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

This is a Category B project according to IFC’s Procedure for Environmental and Social Review of projects because it may create a limited number of specific environmental and social impacts that can be avoided or mitigated by adhering to generally recognized performance specifications, guidelines, or design criteria.

The key environmental, health and safety, human resources and social issues that were reviewed included the following: environmental and social management systems; emissions to the environment – air, water and subsurface; solid, and hazardous waste and materials management, including transportation; community and occupational health and safety; energy use and efficiency; community engagement; and land acquisition. The potential impacts of construction activities, besides being mitigable, are likely to be (a) limited to the project sites, (b) short term in nature and (c) 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. A separate ESAP is not required for this project since mitigation measures are adequately described in the ESIAs developed for the project, and will be implemented as part of the company’s existing management system, which was determined to be satisfactory to provide comprehensive oversight of environmental and social considerations.

PS5: Land Acquisition and Involuntary Resettlement is not applicable as no physical displacement will result from the construction and operation of any of the projects and their associated infrastructure, and all private land will be acquired/ purchased on a willing buyer, willing seller basis. Most of the land required for the projects (except Parner in Maharashtra and for 10 wind turbines at Dangri in Rajasthan) is revenue land owned by the government, and the developers have/ will be granted a land use permission and possession rights over it for 20 years. Most of the land across all 4 project sites is barren and unirrigated, and not put to productive use. At the Parner site, around 19 ha of private land is being purchased from about 11 families on a willing-buyer, willing-seller basis at a mutually agreed and negotiated rate. At Dangri site, 10 ha private land is being purchased from 11 families and at Nipanya site, 4 ha has been purchased on a willing- buyer and willing-seller basis. The land for the proposed Rojmal project and associated right of ways comprises of revenue land only and no physical or economic displacement will be involved with the project.

PS7: Indigenous Peoples is not applicable as no tribal land is being purchased for the development of projects and their associated infrastructure and no diversions, material degradation or adverse impact is expected on land resources on which indigenous peoples are dependent.

PS8: Cultural Heritage is not applicable as the projects being considered for IFC financing are not located in areas of known historical or cultural significance.

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.

GIL, the sponsor, has a Quality, Health, Safety and Environment (QHSE) Policy and a documented QHSE management system (QHSEMS). GIL has appointed a senior and experienced QHSE professional for oversight of the QHSEMS development and implementation. A corporate QHSE audit program is in place as part of GIL’s efforts to embed its QHSE Policy across its various subsidiaries and project sites, including the company. The company’s QHSEMS includes policies and procedures that require it to carry out an environmental and social impact assessment (ESIA) or environmental and social audit (ESA) for each project, consistent with the IFC Performance Standards. The company (Green Infra Corporate Solar Limited) will adopt the QHSEMS of its sponsor and GIL’s QHSE & MR head will have the overall responsibility for implementation of the corporate QHSEMS across the 5 projects.



The company contractually requires 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 program, b) stakeholder engagement and grievance redress system/ mechanism, c) labor and health & safety related requirements, d) regular training of employees and contractors and e) emergency preparedness and response procedures. The company as a part of its own contractor oversight procedure undertakes periodic monitoring/ review and report of E&S performance of the project to the GIL management and investors. Apart from this, internal and third party audits (especially during construction phase) are undertaken to assess compliance to aforesaid requirements.



A draft ESIA has been prepared for each of the 5 projects by external consultants who were engaged by the company. Each ESIA report addresses the social, environmental, occupational health and safety aspects and impacts associated with construction and operation at the respective sites. It includes: a baseline assessment of the project site (soil, hydro-geology, topography and drainage, ground and surface water resources, meteorology, ambient air quality, noise, land-use, socio-economic status, flora and fauna); identified key risks and impacts. In addition, it outlines a management plan that addresses impact on surface drainage, wastewater, sanitary and sewage facilities, security, drinking water, garbage disposal, occupational health and safety, legal compliances, traffic emergency preparedness and response and monitoring plan.



The ESIAs have assessed impacts and designed appropriate avoidance, mitigation and compensation measures for project-related risks and impacts (across the project life cycle) in accordance with the 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 n
oise, 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, and l) labor engagement and influx. The company is currently reviewing locations of certain wind turbines which may be close to habitation to ensure no hazard from blade throw.



The ESIAs include Environment and Social Management Plans (ESMPs) that outline a) the avoidance & mitigation measures for the identified adverse impacts, b) monitoring and reporting framework and c) management responsibilities to implement the ESMPs. A summary of the stakeholder consultations and community engagement (undertaken as part of the ESIA) has been provided. Further for each of the 4 projects, a stakeholder engagement plan has been developed along with stakeholder analysis and a grievance redress mechanism. The ESIAs also outline specific management plans covering traffic and road safety, occupational health& safety, waste water management, emergency management and response, stakeholder engagement, cultural heritage protection that will be implemented by the projects.



An emergency response plan developed as a part of each 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. For emergency response, the company will maintain a community engagement plan and put in place an appropriate disaster and emergency response plan. Emergency numbers (such as nearest police station, hospital or clinic, etc.) will be displayed at the site for use by staff.



Performance of the company’s existing environmental and social management system is consistent with IFC PS requirements in providing adequate oversight, comprehensive risk assessment, monitoring, reporting and training. As the company grows its portfolio of wind assets, GIL will continue to manage its environmental and social performance per IFC PS and applicable World Bank Group EHS guidelines, and implement specific mitigation, monitoring and management measures outlined in the respective ESIAs for each site and included in the respective ESMPs or consent documents, examples of which include:



Oversight of environment, health and safety management system encompassing construction and O&M activities which partners will implement during the construction and O&M phases. This will be done by including the E&S provisions in contractual agreements with partners and putting in place a robust oversight mechanism (deputing personnel, regular monitoring, and internal audits and reporting).



If future encroachment and/ or seasonal cultivation of revenue land is noticed during the project construction period, the company will ensure that appropriat
e compensation measures are implemented for such informal cultivators and/ or settlers. In this regard, the company will review IFC’s Performance Standard 5 (PS 5) provisions on informal settlers and implement measures in compliance with the PS 5 requirements.



If any private land at any of the project locations is to be acquired or expropriated under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, the company will ensure that compensation for such land acquisition will be in compliance with IFC’s Performance Standard 5 (PS 5) provisions.”



The company will allow continued grazing activity in most part of the site. Access to agricultural fields, villages, communities and their networks will not be disrupted/ hindered in any way. The project will not hamper the activities or access to the temples/ mosques in the project area.



Specific requirements and audit procedures to ensure that: contractors comply with applicable statutory requirements migrant (non-locals’) worker accommodation is consistent with IFC Guidance on Worker Accommodation; workers have access to an appropriate grievance mechanism; and migrant workers are engaged on substantially equivalent terms as non- migrant workers performing same work, all in accordance with PS 2 provisions.



For construction safety, implement appropriate mitigation measures including speed limit, posting of traffic marshals, material movement planning to reduce community exposure to safety risk. At each project site require appropriate access control, barricading of excavated areas; safety signage; illumination and other measures to mitigate the risk of accidents for general public during construction.



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 prominently displayed at site. The company will ensure that all transformers are fenced and cables insulated to avoid any electrical hazards.



Significant impact on birds and bats is not expected based on ESIA findings, the company will on a continual basis: a) implement post-construction monitoring programs at each project for affected bird and bat populations (b) train staff/ local people on identifying and undertaking bird and bat collision monitoring; (c) implement a bird and bat collision monitoring program; (d) monitor the seasonal water bodies (in the monsoon and winter season for bird activity) and those permanent ones for birds commuting between sites flying through turbine clusters and (e) according to results of the proposed monitoring program and birds or bat activity, an adaptive management plan would be implemented and recommended by ornithologists/wildlife specialists to address the impacts, including, if required, a shutdown on demand protocol, enhanced collision monitoring program or habitat management.



Monitoring of waste and carca
ss disposal and space use by birds will be implemented for the Nipanya and Rojmal project sites. The results will serve as guidance on how to implement the post-construction monitoring if required. In addition to turbines, the proposed transmission line has been also evaluated and it will be provided with bird deterrents to avoid impacts. Joint monitoring of critical avifaunal species and bird/bat collisions with other developers/operators in the area is also proposed in order to understand the biological significance of impacts on a broader scale.

GIL has in place human resource policies and procedures, which will be applicable to company employees at each project site. The HR Manual covers employee working conditions and terms of employment including amongst other aspects recruitment, training, separation, leaves, code of conduct and employee grievance redress.



As per the HR policy, the minimum employment age at is 18 years. The company has procedures that ensure child labor or forced labor is not employed directly or by subcontractors through verification of relevant documents. Working hours on site can vary by nature of activity and phase of project, with most labor intensive phases being at the construction phase during which there are continuous operations. During the construction phase, each project will have about 80-100 construction workers. The developer at each site will aim to maximize hiring of unskilled labor from nearby villages. Skilled workers for crane operations and electrical works will be brought from outside; their numbers are expected to be around 20-25 per site. No labor camp is proposed at any project site. The migrant skilled workers are expected to live in rented accommodation in nearby small towns. The company will ensure that migrant workers hired directly or indirectly through developers/ contractors will be provided appropriate worker living conditions including basic amenities and electricity; access to potable water and food; provision of power or fuel for cooking; access to toilets and wash areas including (as appropriate) 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.



For all the four projects, typically the company will deploy 1-2 persons at site for supervision and monitoring of the O&M contractor during the operations phase. The company will agree with all its O&M contractors on EHS staff to be deployed at each project site. Further, security men will be hired at each location, these will be hired locally and the O&M contractor will train them.



The ESIAs for all projects have identified the key occupational health & safety risks and mitigation measures for the construction and operation phases. These include working at a height; working on live power lines and equipment; fire; exposure to electromagnetic fields; working in dangerous/ difficult terrain; road safety; and natural risks. The company as part of its ongoing monitoring of its O&M contractors will ensure adherence to GIIP as described in the applicable Environment, Health and Safety Guidelines; ensure usage of appropriate personal protective equipment (PPE) by all contract workers and employees; and enforce adherence to all applicable operational control procedures.



All project developers and O&M contractors will provide requisite training on occupational health and safety to all workers including contract workers; ensure use of appro
priate personal protective equipment and safe work practices. Moreover, prior to commencement of work on transmission line and on testing/commissioning, the project developers and O&M contractors will put in place control procedures including for safe working near live equipment, work permit system, tag out/ lock out procedures and institute training programs on working at height, electrical safety and emergency preparedness and response.

Wind turbines have marginal pollution related impacts. The ambient air quality parameters in the project area are within national standards. A 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 diesel generator 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.



GIL will, implement the traffic management plan and other mitigation measures (e.g. the use of noise barriers at potentially high noise area/locations, use of PPEs, restrictions on traffic movement during night hours, regular maintenance of vehicles, minimizing ground vegetation clearance etc. The noise impact assessment for the 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 20,000 liters per day, and about 1,000 liters per day 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. 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 th
e Hazardous Waste (Management, Handling &Trans boundary Movement) Rules, 2008 through authorized entities. The company 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.

Land disturbances 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 the 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 soil and 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 project will result in a net reduction of greenhouse gas emissions. The company''s combined installed capacity of 182.4 MW of wind turbines at the four sites has the potential to offset in excess of 500,000 tons of CO2 equivalents per year when compared to emissions from fossil based fuel generation. A further offset is anticipated when the proposed 64 MW Rojmal project is commissioned.

Though turbine sites are generally located away from human settlements and other sensitive receptors, adverse impacts on local communities during project construction and operation may include noise, dust, traffic, safety and security. Increase in traffic on village roads is expected at each location. Measures to minimize community health and safety risk have been discussed in the project ESIAs (including traffic planning, managing influx related issues, sourcing water from authorized vendors, appropriate disposal of sanitary wastewater and hazardous waste) and the associated ESMPs (community development, stakeholder engagement). The company, as part of project oversight, will ensure that the project developers and O&M operators at each project location implement the mitigations measures detailed in these management plans.



The O&M contractors at each site will engage private security contractors. At some sites, the security personnel will be armed. The company will ensure that all project developers and O&M contractors will implement the following measures with respect to security personnel: 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; protocol for use of weapons are defined and communicated; 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.

None of the project sites being considered for IFC financing are located within any conservation areas/protected areas/World Heritage sites or Eco Sensitive Zones. No forest land is involved in the right of way (ROW) of the transmission corridor proposed for any of the projects. 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. No known major avian migratory flyway directly coincides with any of the project areas being considered.



However, the Nipanya and Rojaml sites are located close to known bird congregation area with seasonal influx of a large number of birds. The ESIA study for Nipanya and Rojaml sites suggest that these sites do not possess high biodiversity value, with no threatened birds or migratory flyway identified. Despite being a heavily transformed and humanized habitat, certain avian species like soaring birds are highly sensitive to collision. Human-bird interactions may occur in human modified landscapes with birds benefitting and even increasing their numbers because of rubbish dumps, landfills or carcass disposal. A rapid assessment of flying vertebrate species (with focus on birds and bats) suggests that no significant adverse impacts are expected from the project development. However, vultures are a highly threatened species in India and some information has been gathered from Gandhi Sagar Sanctuary, from which birds have been taken for conservation purposes and also territory surrounding Madhya Pradesh in Rajasthan host carrion eating birds. Although there are no trees/cliffs where to breed, movements of such birds exceed tens of km while foraging for food. Although significant impact on birds and bats is not expected based on ESIA findings for either site, GIL will implement specific mitigation, monitoring and management measures outlined in the respective ESIAs for each site and included in the respective ESMPs, and referenced earlier in the document as management system actions.

The company will ensure that the project developers at each site obtain a No Objection Certificate (NOC) from the local panchayat (village level elected self- government).

The ESIA consultants, as part of the impact assessment process, consulted with local villagers at all project locations on the project and their expectations and concerns linked to the installation of WTGs. These consultations included discussions with village representatives, a few land owners, women’s groups and opinion leaders in the 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 members and some impacted households. These consultations suggest that the land purchase (for privately owned land at Parner) 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.

Key concerns and expectations reported in these meetings included increased local employment and contractual benefits and infrastructure development of villages (like drinking water, roads, health care and education facilities. GIL has developed a draft Corporate Social Responsibility (CSR) Policy and Program under which programs with focus on education (distribution of books, stationery, repair of school buildings, etc.), drinking water, rainwater harvesting and basic infrastructure like roads, toilets will be supported at all projects sites in consultation with the local community. The site specific community development/ corporate social responsibility plans will be finalized in consultation with local panchayats, members of neighboring communities and district authorities. Further, each project developer and/ or O&M contractors will implement its own CSR programs.

The ESIAs for all projects include a stakeholder engagement plan as well as community grievance mechanism. The Stakeholder Engagement Plan describes the company’s approach to engaging with the affected communities and project stakeholders and implementation of a grievance mechanism. The stakeholder engagement plan requires all projects to disclose the findings of the ESIA to the community and seek and incorporate their feedback. A community grievance mechanism has been developed as well. The grievance redress mechanism recommends creation of a grievance redressal committee (GRC) with representatives from the contractors and the company. The communities will be informed about the mechanism and the stakeholders will be encouraged to utilize the grievance mechanism to raise their concerns and suggestions. All grievances, their investigation and closeout; and minutes of GRC’s meetings will be documented and shared with relevant stakeholders.

A copy of the Environmental and Social Review Summary (ESRS) and the associated Environmental and Social Action Plan (ESAP) will be made available at the corporate offices of GIL, and at the main entrance of the field offices for Inox, Kenersys and Wind World India located in Dangri, Nipanya, Parner, Rajgarh and Rojmal. Additionally, GIL will post the Environmental and Social Impact Assessments and associated documents for the four projects (Dangri, Nipanya, Parner, Rajgarh and Rojmal) on its web site for public access.

GIL Website: http://www.greeninfralimited.in

URLs for ESIAs
http://www.greeninfralimited.in | Sustainability | Reports

Contact Information
Mr. Nishant Kumar
GIL
Designation, AGM QHSE
Address :- 2nd Floor, Tower ii, NBCC Plaza, Pushp Vihar, Sector-V, Saket, New Delhi-110017
Tel # +91-11-49190500
Fax # +91-11-49190519
e-mail address: mailto:nishant@greeninfralimited.in

Dangri Site Address
Contact Info
Mr. Sunil Basha
GIL
Designation, Manager Projects
Address, Village Dangri, Fatehgarh Tehsil, Jaiselmer, Rajasthan
Tel # +91 7568127223
e-mail address: mailto:suneel@greeninfralimited.in

Nipanya Site Address
Contact Info
Mr. Vinay
GIL
Designation Manager Project
Address, Village Nipanya, Mandsaur, Madhyapradesh
Tel # + 91 9009598817
e-mail address: mailto:vinay@greeninfralimited.in

Parner Site Address
Contact Info
Mr. Pavan
GIL
Designation, Sr.Manager Project
Address, Village, Parner, Ahmednagar, Maharastra
Tel # +91 9527233222
e-mail address:mailto:pawankumar@greeninfralimited.in

Rajgarh Site Address
Contact Info
Mr. Sunil Basha
GIL
Designation, Manager Projects
Address, Village Dangri, Fatehgarh Tehsil, Jaiselmer, Rajasthan
Tel # +91 7568127223
e-mail address: mailto:suneel@greeninfralimited.in

Broad Community Support is not applicable for this project