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
Approximately 390 acres of land is required for the project and its ancillary infrastructure (like the transmission line, access road, pooling sub-station). The land is privately owned and is being/will be purchased from about 140 land owners on a willing-buyer, willing-seller basis at a mutually agreed/negotiated rate. The willing buyer-, willing seller method has been corroborated in the ESIA with the following evidence; a) rates of land offered are higher than the prevailing rates; b) land owner consultations did not come across any evidence of coercion/ threat or negative perception with regard to the land purchase process; c) WTG locations where land owners have expressed unwillingness to sell lands have been excluded from the project and d) the documentation of the land sale deed agreements do not show any significant differential rates for land of similar type/use. Easement rights of land for the transmission line are also being taken on the basis of a negotiated settlement. 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 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 are located in the villages near 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.

If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards (PS).

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. Despite the large size of the project (and as described above) there will be no relocation involved and all land is being purchased on a willing-buyer, willing-seller basis. Furthermore, no significant adverse impacts on bird, bats or Indigenous Peoples have been identified. Key environmental and social issues are expected to include a) ensuring fair labor working condition, occupational health and safety of workforce including contract workers engaged during construction and operation; b) hazard management and mitigation of transportation risks during construction and operation; c) management of environmental and community impacts from noise and shadow flicker; d) management of any impacts on avifauna; e) sedimentation and safe disposal of construction wastes; public safety, dust control and f) effectiveness of the company''s management systems including the internal capacity and staffing to undertake the project in a manner that is consistent with the IFC PSs

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.

Ostro has a corporate health and safety, environmental (HSE) policy, which defines the scope for HSE management at different assets and operations of the company. This policy will also apply to the project companies. In accordance with the requirements of this policy, Ostro has, designed and developed an Environment and Social Management System (ESMS) manual which lays down specific processes and procedures to be followed during the lifecycle (preconstruction/construction/operations and decommissioning) of the projects it undertakes. The environment and social procedures to be followed during planning, construction and operation stages (like site screening / contracting / scheduling / mobilization / operation and maintenance) have been specified in the ESMS manual. The operationalization of the ESMS manual also covers aspects like risk based categorization in line with IFC Performance Standards, requirements for due diligence and environment and social impact assessments (ESIAs) and links it to the decision making process with respect to the specific projects planned to be developed or under consideration by the group company. Systems for ongoing monitoring and reporting (including specific indicators for environment/health and safety/social/labour aspects) have also been outlined in the ESMS. Corporate as well as site level organizational structure along with specific roles and responsibilities have also been provided in the manual. In line with the requirement of the ESMS manual, a qualified EHS personnel has been engaged at the corporate level to oversee and coordinate all activities at the different projects. The ESMS has been adopted and approved by the management and applies to all assets of the group company.

An Environment and Social Impact Assessment (ESIA), undertaken by a third party has been carried out for the project 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 (refer ESAP action #1) based on a) the outcome of the ESIA/ESMP and b) aligned to the requirements of the corporate ESMS. In addition to the mitigation measures delineated and discussed in the ESIA, Suzlon (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. The project 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 in line with the ESMP and the ESMS manual will be developed and implemented by the companies to ensure monitoring and compliance to the requirements.





The ESIA (dated January 2016) 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, wild life protection that will be implemented by the project.

An 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, endemic diseases, 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.



The project 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). The companies 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 redress system/mechanism, c) labour and health & safety related requirements, d) regular training of employees and contractors and e) emergency preparedness and response proced
ures. The companies, 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, refer ESAP action # 6 and 8) will be undertaken to assess compliance to aforesaid requirements. The project will ensure that all applicable clearances, permits, consents, authorization and all regulatory approvals under all the relevant legislation have been obtained prior to commencement of operations.

The companies adhere to the Human Resource (HR) policies and procedures of the holding company; Ostro Energy Private Limited (Ostro). Ostro will undertake a review of its HR policies/systems and procedures and strengthen and upgrade it to meet the PS 2 requirements (refer ESAP action #2). 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.



The project plans to engage an experienced team of 4-5 employees at site during construction and operations phase, supported by around 10 employees based at Ostro Head Office in New Delhi. During construction stage (lasting around 12 months), 100-150 workers will be required on average though at peak construction about 200-250 workers will be deployed by Suzlon. About 20-30 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.



Ostro has a documented guideline for accommodation in labour camps which has been developed with due consideration to IFC guidelines on Labour Accommodation and Building and Other Construction (Regulation of Employment and Conditions of Service) Act, 1996. The company will contractually require its contractors and labour suppliers to ensure strict adherence to the guidelines. This will include contractors engaging 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 including protection against heat/cold and disease carrying animals (e.g. mosquitos).



The contract labour management process developed as a part of the ESMP and the project specific ESMS will be implemented for the project. As a part of the contractor oversight procedures, the companies will review the contractors’ HR policies and procedures and communicate to them specific provisions of its own HR policy and PS 2 requiremen
ts 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 agreed guidelines; workers have access to an appropriate worker grievance mechanism; and migrant workers are engaged on substantially equivalent terms as non-migrant workers performing the same work, all in accordance with Performance Standard 2 provisions. The companies will provide training and capacity building support to the contractors to understand and meet the aforesaid requirements.



The companies will ensure that Suzlon and its sub-contractors fulfill relevant environment, health & safety and labour related obligations/requirements. The company will require its contractors to ensure use of relevant personal protective equipment, implement work permit and tag out/lock out systems or working at height, confined space, electrical works etc, and implement an incident/accident recording/reporting system. It will periodically review OHS performance of the contractor during construction and operation phases. The company will contractually require the contractors to report on OHS, ESMP implementation and worker grievances

Ambient air quality parameters in the project area are well within national standards. Temporary impacts on ambient air quality are expected during construction 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 in the ESIA, 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 one of the 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 existing commercial activity and traffic movement in the area. Major noise sources during construction will include operation of cranes, excavation, movement of construction machinery, operation of generator sets and vehicular movement. 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.



The project will implement a traffic management plan and other noise mitigation measures like use of noise barriers at potentially high noise area/locations, restriction on traffic movement during night hours, regular maintenance of vehicles and minimizing ground vegetation clearance. As a part of its oversight procedures, the companies will undertake six monthly monitoring of ambient noise levels in order to understand the increase in noise levels due to the project operation. The noise impact assessment for the operations phase indicates that no material noise impact on sensitive receptors is expected due to the project and are largely expected to be within the prescribed IFC guideline limits.



The modeling results (including cumulative modelling) for shadow flicker suggest that one turbine locations are likely to result in shadow flicker impacts on nearby sensitive receptors (residential structure located at a distance of about 320 m). The project will revisit the micro-siting of this location 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. Blade glint, blade throw, visual interference and Electromagnetic Fields (EMF) related impacts are not expected on account of the project.



During construction, the project water requirement will be about 65 kL/day per WTG to build foundation of tower and 3-5 kL/day for domestic water use
considering 75 workers during peak hours. In the operational phase water will be needed for the domestic use of project staff at the site, which is estimated to be around 2-3 kL/day considering 35-40 technical persons present on site in shift and about 15 security personnel. 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 of through septic tanks and soak pits. There will be no discharge of waste water to any surface water body. During rainy periods, appropriate mitigation measures to minimize erosion and water pollution will be implemented. No material impact on water resources is expected on account of the project either during construction or operations.



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 in an environmentally safe manner through approved local vendors. 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. The project 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 is securely stored, handled/used with appropriate care and personal protective equipment; segregated; and disposed of in accordance with the waste management plan requirements. The project is expected to result in annual reduction of around 5, 13,600 tons of CO2 equivalent.



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 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 prevention of soil erosion

The turbine sites are located away from human settlements and other sensitive receptors. The planned project equipment, plant and infrastructure meet good industry practice specifications. 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 associated management plans (emergency, community development, stakeholder engagement). The project will ensure that the O&M operator of the wind farm implements the mitigation measures detailed in these management plans. Traffic management measures like movement during day time, speed limits, restricting on honking and driver training will be undertaken. The companies 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. The project 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.



The project will allow grazing activity in most part of the site during operations. 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 temples/mosques in the project area.



The project will employ unarmed private security personnel during project construction and operation. These personnel will be engaged through an outsourced and authorized security agency. The project will require the security agency to implement procedures (refer ESAP action #5) to ensure that: past records of security personnel employed are screened; security p
ersonnel 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 in or adjacent to any conservation areas/protected areas/World Heritage sites or Eco Sensitive Zones. There are no Important Bird Areas (IBAs), wildlife sanctuaries, national parks or bird sanctuaries within 50 km of the proposed project site. No forest land is involved in the right of way (ROW) of the transmission corridor proposed for the project.



The ESIA studies suggest that the project site does not harbor high biodiversity of flora and fauna, including endemic species. No known major avian migratory flyway coincides with the project area. It also suggests that no major change is likely to occur in terms of habitat and foraging/feeding areas for birds as the area is mostly dry/ has sparse vegetation and received very low rainfall. Based on the analysis of the type of farming, variety & growth and ground cover it concludes that no significant loss of habitat, displacement/fragmentation and loss of foraging/feeding areas from this project is envisaged. The site is devoid of large trees, old /abandoned structures, caves, abandoned dug well or similar and hence the presence of bat is not anticipated. The ESIA also suggests that no bats were identified during the field survey or that any suitable bat habitat or roosts were identified. 



Two months of bird monitoring done in the wintering season (October/November) observed 73 species of birds. Of these fifteen of were reported to be migratory and three were identified as Near Threatened species as per IUCN Classification. A collision risk assessment done in the ESIA based on the abundance, general flight height and migratory status of these species assessed the potential impact to be “major” in the case of nine of these species of bird. However, none of these species fall in vulnerable, endangered or critically endangered conservation categories. The ESIA has identified and established 19 turbines as vulnerable to “collision risk”. The project has, based on recommendations of the ESIA, shifted the location of 7 of these turbines and decided to have alternate locations with another 6.



Although the ESIA does not assess any significant impact on birds and bats based on desktop review and two months of winter monitoring and analysis, the companies will undertake and implement a monitoring programme with the help of qualified experts to establish a more robust baseline and assess in detail impacts and risks to avifauna due to the construction and operation of the project (refer ESAP action #3). The project is planned to be developed in phases over a period of 12 months. The monitoring activities undertaken during this period will help to build in mitigation measures prior to start of full operations. Furthermore, the mitigation measures listed in the ESIA (e.g. painted tip blades, removal of carcass/dead animals, regular checking of towers) will be implemented by the project. The project will also train staff on undertaking bird/bat strike monitoring, monitor the
water bodies (in the monsoon and winter season for bird activity) and if, the proposed monitoring program indicates significant activity or/and bird/bat strikes, implement measures (within 6-8 months of commissioning) as recommended by ornithologists/wildlife specialists to address the impacts, including, if required, a targeted shutdown (curtailment) protocol and enhanced collision monitoring program

The proposed project is located in land associated with/belonging to eight villages which are spread out in three Mandals (tehsil) - Kambadur, Kanaganapalle and Ramagiri of Anantapur district in the state of Andhra Pradesh. The ESIA consultants, as part of the impact assessment process, consulted in October-December 2015 with local people in all these eight villages. These consultations included discussions/meetings with village representatives, select 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 elders, land/revenue officials and some impacted households. These consultations suggest that the privately owned land purchased was being acquired on a willing-buyer, willing-seller basis and that the rates of compensation offered were more than the prevailing 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 includes a stakeholder engagement plan, which proposes a stakeholder/community engagement strategy/programme for the project. As a part of the ongoing engagement process the companies will a) disclose the findings of the ESIA (and the ESMP) to the community/stakeholders (refer ESAP action #4), and (b) seek and incorporate their additional 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.

The project will begin implementing 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 any 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

Project Office:
Mr B Prabhakar Naidu, S/o Mr Krishnaiah,
Main Road, Vepakunta village & post Kanaganapalle Mandal
District- Anatapur
Mr. Chetan Meshram
HoD- ESG
Unit G-0, Ground Floor, Mira Corporate Suites,
1&2 Ishwar Industrial Estate, Mathura Road, New Delhi. Phone No: +91-9818424532

Broad Community Support is not applicable for this project

Ostro Andhra(37086) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Developed and implement a project specific Environment and Social Management System (ESMS) for construction and operation phases covering (but not limited to) the impacts and mitigation measures delineated in the ESIA and ESRS	15-Mar-2016	Completed	Completed	1/20/2016
Align its Human resource Policies and Procedures to PS2 requirements. Develop and implement appropriate contractor oversight procedures to ensure compliance to labour laws and other E&S requirements as detailed in the ESRS	31-Mar-2016	Completed	Completed	1/28/2016
With an objective to assess impact on birds/bats: a.) Finalize ToR and appoint a consultant to conduct avian monitoring program (for construction and operation phase) for two years. In the event of significant bird/bat strikes, implement mitigation measures recommended by independent experts to address the impacts (within 6-8 months of the commissioning of the project (to be completed by 03/15/2016); and b) Identify two in-house staff for training and monitoring (to be completed by 04/15/2016);	15-Apr-2016	Completed	Completed	1/18/2017
Disclose the ESIA and implement a Community/Stakeholder engagement and grievance redress process in consultation with the community/stakeholders;	31-Mar-2016	Completed	Completed	5/15/2016
Put in place security personnel procedure as described in the ESRS and consistent with PS4 provisions	30-Jun-2016	Completed	Completed	6/30/2016
Appoint an external qualified third party consultant to undertake an Social, Environment, Health & Safety and Labour Audit during the construction phase to assess compliance with ESMS and agreed ESAP requirements	31-Mar-2016	Completed	Completed	10/30/2016
Submit an Environment, Health & Safety and Labour Audit report during the construction phase to assess compliance with ESMS and agreed ESAP requirements	31-Oct-2016	Completed	Completed	12/30/2016