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. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the 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 proposed investment is a Category B project as per IFC’s Environmental and Social Sustainability Policy because it is expected to have limited adverse environmental and social impacts during construction and operation, with impacts primarily expected to be short term, restricted to the site and relatively minor. Predicted adverse impacts can be avoided or mitigated by adhering to recognized site selection and design criteria, guidelines and performance standards, as described in the following sections.

IFC’s project appraisal considered environmental and social management issues and plans for the Project, and gaps between these plans and IFC requirements. Corrective measures intended to close these gaps within a reasonable period of time are summarized below and in the agreed Environmental and Social Action Plan (ESAP) disclosed in this review summary. Through the implementation of these management plans the Project is expected to be designed and operated in accordance with Performance Standards objectives.
Key environmental and social issues applicable for this investment are: i) design and construction of the project in accordance with accepted building structural and electrical codes, most notably related to loading roofs, resistance to cyclone damage and electrical safety; ii) labor and working conditions for construction workers and operational staff, including occupational health and safety; iii) waste management.

The company does not own any premises at present, while all solar energy systems will be installed on client buildings or land. Clay Energy’s leased depot in Suva will be used by Sunergise (currently leased on a five year plus five year contract, which is now four years into the initial term) or alternatively Sunergise will purchase or develop its own depot. Village installations on community land will only occur with the village council agreement and PPAs with individual customers. Accordingly, no involuntary resettlement or economic displacement has occurred and PS5: Land Acquisition and Involuntary Resettlement does not apply.

Ground-mounted panels are usually sited on open, ideally flat land with grass cover (although individual trees may be removed to prevent shading of panels, therefore PS6: Biodiversity Conservation and Sustainable Management of Living Resources does not apply. Given that the use of premises or land for a solar energy system is only undertaken on a willing basis by the private owner/s or customary landowner/s, PS7: Indigenous Peoples does not apply. Similarly, as most ground sites have been previously disturbed PS8: Cultural Heritage does not apply.

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.

The Company does not have a corporate environment policy, primarily because it is in the start-up phase and has been sub-contracting all installation to contractors (to date).
Environmental and Social Assessment and Management System
Although Sunergise does not have an environmental and social management system (ESMS), its EPC contractor Clay Energy has established practices for worker safety and depot management, a number of which are outlined in its OHS Policy. Sunergise will develop an ESMS for its activities, aligned with IFC?s Performance Standards, incorporating: an Environment Policy and standard environmental management measures; OHS Policy and Procedures; Human Resources (HR) Policy; and Community Engagement Framework (CEF).

The ESAP details how gaps in performance and management necessary to achieve compliance with IFC Performance Standards will be filled. It includes environmental commitments and details of mitigation and monitoring plans, communication and documentation.
System Design and Building Approval

Sunergise? system development activities involve: (i) concept design ? a rapid assessment of power demands and potential system size and design; (ii) scheme design ? design of major system components; (iii) detailed design ? full design of the system; (iv) installation ? usually over a 4-8 week period; and (v) maintenance over the life of the PPA. Rooftop site assessment considers roof orientation, obstacles/shading, array capacity, and structural integrity of the building to support the panels (assessed by viewing the building structural certificate that is typically held by all house/building owners for insurance purposes). Ground-mounted panel sites are assessed in terms of?orientation, obstacles/shading, visibility (particularly at tourism facilities), ground cover (cleared land, grassland and shrubland are preferred in that order, with forest areas avoided), and distance to the connection point to?the grid or client.
Solar energy systems are compatible with building rooftop and ground mounting on residential, commercial, industrial and agricultural premises. Suva City Council and Nadi City Council require the developer to obtain a building permit for a solar power system to be installed in these respective areas, but Rural Land Authorities (rural councils) in Fiji do not. City Council engineers assess the structural integrity of the building to support a rooftop system by either inspecting the building or reviewing the current building certificate (required to obtain building insurance). No form of environmental assessment is required for solar energy systems in Fiji.

Organizational Capacity
Sunergise currently has a core management team of seven, including a CEO and CFO. The acquisition of Clay Energy will provide Sunergise with experienced and qualified in-house system engineering, design, installation and maintenance capability. Clay Energy has a total of 24 full-time employees, consisting of 6 engineering/sales staff, 12 technical/construction staff, and 6 administration staff, who are all on term contracts of one year (renewable).

Clay Energy contracts additional local technicians from EPC Ltd, a Fiji-based electrical contractor, when the workload requires additional installation staff. These contracted staff are trained by Clay Energy to undertake solar technician work, and supervised by Clay Energy?s site manager. When working outside Fiji, Clay Energy uses electricians from the country where the system is being installed, in compliance with national electrical standards. Clay Energy hires local labor for manual work activities (transporting gear and panels, digging holes, concreting ground mounts, etc) on most installations. An EHS Officer will be appointed by Sunergise as a part-time position to supervise the environmental, health and safety aspects of the business.

Training, Monitoring and Reporting

Staff training is conducted by Clay Energy to ensure that all employees have the appropriate skills and EHS knowledge to effectively and safely undertake the range of assigned activities. The Company will periodically conduct EHS training for all new and existing employees and contractors on aspects such as safety audits, job related risks, hazardous materials, fire prevention, and proper use and disposal of wastes. 
The Company will establish a monitoring program to assess the EHS performance of its operations including ambient noise, number of accidents/incidents, etc. The Company will submit annual environmental and social performance reports to regulators, lenders and investors.

Sunergise currently has six people working for the Company, while Clay Energy employs 24 full-time staff on annual contracts, whilst also hiring local labor for off-grid civil works based on verbal agreement. Clay Energy also hires registered electrical contractors on a job-by-job basis in other Pacific countries in order to comply with relevant national electrical standards. Sunergise and Clay Energy combined staff numbers are expected to rise to around 45 full-time staff by the end of 2016. All workers will be Pacific island nationals apart from some specialists, and all will reside off-site in the local communities except when they are installing or maintaining systems away from their home base.

Human Resources Policy and Management
Sunergise will prepare a formal Human Resources (HR) Policy and procedures that will apply to all employees and contractor staff. The HR Policy will be in accordance with Fijian labor regulations and IFC PS2, incorporating provisions covering contracts and terms of employment, wages and benefits, working hours and overtime, training, leave, employee welfare / adequate working and living conditions, non-discrimination and equal opportunity, a worker grievance mechanism, the right of association, no engagement in forced or child labor, and the application of labor practices to third party workers. The HR policy and procedures will be disclosed to staff (both employee and non-employee workers), with training provided to staff and third parties so that they are aware of the scope of these documents. Construction laborers will be paid a minimum wage in accordance with the national law applicable to the location of the installation. 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 maintain a database of worker grievances and outcomes.
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 25 jobs respectively during the operation phase. Workers will generally live in the community closest to each installation site.
Occupational Health and Safety (OHS)
Sunergise will establish an OHS management system based on (i) Clay Energy?s OHS Policy and established practices; (ii) compliance with Fijian and other Pacific country laws (as applicable to the country of installation); (iii) compliance with AS/NZS electrical codes; and (iv) compliance with PS2.

Construction hazards include working at height, heat and sunlight exposure (on hot roofs in direct sunlight), the use of cranes and electrical hazards. Environmental, health and safety (EHS) management during solar energy system installation will be the responsibility of the Clay Energy Site Supervisor. Sunergise will require contractor staff to adhere to its OHS policy and procedures and HR requirements. Contractors will be required to provide appropriate training and personal protective equipment (PPE) to their workers and ensure that this gear is properly used.

Key OHS components will include: more detailed OHS procedures; regular health and safety committee meetings; monthly auditing of OHS performance; regular training, including induction and on-the-job training (e.g., training recorded, competence assessments of all workers relative to the task to which they are assigned); stated requirements for the use of personal protective equipment (PPE); requirements for various types of equipment such cranes, other types of lifting equipment and scaffolding; electrical safety; and first aid.

Construction of a typical roof-mounted system (say 100 kWp capacity) takes about four weeks, whereas a similar sized ground-mounted system can take double this time. Installation works involve mounting and wiring panels and inverters, with mounts constructed to support ground-mounted panels.

Sunergise does not own any facilities such as offices or depots, but leases warehouse space for the temporary storage of solar equipment upon arrival in Fiji. Clay Energy leases a depot in Suva that houses its offices, a workshop for assembly, maintenance and repairs, and warehouse and yard storage for a limited amount of inventory (electrical gear, solar panels, inverters, batteries, etc). This 1,200 m2 facility will continue to be leased or a depot will be purchased.

Energy Efficiency
Sunergise? solar energy system design is based on current best practice using crystalline panels that convert sunlight to DC energy at a high energy conversion efficiency rate. Photovoltaic crystalline modules are primarily sourced from Trina Solar, the second largest manufacturer of solar panels in the world. Solar panels repay the energy used in their manufacture in less than one year of operation in Fiji (source: Trina Solar).

The principal environmental benefit of installing solar energy systems is a reduction in greenhouse gases (GHG) produced by replacing grid-generated power from fossil fuel combustion with renewable energy. For each 1 MWp of installed solar power it is estimated that around 900 tCO2eq/annum of GHGs will be avoided based on peak daytime loads currently being met by diesel generation of grid electricity in Fiji and 1,600 MWhr/annum of electricity generated per installed MWp. Accordingly, the project will reduce the generation of GHGs by an estimated 2,745 tCO2eq/annum with the targeted installation of 3.05 MWp by the end of 2014.

The depot is supplied with electricity from the FEA grid, which is used for lighting, office air conditioning, workshop power, computers and other office equipment. Energy saving measures in the depot and offices include compact fluorescent lighting and 1kW of rooftop solar panels that offset around 4 kWh/day electricity consumption. Another small-scale energy use is fuel used in Company vehicles.
Water and Wastewater
Annual water consumption in Clay Energy?s Suva depot is minor at around 120,000 L per annum, sourced from the city supply operated by the Water Authority of Fiji. Water use at the depot consists of human consumption, hygiene uses such as hand washing and showering, in toilets, for depot cleaning as well as being plumbed to fire reels. Sewage from the depot is treated in the town system operated by the Council.

Water requirements during construction are minor, consisting of water for cement mixing for ground mounts, washing equipment and drinking water. Water may be used to wash some panels of accumulated dirt at some installations once a year with a pressurized hose using water from municipal supplies. As most panels are mounted at the roof grade of greater than 10% the panels are self-cleaning from rainfall. Depot stormwater is discharged into the watercourse at the rear of the premises, but there is no spill containment device fitted to the system.
Waste and Hazardous Materials
The installation and maintenance of solar energy systems generate small volumes of generally non-hazardous waste. These impacts have the potential to affect local residents and businesses, but can be adequately managed through the effective implementation of standard mitigation measures.

The primary solid waste streams from Company activities are: (i) office waste ? paper, plastic, glass, e-waste, etc; (ii) packaging from new panels, inverters and other components; (iii) wiring off-cuts; (iv) used either sealed or flooded lead-acid batteries collected from off-grid installations; and (v) non-repairable electrical components. Off-grid batteries provide a slow discharge from thick plates, with battery life generally ranging between 3-12 years. Flooded lead-acid batteries have the potential to leak, whereas sealed batteries are less likely to and therefore preferred. Waste will be managed in accordance with a waste management procedure that will be developed by Sunergise, setting out waste handling, reuse, recycling and disposal. All waste is segregated on site and removed from site to be stored in designated waste bins at the depot. Recyclable materials are either given or sold to local recyclers, while non-reusable materials are disposed of in Council-operated landfills (e.g. Suva City) via waste contractor skip bins that are hired to transport these materials as required. Sunergise will manage the disposal of PV modules.

Hazardous materials stored in the depot include cleaning agents, diesel in jerry cans and 205 L drums, oils/lubricants, and new and used lead-acid batteries. Spills are cleaned up by hand.

Other Issues
The potential visual or aesthetic impact of solar panels can be an important consideration of customers, whether they are sited on roofs or on the ground, particularly for businesses such as resorts that rely upon tourism. Panel sites are negotiated with each customer to minimize the visual impact where possible whilst ensure that solar exposure is not unduly reduced. The reflection of sunlight off solar panels is minimized by a rough texture finish on the surface of the panels. This is important on most sites, but even more so near airports.

Construction noise is relatively minor with little chance of disturbing nearby local residences and businesses as it is restricted to small hand tools and cranes to lift panels onto multi-storey buildings. This potential impact will be managed by restricting site working hours to between 8 am and 6 pm six days a week and ensuring that cranes and tools are operated and maintained in accordance with manufacturer?s requirements.
The erosion and sedimentation hazard created during the construction of ground mounts is minor due to limited area of ground disturbance per post on generally flat sites, while a minor volume of spoil is generated from each footing.

The Project will involve the construction of facilities primarily on existing roofs of single or multi-storey buildings, with a small percentage located on ground-mounted stands. Sites will range from urban, commercial and industrial areas to resorts and rural locations. The primary risk to community health and safety relates to electrical safety during system operation. DC voltage from solar panels can arc over a longer distance than AC voltage, with a greater potential to electrocute or start a fire.

Life and Fire Safety
Solar panel and inverter design, as well as Clay Energy?s solar power system installation designs meet relevant Australian and New Zealand structural, electrical and fire safety standards. These standards include AS/NZS 3000:2007 ? Wiring Rules, 4777:2005 ? Grid Connection of Electricity Systems, and 5033: 2012 - Installation and Safety Requirements for Photovoltaic Arrays. Electrical systems are fully insulated and earthed, with safety features including fuses, connecting wires run through insulting conduits, and locked cages around inverters and combiner boxes that may be accessible by the public. All installations carry appropriate signage according to AS/NZS 5033 (hazardous voltage, current signs for fire safety, etc). Fuse protection and other design features ensure that standard and adequate fire protection is achieved. Clients are given system manuals that include information on system safety hazards, particularly for off-grid systems with batteries.

The solar panel roof mounting / fastening system is designed to withstand cyclonic storms, with solar panels rated for region D (cyclone rating), capable of withstanding winds of up to 80 m per second. In December 2012 cyclone Evan hit Fiji and destroyed the Port Denarau Marina moorings, but only one recently-fitted solar panel out of 200 was blown off the roof. Sunergise has insurance coverage that includes workers compensation and general liability that covers fire and cyclone damage. The Company checks the client?s insurances and declares these to its own insurers.

Fire safety at the existing depot is in accordance with National Fire Authority requirements, with an annual certificate required from a site inspection to satisfy these?requirements. The depot is equipped with smoke alarms, portable fire extinguishers and fire reel.

Clay Energy maintains engineering quality by having its engineers complete an online training course in grid connection of solar PV provided by the Global Sustainable Energy Solutions training center in Australia. System installation is managed by a team of qualified and experienced technicians. Electrical components and connections are installed as per the applicable AS/NZS electrical standards. Ongoing in-house technician training is provided on specific equipment requirements and installation best practice.

Site Security
Clay Energy?s depot is security fenced and has a closed circuit TV (CCTV) surveillance system, security alarms and lockable areas for valuable components within the warehouse, but no guards are used. Sunergise will be required to ensure that any security arrangements meet the requirements of PS4. Sunergise will develop an emergency response plan and evacuation procedure for its offices and depot/s that will be implemented during operation.

Consultation occurs with potential clients who are considering entering into a PPA with Sunergise. The structural and electrical features of solar energy systems are explained to the potential clients, and agreement is reached on the timing of installation once a PPA has been entered into. Prior to commencing work at each site Sunergise posts signage around the site to inform people of upcoming work and to provide the contact details of the site manager in the event of an issue rising or a desire to make a comment. Stakeholder engagement at potential community sites is based on standard local practices during the negotiation of the PPA and installation and maintenance of the system. Whenever site access is required an introduction is made to the village Chief and landowners requesting access, a gift is offered and a blessing is asked for. Sunergise lists contact details on its website, while no complaints have been received about installation activities.

Direct consultation with neighbors is generally not required beyond the above activities as individual solar energy systems as usually very low impact facilities with little effect on neighbors. Discussions are held with urban Councils (as applicable) during the design process. The company will develop a simple stakeholder engagement procedure that identifies potentially affected stakeholders at each site and describes the consultation process relating to system design and installation. The procedure will include a simple grievance redress mechanism to receive and respond to any concerns that people living in the vicinity of installations may have.

Local Initiatives

Sunergise plans to commence a program to help provide solar energy systems to schools in the two years as a community development initiative.

The ESRS and attached ESAP will be made available via the World Bank Group’s InfoShop. In addition, an advertisement will be lodged in a local newspaper informing the public that the ESRS and ESAP are available for review. 
In Fiji the ESRS can be reviewed at Sunergise’ offices at the following address:
Sunergise
Damji and Sons Building
Main Street
Nadi, Fiji
Any queries and/or comments about the Project may be directed to:Paul Makumbe
CEO
Sunergise International Limited
Phone: +679 860 4850
Email: mailto:paul.m@sunergisegroup.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Develop a Company Environmental and Social Management System (ESMS) that incorporates an overarching policy and procedures to manage EHSS risks and impacts, an emergency preparedness and response plan, and a stakeholder engagement procedure (including a grievance mechanism).	05/30/2014
Prepare a procedure for site selection impact avoidance, including avoidance of natural habitat (for ground-mounted systems), cultural heritage sites and historic buildings, including visual amenity considerations.	04/30/2014
Appoint a suitable staff member as the Environmental, Health and Safety (EHS) Manager, a part-time position.	05/30/2014
Develop an EHSS site screening procedure for the selection of premises or land to acquire in the event that Sunergise decides to acquire its own premises.	07/31/2014
Prepare a Human Resources (HR) policy and procedures appropriate to the Company size and workforce, in accordance with national laws and IFC Performance Standard 2.	09/30/2014
Prepare an Occupational Health and Safety (OHS) plan in accordance with good industry practice and WBG Environmental, Health and Safety Guidelines, covering measures/procedures appropriate to the main work hazards (e.g. working at height, heat/sun exposure, and electrical safety) incorporating an Emergency Preparedness and Response Plan.	09/30/2014
a) Review each installation Contractor's HR documentation and approach, confirming compliance with Performance Standard 2, and b) report this to IFC on a regular basis.	07/31/2014
Develop a Waste Management Procedure to ensure the proper segregation, storage, recycling, reuse and disposal of waste.	07/30/2014
Formalize the consultation process with prospective clients (businesses and communities) in a simple Company procedure. This may include the production of printed matter to explain solar energy systems and associated maintenance and safety hazards.	06/30/2014
Confirm that the codes applied to solar energy system design are aligned with good international industry practice.	04/30/2014