As per the solar park level ESIA study report, 1500ha land for the solar park was identified from five villages in Gurh tehsil (Badwar, Barsaita Desh, Barsaita Pahad, Etar Pahad and Ramnagar Pahad), Rewa district.  RUMSL along with district administration had identified 1232.697ha (80%) of government land and 302.989ha (20%) of private land, avoiding farm lands under use and physical structures.  As per land use records, the purchased lands are classified as barren rocky, scrub and fallow lands.  Government lands acquired for the solar park was earlier part of a former army firing range that spread over 22,000ha of government land in the region and which was closed in 2002.  

Private lands owned by 462 farmers were purchased by RUMSL.  The private lands were purchased following the “Consent Land Purchase Policy” approved by the Government of Madhya Pradesh in November, 2014 under which the private lands can be purchased only if the owner is willing to sell and provides consent in writing to concerned authority.  The policy also provides for determining the compensation amount as prevailing government guideline rate for the land, value of immovable assets on the land (such as trees, well, house) and an equivalent rehabilitation grant (one-time amount equivalent to the cost of land as per the Collector guideline rate).  The land purchase did not result in any physical displacement (one unused residential structure was paid for as part of the land purchase).   

Discussions with RUMSL and local community members at appraisal indicates that all the land owners have given land on a voluntary basis and there have been no legal cases filed against the land purchase process.  Each village community had organized multiple village level meetings (gram sabha) which were attended by RUMSL, government revenue authorities and land owners concerned to discuss and finalize the modalities of land purchase process.  Considering that 302.989ha of lands were purchased from 462 farmers after getting consent letters signed from each of them, PS 5 is not considered applicable to the project.

PS 6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources) is not applicable because the site is barren and rocky and - based on the site visit observations, solar park level ESIA report findings and discussions with RUMSL and local community members - it is evident that no forest land has been impacted by the solar park project.  Forest resources adjoining the solar park comprise a degraded tract of dry deciduous forest which has been reduced to tropical grassland.   

The solar park site does not fall within a Scheduled Area (Indigenous Peoples lands) as defined in the Fifth Schedule of the Constitution of India.  In the five project villages, the proportion of scheduled tribes (Indigenous people) is 20.9% and scheduled castes (vulnerable people) is 9.7%.  Among the 462 farmers whose lands were purchased by RUMSL, about 5 IPs were identified. However, no lands from indigenous community members have been purchased for Unit III and hence PS 7 is not applicable on the project.  PS8 (Cultural heritage) is not applicable to the project as the site does not contain any archaeological sites or structure that has 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. The project will implement Chance Find Procedure and train its staff with respect to the same.

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. 

The key E&S issues for this project include: cumulative E&S impacts especially on water resources, land, and social aspects due to solar park development; construction phase E&S impacts; procurement and management of human resources including contract workers in accordance with IFC PS 2 requirements through the project life; and occupational health and safety issues during the operational phase.

   Environmental and Social Policy, Assessment and Management System

At the solar park level, RUMSL commissioned an E&S baseline assessment in April 2015 at solar park conceptual stage and an E&S risk identification and assessment (ESIA) study at land acquisition stage. The solar park level ESIA process was undertaken by RUMSLs 3 ^rd  party consultant (AECOM India) between December 2015 and May 2016.  The solar park level ESIA report including E&S Management Plan (ESMP) prepared in May 2016 was shared with all prospective companies that bid for the project including SPPL as part of tender documents.  The solar park level ESIA process was undertaken in line with national regulations, the World Bank operational policies (Bank has funded RUMSL for development of solar park and associated evacuation infrastructure) and IFC performance standards.  The solar park level ESIA assessed: the land purchase process; resource requirements (water, labor, land); E&S baseline (ecology and social aspects) and formulated management plans covering aspects such as: waste; community/stakeholder engagement and grievance redress; occupational health and safety (OHS); construction labor management; disaster management plan (DMP); E&S management plan (ESMP); E&S quality monitoring; inspections, monitoring and audit; and reporting and review.  The solar park level ESIA concluded that no major environmental risks and impacts are associated with solar park development other than generic risks and impacts caused by a typical solar project.  On the social aspects, the solar park level ESIA identified 462 farmers as private land sellers at solar park level with no physical displacement.  The key social impacts of land purchase is the increase in proportion of marginal land owners (land ownership less than 1 ha) among the 462 farmers after the lands were purchased.  The land sellers were not critically dependent on the lands purchased (as the rocky surface did not yield notable harvest and were monsoon fed) but are keen to avail employment and other livelihood opportunities from the project.

At the project level, solar projects in India have been listed under the “white category” of industries that does not require any permitting from environmental regulators and only an intimation report to the concerned State Pollution Control Board (SPCB) shall suffice.  However, the company has retained its pre-bid phase E&S consultant (Arcadis India) to do a project specific ESIA study for the REWA project which is expected to be completed by end of Aug’17 in line with its corporate ESMS requirements.  The project level ESIA will assess: resource requirements (water and labour); regulatory compliance; stakeholder engagement; and livelihood enhancement opportunities available to local community members from the project.

As part of ESAP #1, the company has committed to formulate and implement an E&S Management System (ESMS) in line with IFC PS 1 requirements.  The project ESMS will consist of an Environment, Health, Safety and Social (EHS) Policy, project-specific ESMPs based on the ESIA currently being prepared, with monitoring actions, and an overarching system for reporting and tracking non-compliances. The project will develop its E&S policy based on ACTIS Energy global corporate policies, Indian legislation and IFC PS requirements. The EPC contractors and O&M service providers will be contractually required by the company to align their E&S policies and procedures with the project's policy requirements.

As per ESAP #2, the company will require the EPC Contractor/O&M service provider to formulate detailed management plans and programs based on the solar park level & project specific ESIAs/ESMPs and group corporate ESMS manuals for construction and operational phases. These plans will cover, among others, the following aspects: livelihood enhancement plans for local community members; construction phase traffic management and accident prevention measures; occupational health and safety including risks due to unexploded ammunitions during site clearing work; managing migrant labor impact on local community; pollution prevention and control; water conservation and management; emergency preparedness and response; labor and working conditions requirements; protection of neighborhood forest resources; waste management, including hazardous waste; compliance with national/state environmental laws; security management procedures; community grievance redress mechanism; chance find procedures and environmental  monitoring.  The company will ensure that the EPC Contractor/O&M service provider implements these management plans and programs and is involved in monitoring and reporting on E&S performance through the project life.

Organizational Capacity and Competency

The company /SPV was incorporated in December 2016 and are taking nascent steps to institute an E&S corporate team by September 2017 when E&S Department head is expected to be in place.  The company plans to engage a turnkey EPC contractor to construct the project as well as undertake O&M. During the EPC contract award phase, the company plans to augment its organizational resources by engaging services of an Owner’s Engineer and support from its group company (ACTIS Operations team) resources.  ACTIS operations team that has necessary expertise in engineering, management and E&S governance is expected to help the company and SPV in delivering ESG performance and has already completed a reconnaissance visit of the site.

As part of ESAP#3, the company will identify and entrust responsibility to an adequately trained and qualified Environmental, Health and Safety (EHS) Officer to supervise and manage E&S aspects both during construction and operations at site. This will either be a company employee or contracted consultant part of Owners Engineer team deployed at site. In addition, there will be one site EHS officer for the construction and operation phase contracted to the EPC contractor/O&M provider respectively.  

Monitoring and Review

EHS monitoring requirements will be included in the project level ESMP for the construction and the operations phases of the project.  The EHS officer contracted to the EPC contractor/O&M provider will be responsible for the implementation of the ESMP, including contractor developed management plans and programs, monitoring actions and reporting. EHS Officer of the company/owners engineer will be responsible for supervision of the implementation of the ESMP, including contractor developed management plans and programs, auditing, tracking compliance and reporting. He/she will also be responsible for interfacing with affected villages and responding to any community grievances.

Human Resources Policies and Procedures

The company has about 12 staff at its corporate office and is planning to recruit 7 more in next 3-4 months to set-up new departments such as human resource (HR) and E&S as part of its corporate team.  The company will draw reference from HR management systems and procedures of its group companies (ASL and SPPL) and adopt the same to meet local regulatory requirements. Although priority and preference will be given to land sellers and vulnerable members among the local community, the project envisages a requirement of skilled workers from outside of the immediate project area. A site labor camp will be constructed outside the project boundaries and maintained till the completion of construction phase. 

As per ESAP#4, company will ensure that the HR policy and procedures adopted by the EPC contractor/O&M provider are aligned to meet IFC PS 2 requirements. The HR policies and procedures will stipulate terms of employment such as: wages and benefits; hours of work; overtime arrangements and compensation; leave benefits; and vacation and holidays. Terms of employment will meet national labor law and PS 2 requirements and will be included in employee contracts. Additional workers’ benefits for full-time operations staff will include health insurance and medical assistance, among others. The HR Policy and procedures will include a stated policy on aspects such as: non-discrimination and equal opportunity in recruitment, working conditions (including occupational health, safety and security), equal facilities for men and women workers, employee termination, retrenchment, workers right to organize, collective bargaining rights, prohibition of child and forced/bonded labor, disciplinary action, sexual harassment and a worker grievance mechanism. The HR Policy and procedures will also provide for staff and workers training (induction and recurrent) related to HR, Technical, wildlife protection, and occupational health and safety aspects. The training management systems and procedures will also cover contractual workers and workers hired by third parties.  

Working Conditions and Terms of Employment

As per the ESAP#5, the company will ensure that adequate labor camp facilities and amenities are provided to its workers through EPC contractor, including: adequate living/sleeping facilities and space per person; potable water that meets national standards; safety from wild animal attacks; climate control (if temperatures are high); toilets, washing and cleaning facilities; canteen/mess or fuel for cooking; locker/storage facilities; and facilities for management and disposal of garbage, sewage and other waste. The company will periodically review and monitor the condition of the labour camps.

Occupational Health and Safety (OHS)

Key occupational health and safety (OHS) risks for a PV project include slips and falls, potential hazards from on-site moving machinery, heavy load lifting, exposure to electric shocks and burns, snake and insect bites and safety issues related to PV module assembly. Taking into account the hot and humid climatic conditions at the project site, construction workers might be at risk of dehydration, heat exhaustion and heat stroke if not hydrated properly.  Additionally, the OHS risk due to unexploded ammunition materials during site clearing work could be of significance being an old army firing range site.  As per ESAP Action item #2, company will ensure that the EPC contractor and O&M service provider develop a site-specific OHS procedures for the construction and operations phases as discussed under PS 1. The procedures will be designed to be specific to the PV solar sector (in terms of industry specific hazards) and the project site (unexploded ammunition materials). The OHS procedures will also include project-specific Emergency Preparedness and Response Procedures which will include fire risk assessment and control systems, fire alarm systems and drills, emergency preparedness and planning, wild animal siting, managing unexploded ammunition materials, if found as part of Occupational H&S Procedures for both the construction and operation phases.

The company will also ensure that the EPC contractor / O&M service provider assess and track their OHS performance during both construction and operations. OHS performance evaluations will be carried out and the EPC Contractor / O&M Provider’s EHS Officer will record and track any OHS incidents through an incident tracker and will report on OHS statistics during both the construction and operations phases.

Resource Efficiency & Water

As per company estimates, project water demand will be about 80 kilo liters per day (KLD) during construction phase and 110-160KLD during operational phase.  Company plans to adopt 2 cleaning cycles per month initially as cleaning frequency could affect power generation rate by 2% and will be optimized considering that the site is rocky and barren.  To conserve water and increase power generation, company has plans to explore robotic cleaning in a limited manner in the project due to cost factors.  Robotic cleaning could cut down power generation losses by 0.5%.  At appraisal, RUMSL has identified an abandoned mining pit spread over 4ha land and located within solar park.  It is estimated that the mining pond will be a good source of water for the solar park both in terms of quantity and quality through the project operational phase.  RUMSL plans to construct water distribution pipelines along the access roads to all 3 units.  Additionally, the company is planning to withdraw ground water by digging bore holes within the plant boundary. Besides, the project region receives about 860mm of annual rainfall and the site has favorable topography to store storm water run-off.  Due to rocky terrain, rainwater harvesting is not envisaged.  However, the company will undertake hydrogeological studies and if found suitable RWH plans will be integrated as part of the project.

Solid Waste Management

It is anticipated that project will generate minor volumes of hazardous materials such as transformer oils, dielectric containing material, paints, batteries and generate hazardous wastes such as used oils, waste/residual paint, oil/paint soaked rags/material, filters, empty oil/paint/chemical drum/barrels, used batteries, contaminated soils and absorbent materials.  The hazardous waste will be managed as per company ESMS manual and disposed through authorized hazardous waste management agencies.  Non-hazardous solid wastes such as paper, wood, plastic, scrap metals and glass will be generated during construction phase.  Solid and hazardous waste generated by the project during construction phase will be managed as per detailed management plans and programs to be formulated based on the project level ESIA/ESMP and discussed under PS 1 earlier.   The company will ensure that waste management procedures are integrated as part of the Project ESMS discussed under ESAP Action Item # 2.  Waste management will be a KPI to be monitored during construction and operational phases.

Energy Efficiency & GHG Emissions

As per the estimates of the company, the 250MWac capacity project is expected to generate approximately 526 gigawatt hours (GWh) of electricity per year.As the project progresses based on actual power generation figures, the company will estimate the GHG emissions reduction and report to IFC as part of its annual E&S performance monitoring report  

Pollution Prevention

During construction, a minor and insignificant amount of pollution to air, noise, water and soil is anticipated which will be readily mitigated through standard 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 pollution impact is anticipated. The company will require the EPC contractor / O&M team to implement pollution prevention measures in accordance with their management procedures to mitigate the risk of any pollution as discussed under ESAP Action Item #2.

Though the solar park land is spread across five villages, no residential settlements or hamlets of these villages are located close to the solar park boundary. The nearest residential settlement is few kilometers away from the park boundary. The entire perimeter of the project site will be fenced and entry to the project site will be regulated. The main access road to the project site is the 2-lane, cement concrete paved, National Highway (NH39) connecting Rewa and Sidhi.  Through the project life cycle, internal village roads will not be used due to site location and availability of road access. As part of detailed management plans discussed under ESAP#2, the company will implement appropriate mitigation measures including setting speed limits within the plant boundary, posting of traffic marshals on NH39 and material movement planning to reduce community exposure to traffic safety risks. 

The project will engage unarmed private security personnel through an outsourced agency. 

Based on client review of local social conditions and discussions with key stakeholders (RUMSL and local community), security risks for this project are believed to be low.  However, as part of ESAP Action item #2 presented earlier, the company will ensure that security management procedures are formulated and implemented by the EPC Contractor/O&M team especially with regards to community grievance redress, local traffic management, and job seekers.

Rewa Ultra Mega Solar Limited (RUMSL) along with revenue department established cordial relations with the local village panchayat (local tier of Government) leaders and community members and has been interacting with them on an ongoing basis from November 2015 until the present day (during land purchase process) to reach agreement on land purchase rates and sort out grievances arising out of solar park-related activities.  RUMSL obtained a no objection certificate from the local panchayats for the solar park development. As part of the solar park level ESIA process undertaken by RUMSL, stakeholder engagement and consultations were undertaken between November 2015 and February 2016 through: in-depth interviews with key informants, focus group discussions with local community and individual consultations covering all project villages. The solar park level ESIA process identified and engaged with stakeholders including: head of land seller households; land seller household members; local village community members; local village panchayat leaders; relevant government departments; and RUMSL. 

As the solar park owner, RUMSL will be responsible for implementing and maintaining external communications and addressing any community grievances. The company will co-operate and co-ordinate with RUMSL in addressing any community grievances related to the project as part of ESMP and will institute and operate project-specific community grievance redress mechanisms. The company, working via the EPC contractor, will initiate this community grievance redress procedure prior to the start of construction and constitute a grievance redress committee to look into any project-related 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.  RUMSL has not demanded any commitment from individual project developers in the solar park towards local area development.  However, the company in line with its corporate social responsibility (CSR) policies and programs, will formulate and implement local community development programs.  

In terms of disclosure of project and E&S information, the company as part of the ongoing project level ESIA process will complete additional stakeholder engagement with regulators, state government departments responsible for managing environmental and social resources in the project vicinity, the solar park owner (RUMSL), local government heads, local community members including land sellers, IPs and other vulnerable sections. The local community members and land sellers were well informed of the project and they sought better livelihood and employment opportunities from the project during the consultations. Moreover, the company plans to disclose this IFC ESRS/ ESAP and the project ESIA Reports at RUMSL office and at the company’s site office in the project area.

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

M/s Arinsun Clean Energy Private Limited,

Site Address:

RUMS Pariyojna Unit No. 3

Tehshil Gurh, District Rewa

Madhya Pradesh. Pin code: 486553

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

Mr.CS Anand

Email: csanand@sprngenergy.com

Phone:+91-9049992095