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 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.

The project will be developed on unused revenue land which has been allotted to the company by the state government. The land is barren, rocky and not fit for agricultural purposes. Private land required for the construction of the transmission line (either pole/tower site and/or for the line right-of-way (RoW) will be leased from individual land owners through a negotiated settlement. There will be no expropriation of land for the purpose of the transmission line. A lump sum compensation based the agreement will be paid to the affected land owners. No forest land is involved in the RoW of the transmission corridor proposed for the project. No physical displacement will result from the setting up of the project and its associated utilities. The project will provide for access roads to ensure continued access to the other lands in its operational phase. Hence, PS5 (Land Acquisition and Involuntary Resettlement) is not applicable to the project.

There are no ecologically sensitive zones/areas within a 10 km radius of the project site. No significant adverse impacts on fauna is expected nor are any forest/protected areas being impacted by the project and planned developments. Hence, PS6 is not considered applicable to the project.

With regard to PS7 (Indigenous Peoples), the project and its activities will not impact any indigenous people/community. No tribal land is being taken for the development of the project and its associated utilities. Hence PS 7 is not considered applicable to the project.

No cultural heritage is expected to be adversely impacted as the site does not contain any archaeological sites, or any structure that have paleontological, historical, cultural, artistic or religious values. No unique natural features, tangible or intangible are present in the project area which could be impacted by the project and its activities. Hence, PS8 (Cultural heritage) is not applicable to the project. However, the project will, as a part of its E&S procedures, implement Chance Find Procedure and train its staff with respect to the same.

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.

Azure has developed and implemented a corporate Social, Environment and Health & Safety Management System (SEHSMS) and is committed to ensure that its individual projects (owned directly or through SPVs) are constructed and operated in a manner consistent with host country requirements, IFC’s Performance Standards and good international industry practice (GIIP) including those detailed in the relevant parts of applicable IFC’s Environmental, Health and Safety Guidelines. Azure’s SEHSMS includes policies and procedures that require new projects to undertake an environmental and social impact assessment (ESIA) consistent with IFC Performance Standards and implement the Environmental and Social Management Plan (ESMP) setting forth: (a) measures to mitigate adverse impacts, (b) monitoring requirements for ensuring the mitigation measures are implemented effectively and in a timely manner; and (c) provisioning for organizational and financial resources to ensure mitigation and management plans are implemented. The SEHSMS has a focus on safety aspects and includes procedures for: risk identification; compliance with regulatory requirements; development and implementation of management programs; incident and accident handling, recording, reporting, investigation and analysis; emergency preparedness and response; responsibility allocation; training and awareness; communication and consultation; monitoring, recording, reporting and documentation; audit; corrective action; and management review.



Accordingly, the company has as per the guidelines/provisions of the corporate level SEHSMS, undertaken a third party led ESIA and will develop and implement a project specific environment and social management system (ESMS) for the construction and operation phases) based on a) the outcome of the ESIA/ESMP and b) in accordance with the requirement of its corporate SEHSMS (refer ESAP action 1). The ESIA (dated August 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 GIIP. These include impacts pertaining to a) ecology including on flora, fauna and wildlife habitat, b) ambient noise levels, 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) occupational health & safety, i) socio-economic, j) cultural resources, h) glare and visual intrusion, and i) labour engagement and influx. The ESIA has assessed that given the lack of sensitive receptors in the area, cumulative impacts are not envisaged.



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 c) responsibilities and d) an organizational structure to implement t
he ESMP.



The ESIA also outlines specific framework management plans covering waste, traffic, health & safety, emergency preparedness/response, construction labour camp management, community engagement and grievance redressal that will be implemented by the project. The company will contractually require the construction contractor/operator to ensure that the avoidance and mitigation measures and plans outlined in the ESIA are implemented during project construction and operation phase.



The company 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 developer/ O&M operator and putting in place a robust own oversight mechanism (deputing personnel, regular monitoring, internal audits and reporting). The company will contractually require the developer/operator to put in place a social and environmental organization consisting of qualified E&S personnel with appropriate responsibility allocation to implement/oversee/monitor a) the implementation of the ESMP, b) community engagement and grievance redressal system/mechanism, c) performance of contractors on labour and health & safety aspects, d) regular training of employees and contractors, e) emergency preparedness and response, f) periodic monitoring social and environmental performance; (g) internal and third party audit; (i) management review; (j) and periodic reporting of E&S performance to the management. The contractor management plan detailed in the ESIA and including monitoring of legal compliance and adherence to laid out procedures will be implemented to ensure that E&S requirements are met.

During the operations phase, the company plans to engage 3 to 4 employees, primarily to oversee the plant operations. The company adheres to the HR Policies and procedures of the holding company Azure, which has already strengthened and implemented its HR systems in line with the PS 2 requirements as a result of previous transactions with IFC. The company’s HR policies and procedures will be made available to all employees and communicated at the time of employee induction. About 20-30 security staff will also be locally hired for construction and operation phase. Most of these staff will reside in rented accommodation in the nearby village/town.



During construction, which will last around 4-6 months, man-power ranging from 50-100 will be required during normal functions while peak construction activities will require about 200-250 workers. Preference will be given to local community members. However, the project envisages a requirement of around 30-50 skilled workers who will be hired from outside the immediate project area. Though the project plans to maximize local content in employment in the construction phase, it also has back up plans for sourcing labour from outside the region in case the labour requirements are not met locally. To this effect, labor accommodation are planned to be set up during the construction phase of the project.



The company will ensure that adequate facilities and amenities are provided in the labour accommodation for construction workers including: adequate living/sleeping facilities and space per person; potable water that meets national standards; toilets, washing and cleaning facilities; canteen/mess or fuel for cooking; locker/storage facilities; and facilities for management and disposal of garbage, sewage and other waste. The company will periodically review and monitor the condition of the labour camps.



The contractor management plan developed as a part of the ESIA and the relevant provisions of Azure’s HR policy and SEHSMS will be implemented for the project. The company will communicate with the contractors on its SEHSMS and HR policies and PS 2 requirements with respect to access to grievance mechanisms, health & safety, benefits and welfare provisions etc. To this effect it will provide trainings and capacity building support to the contractors. The company, as a part of the contractor oversight procedures will regularly monitor compliance to the aforesaid guidelines/requirements and ensure that these are met. Internal audits and follow up on corrective actions will be undertaken to assess efficacy of the oversight system.



The company will ensure that the developer/O&M operator fulfills its health & safety and labour related obligations/requirements. The company will require the developer to ensure usage of relevant personal protective, implement work permit and incident/accident recording/ reporting systems etc). The company will (apart from the periodic internal audit) engage a qualified t
hird party to review/audit its labour, OHS and contractor management practices during the construction phase to assess compliance to aforesaid requirements (refer ESAP action 3).

The project, which will contribute to GHG avoidance of approximately 53,054 tons of CO2 equivalent emissions per year beginning in FY2015. No material impact on ambient air quality is expected on account of this Project. However, temporary impacts on ambient air quality and noise levels may be expected during construction. The company will implement measures during construction: for management of excavated earth and construction rubble; and minimization of fugitive dust emissions. Further, the company will ensure that other wastes (packing material, metal, debris, cement bags, drums/carbuoys etc.) are collected, stored and disposed off to re-users or in appropriate authorized debris disposal areas.



Limited concreting work is expected for structure foundations, sub-station, transformer yard and transmission towers. Cement concrete mixers will be used at site since significant concreting work is not expected. Concreting and other construction activities including use of earth moving equipment and increased traffic for material movement is expected to result in increase in ambient noise levels. However, this increase is short term during construction stage only. The construction work will be carried out only during day time and no noise generating equipment will be operated at night.



Water use will be for domestic and panel washing purposes only. Given that the project involves PV rather than Concentrated Solar Power (CSP) technology, water consumption will be minimal (about 20-25 M3/day). Dry brush cleaning solutions will be considered. Water required will be sourced from authorized water tankers. The company will also evaluate the feasibility of appropriate reuse of treated sewage and wastewater. No material impact on surface or groundwater resources is expected on account of the project. The company will ensure that the water made available to workers and employees’ meets national potable water quality norms. Appropriate facilities for collection, treatment and disposal of sewage (septic tank and soak pit) both during construction and operation phases will be provided.



Hazardous materials (transformer oils, dielectric containing material, paints, batteries etc) and hazardous wastes (used oils, waste/residual paint, oil/paint soaked rags/material, filters, empty oil/paint/chemical drum/barrels etc) are not expected to be generated in significant quantities during construction or operation. However, the company will ensure that hazardous material and hazardous wastes generated at site both during construction and operation are: stored under segregation and containment; handled/used with appropriate care and personal protective equipment; and disposed of through entities authorized to handle and dispose hazardous wastes. Further, the company will ensure that transformers do not use PCB containing oils and that ozone depleting substances banned/phased out under Montreal Protocol are not used. Use of any pesticides is not envisaged at the pro
ject site.

The nearest habitations are about one kilometer from the project site and the nearest community is about two kilometers from the project site. Increase in traffic is expected during the construction phase. The company will implement appropriate mitigation measures (as discussed in a traffic management plan) including setting speed limits, posting of traffic marshals and material movement planning to reduce community exposure to safety risk. Further, at the project site, the company will exercise appropriate access control, barricading of excavated areas; safety signage; illumination and other measures to mitigate the risk of accidents for general public during construction.



The project will engage security personnel but they will not be armed. However, the company will 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 conduct; security incidents are recorded, investigated and corrective action implemented; bona fide complaints against security personnel are investigated and appropriate disciplinary actions are implemented; and there is a grievance mechanism for aggrieved members of community or employees, in the event of a violation of the code for security personnel.

The company representatives have been undertaking informal stakeholder consultation with the community in and around the project site (specifically the two villages) but these have not been documented. The ESIA proposes a stakeholder engagement programme for the project. The two important elements of the programme are a) disclosure of the findings of the ESIA (especially the ESMP) to the community and b) implementation of the stakeholder engagement plan and the grievance redress mechanism proposed for the project (refer ESAP action 3). The company will implement a plan for ongoing engagement with the stakeholders including consistent with requirements of PS 1 and delineated in the ESIA.

The company will implement the grievance redress plan prior to start of construction activity and constitute a grievance redress committee to look into any 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 also proposes to develop and implement appropriate community development programs in consultation with the affected communities.

The company will locally disclose the social and environmental information including the ESIA for the project at the following locations:Panchayat Office,Hardhani and Nadiya Kalan
Baori Tehsil
Jodhpur district
Rajasthan, India

Any queries and/or comments about the project may be directed to:

Manoj Mishra
Head- SHES and Quality
8, LSC, Pushp Vihar,
New Delhi -110062
India
Phone: +91 11 49409800/ +91 11 49409848

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Develop and implement a project specific ESMS for construction and operation phases covering (but not limited to) the impacts and mitigation measures delineated in the ESIA	10/01/2014
Disclose the ESIA and implement a formal stakeholder engagement and grievance redress process in consultation with project stakeholders	09/30/2014
Undertake a third party audit of EHS and labour related compliance	01/15/2015