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 revenue land which is in the process of being allotted to the company by the state government. As per the revenue/land records this land is barren, uncultivable and not fit for agricultural purposes. The social assessment came across small patches which were being used for agricultural and grazing purposes in one of the three land parcels. Consultations with the village head (sarpanch) informed that in the lack of any on-site activity, the villagers seasonally using some patches of land cultivation and grazing activities. These encroachments were reportedly seasonal and not long term in nature. ASEPL will, going forward a) to the extent possible exclude from its lease area any such land parcel which has agricultural usages and b) upon allocation and boundary delineation/demarcation of land undertake an assessment to evaluate any residual livelihood dependencies (refer ESAP) . In the event of any livelihood impact, the company will provide for compensation (for loss of crops/assets) and other livelihood restoration measures. The right of way (RoW) for the transmission line connecting the project to Bari Seer substation will pass through revenue lands. Private land, if any, 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 on 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 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.

ASEPL has developed and implemented a corporate Environment and Social Management System (ESMS) 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.



ASEPL’s ESMS is a three tier system with defined corporate policies for environment, health & safety and social aspects (like those for corporate social responsibility, grievance handling human resource management etc). At the second level are the operational control procedures and (instructional) checklists for planning, implementation, monitoring and review stages of the projects (like requirements for, i) undertaking an environmental and social impact assessment (ESIA) consistent with IFC Performance Standards before start of any new projects; ii) undertaking stakeholder engagement; iii) ensuring legal compliance; iv) managing grievances; v) handling resettlement and rehabilitation related issues/aspects; vi) planning emergency response etc. Finally the ESMS provides for an institutional structure with defined E&S responsibilities and lays down requirements for training, internal as well as external monitoring/audit, reporting and documentation at the corporate as well as project site level. The ESMS also has a focus on safety aspects and includes procedures for: risk identification; compliance with regulatory requirements; incident and accident handling, recording, reporting, investigation and analysis; training and awareness; monitoring, recording; audit; corrective action; and management review. A review of the ESMS implementation and compliance found gaps with respect to a) institutional/organizational capacities; b) grievance handling; c) contractor management practices; d) safety management; e) emergency response planning etc. ASEPL has provided a time bound action plan to ensure closure of gaps and ensure compliance with the ESMS requirements.



Accordingly, the company has as per the guidelines/provisions of the corporate level ESMS, undertaken a third party led ESIA and will implement the environment and social management plan (ESMP). The ESIA 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) soil resource and quality; b) land use pattern; c) ecology including on flora, fauna and wildlife habitat, d) noise and vibration, e) ambient air quality, f) water resource and quality, g) wastewater; hazardous and solid waste, h) traffic and transport including impact on local infrastructure and community health & safety, h) occupational health & safety, i) socio-economic, j) archaeologic
al, historic and cultural aspects, k) aesthetic, glare and visual intrusion, and l) labour engagement and influx. The ESIA has assessed that the project will not significantly contribute to cumulative impacts in the region due to the larger land use of the area (largely barren and uncultivable land). Similarly impact on water resource availability is not envisaged in the long term due to the proposed and dedicated water pipeline for industrial projects in the area. The ESIA has not assessed any significant cumulative impact linked to the development of this project.



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 the ESMP. The company will contractually require the construction contractor/operator to ensure that the avoidance and mitigation measures and plans outlined in the ESIA and ESMP 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 (refer to the attached ESAP) 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

During the operations phase, the company plans to engage 10-15 employees, primarily to oversee the plant operations. The SPVs will adhere to the HR Policies and procedures of the company, 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 20-25 peoples for cleaning and 15-20 security staff will also be locally hired during operations phase of the project. Most of these staff will reside in rented accommodation in the nearby village/town.



During construction, which will last around 4-6 months, around 250-300 workers will be required during normal functions while peak construction activities will require about 500-600 workers. Preference will be given to local community members. However, the project envisages a requirement of around 100-150 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 camps 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 (as per the ESAP). The company will periodically review and monitor the condition of the labour camps.



The contractor management linked requirements suggested as a part of the ESIA/ESMP will be implemented for the project. The company will communicate with the contractors on its ESMS/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 third par
ty to review/audit its labour, OHS and contractor management practices during the construction phase to assess compliance to aforesaid requirements (refer ESAP)

The project will contribute to GHG avoidance of approximately 141,450 ton CO2 per year (on average for 25 years). 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 for piling and concreting work. 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.



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 not be significant (about 20 M3/day). Dry brush and vacuum cleaning solutions will be considered. Water required will be sourced from authorized water tankers. In the long term (2-3 years) a dedicated water pipeline is proposed which will provide water to all the projects in the area and is likely to be the source for the project.



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 project site.

The nearest habitation/settlement is about two kilometers from the project site. An increase in traffic is expected during the construction phase. The company will implement appropriate mitigation measures 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 ESIA consultants, as part of the impact assessment process, consulted (in July 2014) with local villagers in Bari-Seer village on the project and expectations/concerns if any linked to the development of the project in particular and solar projects in general. These consultations included discussions with village representatives and community members including women groups in the village. The community expressed support for the project and expected benefits in terms of employment, local contracts, community development and skill training. IFC’s appraisal process also included meetings with village representatives and community elders. Further community consultations are planned once the land area for the project is delineated.

The ESIA proposes a stakeholder engagement programme for the project. The two important elements of the programme are a) disclosure of the ESIA/ESMP (see attached ESAP) to the community and b) implementation of the stakeholder engagement plan and the grievance redress mechanism proposed for the project. 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,Bari-Seer Village
Baap Tehsil
Jodhpur district
Rajasthan, India
Any queries and/or comments about the project may be directed to:

Mr Ashish Bhardwaj
GM-Finance, Acme Solar Energy Private Limited
Plot no. 152,Sector-44, Gurgaon, Haryana, India
Phone: 0124-7117032
Fax: 0124-7117001
Email: mailto: mailto:ashish.bhardwaj@acme.in

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Disclose the ESIA and implement a formal stakeholder engagement and grievance redress system in consultation with project stakeholders	10/31/2014
Post the delineation of the project area boundary, undertake a rapid social assessment to identify impacts and implement mitigation measures in line with the ESIA.	11/30/2014
Construct and operate labour camps in line with the requirements of the PS2 and host country statutory requirements	11/15/2014
Ensure provision of qualified and dedicated personnel looking after Environment, Health & Safety, labour and community relations during the construction phase of the project.	10/31/2014
Undertake third party audit of EHS and labour related during the construction phase	02/01/2015