This is a Category B project according to IFC’s Sustainability Policy as the E&S impacts associated with the project are limited, generally site-specific and could be addressed through the implementation of standard good international industry practices.

In the two above-mentioned solar plants appraised by IFC, CMES has purchased lands from private land owners following a willing buyer-willing seller approach wherein lands were purchased on mutual agreement without any obligation or compulsion on the seller.  The company is committed to adopt the same approach in its future solar plants as well.  Considering the approach adopted, it is determined that the requirements of IFC PS5 (Land Acquisition and Involuntary Resettlement) Standards are not applicable to the project.  However, as a good management practice and as part of the agreed E&S Action Plan (ESAP), the company has agreed to formulate and implement a Land Purchase Policy and Procedures that is satisfactory to IFC and in line with the requirements of IFC PS 5 (Land Acquisition and Involuntary Resettlement) and local regulations (more details are presented under PS 1).

In the solar plants appraised by IFC, the plants are not located in or in close proximity of any legally protected areas (such as national parks, wildlife sanctuaries, reserved or protected forests) and ecologically sensitive zones. No significant adverse impacts on fauna, flora or sensitive habitats are expected. Hence, PS6 is not considered applicable to these plants, although it may be applicable to future (yet to be defined) pipeline plants.  With regard to PS7 (Indigenous Peoples), the two plants appraised by IFC will not impact any indigenous people/community and no tribal land is being taken for the development of these plants and their associated utilities. Hence PS 7 is not considered applicable to the plants at this time, although it may be applicable to future (yet to be defined) pipeline plants. No cultural heritage is expected to be adversely impacted at the two plant sites appraised by IFC hence PS8 (Cultural Heritage) is not applicable to the plants at this time. The Company will implement a Chance Find Procedure and train its staff with respect to the same. As a good management practice and as part of ESAP, the company is committed itself to establishing and maintaining a process for identifying the environmental and social risks of its future, greenfield solar plants by undertaking Environmental and Social Impact Assessment (ESIA) studies in line with IFC PS 1 requirements (more details are presented under IFC PS 1). 

E&S Policy, Assessment and Management Systems: Company operations are guided by a Code of Conduct and Business Ethics, a Vendor Code of Conduct, and by a Project & Contractor Management Plan. In addition, as part of IFC’s investment, the company has recently developed an Environment, Health and Safety (EHS) Policy and is in the process of finalizing an Environment and Social Management System (ESMS) aligned with IFC PS 1 requirements, with the assistance of an independent E&S consultant.   The ESMS is an overarching corporate system applicable to all CMES project SPVs incorporated for plant development, operations and maintenance. It will focus on incorporating an E&S screening and impact assessment (ESIA) process in alignment with Indian regulations and IFC Performance Standards, especially for greenfield, ground mounted solar plants. Key elements of ESMS will include among others: a land purchase policy (incorporating land identification and screening procedures; avoid use of intermediaries/land brokers; and management of potential social impacts due to land purchase); construction phase E&S management; occupational health and safety aspects; pollution prevention and mitigation; contractor/vendor management; emergency response; E&S performance monitoring and review systems including contractor oversight procedures; E&S organization; chance find procedures, training and capacity building of workforce on E&S aspects, security personnel engagement procedures and implementation of community grievance mechanisms.

Solar Plants in India have been categorized under the “white category” of industries that do not require any permitting from environmental regulators but only an intimation report to the relevant State Pollution Control Board (SPCB). The company has been managing E&S risks and impacts at its plant sites through: straightforward application of regulatory requirements; evolving better design criteria based on past experience; adopting best in class solar technology; and procuring solar plant equipment’s from globally certified (CE, IEC or UL) solar product suppliers/vendors. In addition, the company commissioned E&S Due Diligence (ESDD) of its greenfield solar plants in the states of Karnataka and Tamilnadu in November 2016 with reference to IFC’s Performance Standards. The ESDD reports prepared by an independent consultant (AECOM India Private Limited) appointed by the company, have recommended Corrective Action Plans for the two plants.  As per the agreed ESAP, the company will complete all action items specified in the CAPs (attached to this ESRS  ) for the respective plants in a time bound manner.

Management Programs: Aside from site-specific technical studies such as topography, and hydrology, company has formulated certain operational control procedures based on E&S aspects and impacts. Currently, operational teams follow the company’s Project and Contractor Management Plan; Safety Rules and Practices; Safety Operating Procedures; and O&M Schedule.  In Karnataka, the SPV has drafted additional documents,  such as a Solar Environment Health and Safety (EHS) Manual; Site Safety Plan; Emergency Response Plan; Operation and Maintenance Protocol; Safety Operating Procedures; a Waste Management Plan; and a Field Quality Assurance Plan.

Organizational Capacity: The company has four functional departments that report to the Managing Director.  All departments are led by well qualified and experienced staff.  E&S aspects are managed under the Projects & Operations Department which is managed by Company’s Chief Operating Officer (COO).  As of November 2016, the company had deployed two staff (at Senior Manager and Manager level) to manage E&S aspects of its plants (including ground mounted and rooftop plants). Both have appropriate experience and qualification to manage E&S aspects in a solar plant.  Land procurement aspects are managed by another staff member and at site level through local intermediaries  . 

Due to the proposed expansion of the company’s footprint through IFC funding, CMES has agreed to strengthen its E&S management team either through additional staff recruitment or through capacity building of company plant and operational staff as part of the proposed ESMS discussed earlier.

 
Monitoring and Review: CMES has developed an internal audit procedure pertaining to health and safety aspects at the plant sites. Site management has also developed monitoring and inspection checklists (e.g checklists for fire extinguishers, PPE, Hydra equipment, JCB vehicles, and Metal Saw machines).  Plant management team prepares daily progress reports and periodic plant status updates and reports the same to senior management of the Company.  Coverage of EHS aspects in the daily progress reports is minimal. The company has agreed to strengthen its corporate E&S monitoring and review system as part of the proposed ESMS discussed earlier. For example, contractors will be required to meet company labor and working conditions requirements and to monitor & report on health & safety statistics during construction.  The company will develop a contractor oversight procedure covering third party EHS audits during construction to ensure compliance with labor laws, IFC PS 2 requirements and ESMS requirements.

As of mid-February 2017, the company had 107 staff  on its payrolls, of which less than 15% were female. In addition, around 200 contractor workers are engaged during peak construction activities in each of the solar plants appraised by IFC. During the operations phase, the company plans to engage about 25-30 employees per ground mounted solar plant, including security personnel, technical staff and those engaged in weed removal and solar panel cleaning. 

Human Resources Policies and Procedures: Company Human Resources (HR) policies and practices are guided by its “Code of Conduct and Ethics”, which lays down various principles required by IFC PS 2 requirements, such as sections pertaining to workforce diversity, equal opportunity, prohibiting discrimination, harassment, child and forced labor, and establishment of working hours and remuneration guidance. The company applies its HR principles and practices to its Contractors through its “Vendor Code of Conduct”, that covers aspects such as the health and safety of workers, environmental matters, compliance with labor laws (relating to child labor, forced/bonded labor, non-discrimination and sexual harassment), and human rights.  These codes however do not cover aspects such as employee grievances redress, recruitment procedures, leave entitlement and maternity benefits for female employees.  As per ESDD report, Company is yet to formulate and develop a comprehensive HR manual covering various aspects required under IFC PS 2.

The company has agreed with IFC to review and strengthen its corporate HR policy and procedures; formulate a comprehensive HR manual and strengthen them as laid out in the ESDD reports and the attached ESAP. It has also agreed to enforce its overarching corporate HR Policies and procedures across all its Plant SPVs and associated contractors, sub-contractors/3rd party vendors. 

Working Conditions and Terms of Employment: Company staff   are provided with a clear terms of employment and working conditions when they are issued an appointment letter. The company complies with local labor regulations and obtains appropriate regulatory approvals as the Principal Employer. Preference is given to local community members. However, when there is a shortfall of skilled workers the company hires them from outside the immediate plant area.  To this effect, labor accommodation camps were set up onsite and few local village houses were also leased for accommodating the outstation staff/workers.  Labor camp facilities were improved based on IFC appraisal feedback specifically at Karnataka site.  Company has also arranged for a food contractor to prepare food off site and supply food onsite during construction phase.   

During operations, most staff will reside in rented accommodation in the nearby village/town.  For managing roof top plants, deployment of staff is less than 5 per site as they can be shared within cluster of neighborhood rooftop sites. 

As per the agreed ESAP, the company will ensure that adequate facilities and amenities are provided in any worker accommodation provided for construction workers (including contractors); this will include 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 any temporary labor camps established at its sites.

Workers Engaged by Third Parties: The company’s Vendor Code of Conduct requires that each vendor/contractor/sub-contractor complies with the provisions of Building and other Construction Workers (Regulation of Employment & Conditions of Service) Act, 1976, providing appropriate PPE to workers and providing adequate training to workers  .  As per agreed ESAP, going forward all vendors, contractors and sub- contractors will comply company’s updated HR policy provisions that are relevant to them, as discussed above.

Occupational Health and Safety: CMES has an Occupational Health & Safety (OHS) and Environment Policy applicable to all its employees, contractors, community and other stakeholders. The policy aims to achieve high OHS standards and a record of ‘zero’ Lost Work Day Case (LWDC) injuries and incidents at each plant. The company will address relevant OHS risks and impacts through its proposed ESMS.  The company will periodically communicate and train its employees, contractors and vendors on its ESMS, Occupational Health and Safety (OHS) and HR policies. 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 as part of the ESMS discussed above.

Greenhouse Gases (GHG): The company plans on commissioning more than 250 MW of solar plants over the next three years.  As per the estimates of CMES, full development of 250 MW solar plants over the next three years will avoid an equivalent of 359,000 tons of CO2 eq/year at the rate of 1,436 tons of CO2 eq/year/MW.

Pollution Prevention: During construction, minor and insignificant pollution of air, noise, water and soil media is anticipated which will be readily mitigated through pollution prevention and control measures.  During the operational phase, other than minor amounts of sanitary wastewater and probable soil contamination near material/waste storage areas, no other environmental impacts are anticipated. Appropriate facilities for collection, treatment and disposal of sewage (septic tank and soak pit) both during construction and operation phases will be provided. Pollution aspects will be managed in line with ESMS requirements discussed under IFC PS 1.

Resource Efficiency and Water Consumption:  Resource consumption in a Solar PV plant is expected to be minimal, with the main resource of note being the water required for cleaning the PV modules.  Company   estimates water requirement at about 6.5 cum/MW/month in its ground mounted sola plant sites and commits to undertake conservation measures as part of the ESMS discussed earlier. Water required will be sourced from onsite bore wells/authorized water tankers.

Hazardous Materials and Waste Management: Solid and hazardous wastes generated by solar plants during construction phase will be minimal.  Non-hazardous solid wastes such as paper, wood, plastic, scrap metals and glass will be generated during construction phase.  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 expected to be generated but not in significant quantities during construction  . 

The company will ensure that all hazardous wastes are handled as per permitting conditions, local regulations and ESMS requirements discussed under PS 1.  Wastes will be: stored separately with adequate containment; handled/used with appropriate care and personal protective equipment; and disposed of through entities authorized to handle and dispose of hazardous waste. The proposed ESMS discussed earlier will address hazardous materials/waste management aspects in line with IFC PS 3 requirements. Waste management will be a key KPI to be monitored during construction and operational phases.

Community Health and Safety: In both the plants sites appraised by IFC, the nearest habitation/settlement is located at about 1 km from the plants site. The company has installed fencing all along its boundary to restrict site access by members of the public. An increase in local road traffic is expected during the construction phase. The company has arranged alternate access roads wherever feasible to mitigate adverse impacts on local communities.  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 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.

Security Personnel: Company has deployed unarmed security personnel at solar plant sites.  Security team engaged by the company is outsourced to security contractors. As part of the ESMS discussed under PS 1, Company will ensure that the past records of such personnel are screened for past human rights abuses; that they have clear objectives and permissible actions laid out in a code of conduct; are trained in avoidance of abusive conduct; that security incidents are recorded, investigated and that corrective actions are implemented; and that there is a community grievance mechanism in place available to any aggrieved members of affected communities or employees, in the event of a violation of the code for security personnel.

At the two plant sites visited, the company’s site management established cordial relations with the local village panchayat (local tier of Government) leaders and has interacted with them to sort out grievances arising out of plant activities  .  Company has also obtained no objection certificate from the local panchayat for the solar plant development.  Company plans to proactively engage with the local community members, local school students, teachers on the plant activities; expectations/concerns if any linked to the development of the plant in particular; and solar plants in general.

The company is yet to establish a formal stakeholder engagement approach and community grievance mechanism system to interact with local communities at its plant sites, though informal methods are being followed.  For example, at the Tamilnadu site, the local community has been approached to relocate a small, religious idol located inside the site boundary. Local communities at the two sites visited have to date reported no grievances against plant activities, as documented in the ESDD reports for these plants.

The company has agreed to develop and implement a fit-for-purpose stakeholder engagement procedures and associated grievance redress approach at each of its sites prior to the start of construction activity. Minutes and proceedings of all meetings held with community representatives will be documented and shared with relevant stakeholders. The company also proposes to develop and implement appropriate community development programs in consultation with affected communities.

In terms of disclosure of E&S information, the company has engaged with local community and disclosed plant related information since the land purchase process for its plants in a limited and as-needed manner.  During ESDD process, the independent consultants engaged by the Company had undertaken stakeholder consultation including local communities.

The company will locally disclose the social and environmental information for the project at the following locations:

1) M/s KAS Onsite Power Solutions LLP
Eluvanampatti Village,
Nilakottai Taluk, Vathalakudu Union, Dindugal District
Tamilnadu - 624 202

2) M/s Harsha Abakus Solar Private Limited
Tondahatti village, ID Halli,
Karnataka – 572 124

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

Mr Nitai Vijay
Senior Vice President – Finance
CleanMax Solar,
1511, Prasad Chambers,
Pandit Paluskar Chowk, Opera house,
Charni Road, Mumbai-400 004

Telephone: 022 - 23676785/ 87/ 88