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 IFC's 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
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 8 – Cultural Heritage

The proposed project will be located in an area devoid of human settlements. The route of the transmission line is not occupied; however, it is anticipated that the use of the ROW will be compensated through a commercial (willing-buyer, willing seller) transaction. Thus, PS 5 – Land Acquisition and Involuntary Resettlement is not considered applicable. Since there are no communities in the project’s area of influence that would be considered as ‘Indigenous’ as defined by the World Bank Group, PS 7 - Indigenous People is not considered applicable.

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 Environmental, Health, and Safety (EHS) Guidelines; the Electric Power, Transmission, and Distribution EHS Guidelines; and the attached Environmental and Social Action Plan (ESAP). Gaps between the company’s management measures and IFC requirements, together with corrective measures intended to close these gaps within a reasonable period of time are summarized in the paragraphs that follow and in the agreed Environmental and Social Action Plan (ESAP) disclosed in this review summary. Through implementation of these management plans and the ESAP the project is expected to be designed and operated in accordance with Performance Standards objectives.
The proposed project will be located in an area devoid of human settlements. The route of the transmission line is not occupied; however, it is anticipated that the use of the ROW will be compensated through a commercial (willing-buyer, willing seller) transaction. Thus, PS 5 – Land Acquisition and Involuntary Resettlement is not considered applicable. Since there are no communities in the project’s area of influence that would be considered as ‘Indigenous’ as defined by the World Bank Group, PS 7 - Indigenous People is not considered applicable. Archaeological and historic sites were found within the project site’s boundaries, in addition to few secondary findings along the transmission line, for which effective mitigations measures will be implemented, thus PS8 - Cultural Heritage will 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.

Environmental and Social (E&S) Assessment

For purposes of assessing the impacts of the project, First Solar engaged a Chilean Environmental consultant firm to conduct an assessment of the environmental and social impacts of the project, which was completed in July 2013. The project is in the process of obtaining the necessary Chilean environmental permits.



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

The company is committed to adopting and implementing an Environmental, Social, Health, and Safety Management System (ESHSMS) for the project based on the Chilean regulations; IFC’s Performance Standards; and the relevant WBG Environmental, Health and Safety Guidelines. The ESHSMS is being designed in line with internationally recognized ESHSMS standards (i.e. ISO 14000 and OHSAS 18000) and includes (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 Community Outreach Programs.



To ensure sound EHS contractors performance, the company 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 EHS supervisors for their operations and the company will conduct periodic EHS performance evaluations to the contractors to assess their EHS performance.



The company will have dedicated qualified personnel to handle the EHS aspects during construction and operation. The project’s EHS staff, which will report to the company’s global EHS team and will collaborate directly with the project’s General Manager, will be comprised of an Environmental Manager and a Safety Manager, as well as EHS technicians, as required. During the construction phase, while liaising with and being accountable to the company’s Safety Manager, the Subcontractor’s safety personnel will be responsible for the successful implementation of and continuous compliance with all environmental and safety policies, procedures and requirements applicable to the project during this phase. The project will also have qualified personnel responsible for community relationship reporting directly to the General Manager. As needed, the company will also hire environmental consultants, to conduct studies, monitoring, audits, etc.



Training, monitoring, and reporting

The company 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, etc. Throughout the lifetime of the project, third-party staff will perform preventive and corrective maintenance tasks as needed. The maintenance staff will a
lso receive EHS training. The company will establish a monitoring program to assess the EHS performance of its operations including number of accidents/incidents, etc. The company will implement a Contractor Monitoring Procedure in accordance with relevant labor laws and IFC PS requirements, as indicated in the ESAP. The company will submit annual environmental and social performance reports to regulators, lenders, and investors.

Human Resources Policy and Management

First Solar will develop a project specific Human Resources (HR) Policy and Procedures based on the IFC PS2 requirements and its own corporate policies. The HR Policy and Procedures will 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 for any worker accommodation provided, as specified in the ESAP. These procedures will be appropriately communicated to all employees.



The company will establish a worker’s grievance mechanism defining the channels (e.g. mail, phone, verbal report to immediate supervisor/reporting authority; etc.) available to submit grievances. The grievance mechanism, which will form part of the HR procedures, will be communicated to all employees and contractors. The company will maintain a database with information regarding grievances outcomes.



At the peak of the construction phase, the project will generate approximately 500 jobs. It is anticipated that a significant percentage of the labor force will be locally hired from Copiapo and nearby communities. Company management and its contractors will closely coordinate with the labor related local authorities (Oficina de Intermediación Laboral Municipal de la Municipalidad de Copiapó.) in the local hiring process. Once decided, but prior the beginning of the construction, the company will inform IFC about the geographical source(s) of its workers as well as about the relevant workers accommodation (i.e., housing, transportation, etc.) to be established as indicated in the ESAP. The company is committed to ensure that worker accommodation, if needed, will meet PS2 requirements. The project will generate approximately 10 employees during the operation phase.



Occupational Health and Safety (H&S)

The company will establish an H&S management system aiming to have a zero accident policy. The company will focus on the prevention of risks related to work at heights, work with live power lines and equipment, fire, exposure to chemicals, exposure to electromagnetic fields, etc.; and will provide and make compulsory the use of personal protective equipment (PPE) including ear protection when workers noise exposure is above 85 dB (A), industrial and dielectric safety helmets, safety goggles, mechanical protection gloves, safety shoes, welding masks, full-body harness, etc. Additional safety measures will include installing preventive equipment maintenance and enclosures and buffers to ensure noise levels below 85 dB(A), planning daytime activity for heavy vehicles and construction machinery activity, etc.

The design of the project is based on established state-of-the-art global technologies whose performance 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 needed for the construction and operation phases will be provided by authorized water tankers from the city of Copiapó. For human consumption, the company will buy bottled water from a company authorized by the local environmental authorities. The water for the operation phase which is anticipated to be 1.5 m3 /day will be stored in authorized water tanks. The panels will be cleaned using dry brush cleaning which does not require water usage.



The sanitary facilities for the construction phase will include toilets, sinks, showers and chemical sanitaries. The chemical sanitaries will be maintained by authorized contractors. The domestic effluents will be collected, directed to the modular wastewater treatment plant (WWTP) to be installed for both the construction and operation phases, and treated to IFC and Chilean standards. The treated wastewater will be used to moisten the roads during construction and to irrigate the site green areas during operations. The generated sludge at the WWTP will be disposed by authorized third parties in areas authorized by the local authorities. The industrial liquid effluents during the construction phase derived from the cleaning of trucks and construction equipment will be collected and filtered. The clear liquid will be reused to moisten the grounds and the sludge will be disposed as a non-hazardous solid waste. The only industrial liquid waste to be generated during the operation phase will come from module cleaning. As this effluent will only carry desert dust it will not require treatment and will be allowed to seep into the ground.



The main source of emissions (SO2, NOX and particulate matter) during the construction phase relates to earth movement and movement of equipment and vehicles in the unpaved roads. Prevention measures to be adopted include full coverage of trucks transporting materials, cover and/or use of dust suppressants on piled material, sufficient sprinkling of water and use of dust stabilizers in unpaved roads, etc. In addition, Luz del Norte will establish strict truck velocities (30 km/h with load and 40 km/h empty), will conduct periodic checks without prior warning along the routes used by the project trucks to ensure proper velocities are used, and will establish a plan to inspect and review all trucks and equipment used during the construction phase for proper vehicles and equipment maintenance. The project will reuse 100% of the excavated material within the site for refills, in case of any remaining material; this will be disposed in locations designated by the local environmental authorities. The aggregate material required for the construction phase will be provided by an external auth
orized company.



The impact on air quality during the operation phase will be very limited since the operation will not generate air emissions. The main source of particulate matter emissions will be vehicular traffic on the access and on-site unpaved roads but it is expected to be low and as indicated earlier, the project will establish dust suppression measures. 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 anticipates avoiding generation of 136,000 tons of CO2eq per year.



The solid waste to be generated during construction includes domestic, recyclable, construction debris, and hazardous wastes. Domestic and construction debris will be transported to the municipal landfill by authorized contractors and 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. The hazardous wastes, such as diesel oils and discarded material from vehicles maintenance, will be adequately stored and collected by authorized contractors for proper disposal. The wastes generated during operation will be mainly oil contaminated wastes and discarded panels. The oily waste will be properly disposed of by authorized contractors. The company analyzed the characteristics of the discarded panels and confirmed that those are not hazardous; thus they will be disposed, as non-hazardous waste, by authorized contractors in the municipal landfill. The company will establish an impermeable waste storage facility with a spillage or leakage retention capacity no lower than the volume of the largest container or 20% of the total volume of all stored containers. Access to the warehouse will be restricted and equipped with all applicable safety and fire prevention measures. The company will establish a tracking system to oversee the proper management of the hazardous wastes and will ensure that, during maintenance, there are established prevention measures to avoid potential soil contamination. The project will not have PCB transformers, ozone depleting substances, or banned/phased out substances. The transformers will be placed on oil retention basins to prevent soil contamination from any potential oil leak or spill. In case of such event, an absorbent element (i.e. sand, sawdust, etc.) will be used and will be managed as hazardous waste. The company has also prepared an appropriate Spill Prevention and Response Plan.

All hazardous chemicals (i.e., paint, glues, aerosols, thinners, etc.) will be stored in a dedicated warehouse. The warehouse will have external and internal signs indicating the class and classification of the substances stored. It will be surrounded by solid, water-resistant, inflammable walls; and will have a light roof, and a solid, structurally and chemically resistant, smooth, washable, impermeable, nonporous
floor. There will also be a dedicated area for fuel storage for a maximum of 4 tanks of 10 m³ each. This fuel is maintained to be used exclusively in case of emergency. The regular fuel supply will be contracted with a fuel station in Copiapó. The anticipated consumption will be 75 m³ of diesel per month.



The main noise sources during construction will relate to the earthworks, operation of machinery and vehicular traffic. To minimize the impact, the company will carry out all work during daytime hours, conduct preventive maintenance of equipment, optimize construction schedules and route vehicular traffic away from the nearest settlement. Equipment generating noise during operation will be enclosed to reduce noise to levels in accordance with the IFC requirements. Additionally, it is anticipated that the noise generated by the vehicles performing maintenance and surveillance activities will be low.



A provisional heliport will be set up for use during the construction phase to allow the landing of rescue helicopters in case of the occurrence of serious accidents requiring urgent transportation of injured personnel. The heliport will consist of compacted dirt with slopes no steeper than 3% in all directions. The heliport will abide by all the standards issued by the Chilean Directorate General of Civil Aviation.



The company conducted a hydrological study to determine the behavior of the storm water in the project site. The study concluded that rainfall of less than 25 years return period does not generate surface runoff. However, the rains of more than 25 years return periods generate surface runoff that crosses the project area. To capture the waters rain of more than 25 years return periods, Luz del Norte will build two channels to accommodate the peak flow of the 100 years return period. It will redirect the collected rain water towards the south of the site following the natural slope of the site.



Luz del Norte has prepared an emergency response plan addressing the risks of the construction and operation phases. It will have all needed emergency response equipment such as, first aid kits, trauma kits, automated external defibrillators, oxygen, cool vests, etc. and qualified trained personnel trained to response to emergencies.

The project will have low negative impacts to the communities. Since the construction phase will last 18 months, will generate a maximum of 500 jobs, and many of the workers may come from Copiapó and surroundings, it is not anticipated that there were will be measurable negative impacts in the nearby communities such as changes in population density or migratory flows.



High tonnage transport will travel through the C-397 and C-391 municipal routes avoiding circulation on the nearby communities. In addition, no abnormal loads will be transported.



The company has developed an emergency response plan for the construction and operation phases that will be implemented if needed. As part of its emergency response planning, the company will have trained emergency response personnel at all times and will involve the local authorities in the development of the emergency response planning as appropriate.



The company will hire only unarmed private security personnel and will not require any support from Chilean 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.

To assess the biological conditions of the project site (solar plant, transmission line, access road), Luz del Norte conducted spring and winter assessments. The assessments identified 19 native flora species, of which eight are endemic and only one, Adesmia argyrophylla, is classified as vulnerable according to the IUCN classification. Observations were also conducted to establish the presence of birds, reptiles, small mammals and large mammals. The following three sensitive fauna species were found: Callopistes maculatus (iguana) vulnerable, Liolaemus atacamensis (lagartija de Atacama) rare, and Liolaemus Platei (lagartija de Plata) rare. No mammals were found, just footprints from guanacos and dogs, as well as very few from foxes and pumas. Footprints are not sufficient to determine population densities. The result of the sampling of birds traffic in the area of the transmission line did not register significant bird presence. While Cathartes aura (red head vultures), Caracara megalopterus, (Andean caranchos) and Geositta maritima (small miners) were detected, their densities were very low.

The company developed a Biodiversity Management Plan to deal with the flora and fauna present in the vicinity of the project site. Key measures include rescue and relocation of reptiles within two to four weeks prior to the starting of the construction, performing morphometric measurements of the fauna captured prior to its release, non-invasive marking for further follow-up, and monitoring to establish the success and the possible conditions of the relocated animals. Even though a low density of mammals and birds was registered, the plan also includes some prevention measures to protect those species. Prior to the construction of the solar park, the company will install a 1.5 m high metal mesh fence to prevent the potential passage of large mammals into the solar park area and avoid those being harmed by getting caught in the maze of the solar panels. The mesh will be inspected on a monthly basis and repaired, if necessary. In addition, on the transmission line towers, As part of the plan, Luz del Norte will also install perch rejectors to prevent birds from perching in areas near the conductors thus avoiding casualties due to electrocution and will conduct training to workers and contractors about the prohibition of hunting or capturing fauna specimens. The Biodiversity Management Plan also includes procedures for collection and establishment of a seed bed and nursery for vulnerable species in the project area. Luz del Norte will monitor and periodically provide to IFC the results of the implementation of this plan.

To characterize the project’s cultural heritage, a team of three archaeologists conducted two surface survey campaigns, one in August 2012 and the second one in March 2013 on the entire plant surface and the proposed electric transmission line route. A total of 28 secondary historical value finds were found (mainly structures and wheel ruts.) Luz del Norte decided to adopt safeguard measures to be coordinated by an archeologist for these findings including geographical, photographic, and documented recordings of cultural materials; collection of findings; worker and contractors training on cultural patrimony; installation of fences and signs prior to the commencement of project's construction, etc. All elements of archeological value have appeared to be found already, however, Luz del Norte will retain an archeologist for the constructions phase, so in case of any new find, those will be reported to the Chilean National Monuments Council and proper management measures will be applied.

As part of the community relations and outreach activities, First Solar has carried out several meetings and activities in the municipal district of Copiapó to establish relationships with the regional and the local authorities as well as with local leaders. First Solar has also met with approximately 35 people from the nearby rural communities of Copiapó and Diego de Almagro. They learned about the project and its potential impacts and proposed mitigations; and provided their views about the project. They were in support of the project and asked the company to closely look and address any potential environmental (fauna, flora) impacts within the project area and to consider hiring people from the nearby communities for the construction and/or support services.

Due to the remoteness and nature of the project, no communities will be directly adversely affected by the construction and/or operation of the Project. However, the company is committed to develop community outreach activities and conduct further consultation and awareness campaigns to inform local communities about the Project. For the purposes of explaining the use/benefits of the renewable energy, Luz del Norte will conduct presentations to students and members of the community of Copiapó. It is projected that a minimum of five talks will be held annually, during the first five years of the project’s operation.

As part of the ESHSMS for the project, the company will design a procedure to receive, register, redress, and monitor community grievances. This procedure will be designed to be easily accessible, efficient, and to respond to the grievances in a culturally appropriate way. For the construction phase, the lead contractors will develop and coordinate implementation of a grievance mechanism to address any issues raised related to contractors’ activities. The company will supervise the effective resolution of grievances raised during this phase and as needed, it will have qualified dedicated personnel to meet with nearby community members and municipal authorities.

The company will disclose this document in Spanish in the Copiapó and Diego de Almagro communities. In Copiapó, the document will be displayed at the Municipality of Copiapo, Chacabuco 857, Copiapó, and in Diego de Almagro it will be displayed at the Municipality of Diego de Almagro: Juan Martínez 1403, Diego de Almagro.

Please contact the following for enquiries or concerns about the environmental and social impacts of this project:

Name: Patricia Pacheco
Title: Director of Government Affairs and Sustainability
Address: Kilometer 46 route C-17, sector Llano de varas, Copiapo, Chile
Phone: +56 22 594 7552

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Submit a copy of the Environmental, Social, Health, and Safety Management System (ESHSMS) for the cosntruction phase including the EHS Conractor Monitoring procedure to oversee the contractors performance	05/30/2014
Submit a copy of the ESHSMS for the operation phase	12/30/2014
Submit copy of permits issued by the Chilean environmental authorities for project construction phase	09/30/2014
Submit copy of permits issued by the Chilean environmental authorities for project operation phase	04/30/2015
Submit copy of the Human Resources policy	05/30/2014
Submit report indicating the number, geographical source of workers and the types of housing arrangemetns to take place	05/30/2014
Submit bi-monthly reports indicating whether new archeological finds have been found during the construction phase	12/31/2015