacts.



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

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

Community engagement is a key pillar of SunEdison’s Corporate ESHS Policy. The Company has made all relevant information on the project publicly available through the publication on the internet of the Environmental Impact Assessment / DIA and has held several meetings over the last months with local authorities where the project has been presented, receiving generally positive feedback. The Company is also collaborating with local non-governmental organizations, including local NGOs with which it intends to sponsor social projects that would improve the infrastructures and services available to the local community.

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

Community relations staff will meet periodically with nearby community members and municipal authorities. As part of the project, The Company will prepare a Community Engagement Framework (CEF) establishing the approach to implement the mitigation actions for impacts to communities as well as the outreach community programs to also be established.

Client’s contacts:
Name: Julio Fournier
Title: Business Development Manager LATAM
Project Name: San Andrés SpA
Address: Av. Vitacura 2939, 27th floor. Las Condes, 7550098, Santiago, Chile
Phone: + (56) 9 563 94451

Name: Maria José Torijano
ESH Manager EMEA & LATAM
Project Name: San Andrés SpA
Address: Alcalá 44, 3rd floor. 28014, Madrid, Spain
Phone: + (34) 608 943 067

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
Submit copy of the transmission line impact assessment and mitigations	06/28/2013 12:00:00 AM	Completed	Completed	06/28/2013 12:00:00 AM
Submit copy of the government authorization for the project land use	06/28/2013 12:00:00 AM	Completed	Completed	06/28/2013 12:00:00 AM
Submit copy of the authorization/agreement for the right of way of the transmission line	06/28/2013 12:00:00 AM	Completed	Completed	08/15/2013 12:00:00 AM
Submit copy of the construction/operation workers accommodation	06/28/2013 12:00:00 AM	Completed	Completed	08/15/2013 12:00:00 AM
Submit copy of the Contractors Monitoring Procedure	06/28/2013 12:00:00 AM	Completed	Completed	08/15/2013 12:00:00 AM
Submit copy of the Community Engagement Framework	06/28/2013 12:00:00 AM	Completed	Completed	09/25/2013 12:00:00 AM
Submit copy of the community grievance program	06/28/2013 12:00:00 AM	Completed	Completed	09/25/2013 12:00:00 AM
Submit copy of permit(s) issued by the Chilean environmental authorities for project operation phase	01/30/2014 12:00:00 AM	In Progress	Under discussion with IFC client