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
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

The proposed IFC loan to the project is a Category “B” project because a limited number of specific environmental and social impacts may result, which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. Potential impacts in construction activities besides being mitigable are likely to be limited to project site; short term; and not expected to impact environmentally sensitive areas. Further, it is possible to readily design and implement engineering and management measures to mitigate adverse impacts during construction and operations. The company will manage its environmental and social performance in accordance with applicable local laws and regulations and international standards, including IFC’s Performance Standards on Social and Environmental Sustainability.

Most of land required for the project is revenue land owned by the government and the companies have a land use permission and possession rights over it for 25 years. This land is mostly barren and unirrigated and not put to productive use. Approximately 11.5 ha of privately owned land is being/will be purchased/leased from about 40 individuals/families on a willing-buyer, willing-seller basis at a mutually agreed/negotiated rate. This privately owned land will be mostly required for access roads and the interconnecting 33kv and 220 kv transmission lines. No physical displacement will result from the setting up of the project and its associated utilities. Since contiguous land is not being purchased, continued access for grazing, pasture or access to agricultural fields will be ensured. Hence, PS5 (Land Acquisition and Involuntary Resettlement) is not applicable to the project.

With regard to PS7 (Indigenous Peoples), no diversions, material degradation or adverse impact is expected on land resources on which indigenous peoples are dependent. No tribal land is being purchased for the development of the project and its associated facilities.

No cultural heritage is expected to be adversely impacted as the site does not contain any archaeological monuments/sites, or any structure that have paleontological, historical, cultural, artistic or religious values. No unique natural features/forms, tangible or intangible are present in the project area which could be materially impacted by the project and its activities. Some temples and mosques are located in the villages close to the project sites; however, these will not be impacted and neither will there be disturbance or access disruption resulting from the project. Hence, PS8 (Cultural heritage) is not considered to be applicable to the project

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.

DJEPL and UUPPL (the companies) have carried out an Environment and Social Impact Assessment (ESIA), undertaken by a third party, to assess potential impacts and design appropriate avoidance, mitigation and compensation measures for project related risks and impacts in a manner consistent with IFC Performance Standards. The companies will develop and implement a project specific environment and social Management system (ESMS) for construction and operation phases based on the outcome of the ESIA/ESMP. In addition to the mitigation measures delineated and discussed in the ESIA, Inox (the ?E&C? and ?O&M? contractor) has in place an environment, health and safety management system encompassing construction and O&M activities which it will implement during the construction and O&M phases. DJEPL and UUPPL will contractually require the contractors to ensure that the avoidance and mitigation measures described in the ESIA are fully implemented during project construction and operation phase. Contractor oversight procedures will be developed and implemented by the companies to ensure monitoring and compliance to the requirements.

The ESIA (dated February 2014) has assessed impacts and designed appropriate avoidance, mitigation and compensation measures for project related risks and impacts (across the project life cycle) in accordance with IFC Performance Standards and good international industry practice (GIIP). These include impacts (including relevant cumulative impacts) pertaining to a) ecology including on flora, fauna, birds and wildlife habitat, b) ambient noise levels including cumulative noise, c) land use pattern, d) ambient air quality, e) water and soil quality, f) wastewater; hazardous and solid waste, g) traffic including impact on local infrastructure and community health & safety, h) socio-economic, i) cultural resources, j) electro-magnetic interference and air aviation, k) shadow flicker, glint and visual intrusion, m) blade throw and n) labour engagement and influx.

The ESIA includes an Environment and Social Management Plan (ESMP) that outlines a) the avoidance & mitigation measures for the identified adverse impacts, b) monitoring and reporting framework and c) management responsibilities to implement the ESMP. A summary of stakeholder consultations and community engagement (undertaken as part of the ESIA) has been provided. Further, a stakeholder/community engagement plan has been developed along with stakeholder analysis and a grievance redress mechanism. The ESIA also outlines specific management plans covering traffic and road safety, occupational health& safety, waste water management, emergency management and response, stakeholder/community engagement, community development, cultural heritage protection that will be implemented by the project.

Emergency response plan developed as a part of the ESIA will be implemented at the site to deal with emergencies such as electrocution, fire, fall of structure, medical emergency, civil disturbances, sabotage/vandalism and natural disasters. Emergency numbers will be displayed at site (viz. nearest police station, health center) at the site for use by staff.

DJEPL and UUPPL will ensure adherence to IFC Performance Standards as applicable to its project and operations by implementing the mitigation, monitoring and management measures outlined in the ESIA. This will be done by including the E&S provisions in the contractual agreement with contractors (E&C/O&M and others) and putting in place a robust oversight mechanism (deputing personnel, regular monitoring, internal audits and reporting). DJEPL and UUPPL will contractually require the contractors to put in place a social and environmental organization consisting of qualified E&S personnel with appropriate responsibility to implement a) the ESMP, management plans and the bird/bat monitoring programme, b) community engagement and grievance redressal system/mechanism, c) labour and health & safety related requirements, d) regular training of employees and contractors and e) emergency preparedness and response procedures. DJEPL and UUPPL will, as a part of its own contractor oversight procedure, undertake periodic monitoring/review and reporting of E&S performance of the project to the management and investors. Apart from this internal and third party audit (especially during construction phase) will be undertaken to assess compliance to aforesaid requirements.

The companies adhere to the Human Resource (HR) policies and procedures of the holding company; Surajbari Wind farm Development Private Limited (SWDPL). SWDPL will undertake a review of its HR policies/systems and procedures and strengthen and upgrade it to meet the PS 2 requirements. This could include (but not be limited to); a) a clear policy on non-discrimination and equal opportunity; b) contract labor management; c) security; d) disciplinary procedures and code of conduct; e) training and employee welfare; f) collective bargaining; g) grievance mechanism in line with PS2 to raise workplace concerns and h) retrenchment. The company?s HR Policies and procedures will be made available/accessible to all employees and communicated at the time of employee induction.

DJEPL and UUPPL plan to engage on its rolls 30 to 40 employees in construction and 10-12 in operations phase. During construction stage (lasting around 15-18 months), 150-200 workers will be required for most part though at peak construction activities about 300-350 workers will be deployed. About 18-20 security staff will also be locally hired in the operations phase of the project. The construction workers (mostly unskilled and semi-skilled) are expected to be either from the local area or will be brought from outside the region (migrant workers). Construction workers from outside the area/region will be provided accommodation in nearby villages or accommodated in labour camps set up by contractors in the project area. The skilled workers (around 25-30%) will be hired from outside and accommodated in rented houses at nearby towns.

DJEPL and UUPPL will require its contractors that engage migrant workers, to make available living conditions with basic amenities and electricity; potable water; mess facilities for food; where workers desire self-cooking, provision of fuel and arrangement for cooking; provision of toilets and bath including separate toilets and baths for women family members of workers; appropriate sewage disposal facilities and/or septic tank and soak pit; and primary medical care for all workers engaged at site.

The contract labour management process developed as a part of the ESMP will be implemented for the project. As a part of the contractor oversight procedures, DJEPL and UUPPL will review the contractors? HR policies and procedures and communicate to them specific provisions of its own HR policy and PS 2 requirements that are applicable to contractors?. It will put in place detailed requirements including audit procedures to ensure that: contractors comply with applicable statutory requirements; worker accommodation is consistent with IFC Guidance on Worker Accommodation; workers have access to appropriate grievance mechanism; and migrant workers are engaged on substantially equivalent terms as non-migrant workers performing same work, all in accordance with Performance Standard 2 provisions. DJEPL and UUPPL will provide training and capacity building support to the contractors to understand and meet the aforesaid requirements.

DJEPL and UUPPL will ensure that the contractors? fulfills its environment, health & safety and labour related obligations/requirements. The company will require them to ensure use of relevant personal protective equipment, implement work permit and tag out/lock out system (for working at height, confined space, electrical works etc) and incident/accident recording/reporting systems etc). It will periodically review OHS performance of the contractor during construction and operation phases. DJEPL and UUPPL will contractually require the contractors to report on OHS, ESMP implementation and grievance related issues.

Ambient air quality parameters in the project area are well within national standards. Temporary impact on ambient air quality is expected during construction phase linked to site preparation activities (foundation and road excavation, leveling, land clearing), vehicle movement and other activities. Mitigation measures, to minimize this adverse impact, are proposed including minimization of disturbance of vegetation, covered transportation of loose construction material/excavated earth and stockpiles, water sprinkling, and management of pollution from vehicular and equipment emissions.

Baseline noise levels at nearest habitations exceed the permissible limits (national ambient noise standards) both during day and night time for some locations. However, this is attributed mostly to the commercial activity and traffic movement in the area. Major noise sources in construction phase include operation of cranes, excavation, movement of construction machinery, operation of DG sets, vehicular movement, etc. Incremental noise level increases during construction will be temporary and limited to the vicinity of the noise generating source, except in case of movement of material through/near habitations or other sensitive receptors.

DJEPL and UUPPL will, implement the traffic management plan and other mitigation measures (like use of noise barriers at potentially high noise area/locations, PPEs, restriction on traffic movement during night hours, regular maintenance of vehicles, minimizing ground vegetation clearance etc). As a part of its oversight procedures, DJEPL and UUPPL will, undertake six monthly monitoring of ambient noise level in order to understand the increase in noise levels due to the project operation. The noise impact assessment for operation phase indicates that material noise impact on sensitive receptors is not expected due to the project.

Water requirement for the construction stage will be about 62.1KLD and 1.35 KLD during the operations phase. These will be sourced from authorized vendors in the area/region. The project will not extract/use water from water bodies located close to the site or in the nearby area. Analysis of ground and surface water quality in the area has shown compliance to Indian drinking water standards IS: 10500. Domestic wastewater during construction and O&M phases will be disposed through septic tank and soak pits. There will be no discharge of waste water to any surface water body. While construction will be generally avoided during rainy periods, appropriate mitigation measures to minimize erosion and water pollution will be implemented. Material impact on water sources is not expected on account of the project both during construction and operation stages.

Construction waste such as packaging and crating material of turbines, construction debris like small concrete, metal, bins, scraps and debris will be collected, stored, segregated and disposed of accordingly. Waste from earthmoving activities and hazardous waste generated from use of heavy machinery /equipment like waste oil, gearbox oil, hydraulic oil, lubricant, cleaning fluids, paints, degreasers and other similar substances will be disposed as per the Hazardous Waste (Management, Handling &Trans boundary Movement) Rules, 2008 through authorized entities. DJEPL and UUPPL will, as a part of contractor oversight, require the contractor to implement the waste management plan and ensure that the waste generated at the site are securely stored, handled/used with appropriate care and personal protective equipment; segregated; and disposed of in accordance with the waste management plan requirements. It will also ensure that: transformers do not use PCB containing oils; and ozone depleting substances banned/phased out under Montreal Protocol are not used. The project will result in reduction of greenhouse gas emissions.

Land disturbance from construction activities such as excavation, leveling, cut and fill, topsoil stockpiling, installation of tower foundation are expected during the construction stage of the project. These will however be short-term and temporary in nature (limited to construction phase). All the excavated material will be stockpiled at a pre-determined staging area with an intention to minimize impact on fertile agricultural top soiland to protect grass spores that may be present. These will be used for back filling and road leveling work. Proper care will be taken to minimize ground vegetation clearance and soil erosion.

The turbine sites are generally located away from human settlements and other sensitive receptors. The project equipment, plants and infrastructure meet good industry practices. The project is located in a moderate seismic hazard zone, which has been taken into account in the design of turbine foundations. The site is not located on any air traffic route and turbines are not proposed within any airport obstacle limitation area.

Though the construction sites are generally away from local settlements, adverse impacts on the local community during project construction and operation may include noise, dust, traffic, safety and security. The measures to minimize community health and safety risk have been discussed in the ESIA (including traffic planning, managing influx related issues, sourcing water from authorized vendors, appropriate disposal of sanitary wastewater and hazardous waste, appropriate accommodation and facilities for migrant workers)and the management plans (emergency, community development, stakeholder engagement). DJEPL and UUPPL will ensure that the O&M operator of the wind farm implements the mitigations measure detailed in these management plans. Traffic management measures like movement during day time, speed limits, restricting on honking, driver training in defensive driving etc as discussed in the traffic management plan will be undertaken. DJEPL and UUPPL will implement an Emergency Response and Preparedness Plan to deal with emergencies such as electrocution, fire, community safety incidents and natural disasters. Emergency numbers will be displayed at site (viz. nearest police station, health center) at the site for use by staff.

The project is not expected to result in community exposure to disease either due to changes in land/hydrologic other terrestrial/air quality/hydrologic regimes or through large influx of migrant labor. DJEPL and UUPPL will nevertheless require the contractor to have measures in place to identify and mitigate risk of community exposure to disease due to influx of labor and any other community health, safety and security risks. Overall, road and access infrastructure in the area is good (the site is well connected by road network) and significant pressure on infrastructure is not expected due to the project.

DJEPL and UUPPL will allow grazing activity in most part of the site. It will ensure that all transformers are fenced and cables insulated to avoid any electrical hazards. Access to agricultural fields, villages, communities and their networks will not be disrupted/hindered. The project will not hamper the activities or access to the temples/mosques in the project area.

The modeling results (including cumulative modelling) for shadow flicker suggest that four turbine locations are likely to result in shadow flicker impacts on nearby sensitive receptors (temple, habitation, school which are located within the distance of 100-300 mts). DJEPL and UUPPL will revisit the micro-siting of these four locations and shift them to other nearby areas so as to ensure no adverse impact on receptors. It will monitor risk of shadow flicker impact on all nearby habitations during operation stage; and in consultation with the affected households (if any), implement appropriate necessary mitigation to reduce or prevent shadow flicker including required provisions of curtains/blinds/screens and establish screening vegetation. Glint, blade throw, visual interference and Electromagnetic Fields (EMF) related impacts are not expected on account of the project.

The project will employ security personnel during project construction and operation. These personnel will be engaged through an outsourced and authorized security agency. Security personnel will not be armed. DJEPL and UUPPL will require the security agency to implement procedures to ensure that: past records of security personnel employed are screened; security personnel have clear objectives and permissible actions laid out; security personnel are trained in avoidance of abusive behavior; 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. Contractor oversight procedures of the company will ensure compliance to the aforesaid requirements

The proposed project does not fall under any conservation areas/protected areas/World Heritage sites or Eco Sensitive Zone. No forest land is involved in the right of way (ROW) of the transmission corridor proposed for the project. A rapid assessment of avifaunal species (with focus on birds and bats) suggests that no significant adverse impacts on faunal and avifaunal species are expected from the project and planned developments.

The ESIA studies suggest that the project site does not harbor high biodiversity of flora and fauna, including endemic species. Analysis of secondary data and consultations with relevant stakeholders suggest that the project area falls in a low bird activity area and has low intensity with regard to migration routes of large bodied birds. No known major avian migratory flyway coincides with the project area. One roost of a common bat species i.e. Indian Flying Fox (listed as Least Concerned species by IUCN) was identified at a reasonable distance (about 2 kms) from two of the turbine locations. The majority of proposed turbine locations maintain safe distances (500-1000 mts) from the water bodies in and around the project area. These water bodies were assessed to not hold water on a long term basis and thus are not likely to serve as bird staging or nesting areas. Discussions with other wind farm developers also did not report any incidences of bird hits in their operation wind farms in the area.

While a significant impact on birds and bats is not expected based on EIA findings, DJEPL and UUPPL will; a) implement a program to monitor the local population of bird and bat species; (b) train staff on undertaking bird/bat strike monitoring; (c) implement a bird/bat strike monitoring program; (d) monitor the water bodies (in the monsoon and winter season for bird activity) and (e) if, the proposed monitoring program indicates significant activity or/and bird/bat strikes, consult with and implement measures (within 6-8 months of commissioning) recommended by ornithologists/wildlife specialists to address the impacts, including, if required, a shutdown protocol and enhanced collision monitoring program. DJEPL and UUPPL will, in addition to the above, explore options for joint monitoring of critical avifaunal species and bird/bat hits with other developers/operators in the area

The ESIA consultants, as part of the impact assessment process, consulted (in January 2014) with local villagers (in Nolakha, Panchewa, Jailner, Bhatkheda, Kacthnera and Sarsod) on the project and expectations/concerns if any linked to the development of the project in particular and wind farms in general. These consultations included discussions/meetings with village representatives, select land owners, women’s groups and opinion leaders in the area/affected villages. Apart from this interviews were also conducted with the general community in the impacted villages. IFC’s appraisal process also included meetings with village representatives, community elders, land/revenue officials and some impacted households. These consultations suggest that the land purchase (for privately owned land) was being done on a willing-buyer, willing-seller basis and that the rates of compensation offered were more than the prevailing market rates for land in the area. It also suggests that the process adopted for land purchase is transparent and participatory and that there are no major concerns relating to encroachments or illegal occupation of revenue land allotted to the project. Key concerns and expectations reported in these meetings included a) increased local employment and contractual benefits, b) infrastructure development of villages (like roads, health care and education facilities and c) better management of traffic. These concerns and expectations have been addressed in the ESIA/ESMP and the management plans and will be communicated to the stakeholders/communities.

The ESIA (in the stakeholder engagement plan) proposes a stakeholder/community engagement strategy/programme for the project. As a part of the engagement process the companies will a) disclose the findings of the ESIA (and the ESMP) to the community/stakeholders, and (b) seek and incorporate their feedback/inputs. It will engage with the communities, panchayat and local administration on an ongoing basis to address any complaints/grievances/concerns of the stakeholder and to plan and implement community development activities.

DJEPL and UUPPL will implement the grievance redress plan (prior to start of construction activity) and constitute a grievance redress committee (comprising of community/company/panchayat representatives to look into community/stakeholder concerns and grievances. Information about this committee and the grievance redress mechanism will be shared with the stakeholders through locally appropriate communication tools. The stakeholders will be encouraged to approach this committee with their concerns and suggestions. Minutes and proceedings of the meetings of this committee will be documented and shared with relevant stakeholders

The company will locally disclose the social and environmental information including the ESIA for the project at the following locations:Project Office- Bhatkheda,Tehsil- Piploda
District- Ratlam,
State- Madhya PradeshAny queries and/or comments about the project may be directed to:Mr. DurgaDath
Vice President - Strategy
Surajbari Wind farm Development Pvt Ltd
102, El Tara building, Orchard Avenue,
Hirnandani, Powai, Mumbai – 400076

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.