The portfolio of projects (mainly rooftop and some small-scale ground mounted ones) will be developed on rooftops and open spaces identified and provided by its commercial and industrial (C&I) as well as government clients across India within their property premises.  Considering the nature of proposed projects that would be developed within the client owned buildings and property premises, the application and requirements of IFC performance standards such as: PS5 (Land Acquisition and Involuntary Resettlement); PS6 (Biodiversity Conservation and Sustainable Management of Living Resources); PS7 (Indigenous Peoples) and PS8 (Cultural heritage) is not anticipated at this stage of the project.  The project will, as a part of its environmental and social management systems, assess the application of all IFC PS requirements in each of the individual sub-projects proposed under the Project.

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

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

The key E&S risks identified through the project life cycle include: occupational health and safety risks for workers; procurement and management of human resources including contract workers; waste management; infrastructural design and equipment safety in public buildings such as railway stations; and structural safety of buildings onto which rooftop panels will be installed.

Environmental and Social Policy, Assessment and Management System

Azure Power Global Limited (Azure) has in place an environment, health and safety and social policy and has developed and implemented a corporate wide environment, health and safety and social management system (ESMS). The corporate ESMS is certified to ISO 9001:2008 and ISO 14001:2004 standards since November 2016 and is valid until September 2018.  Azure is committed to ensure that its individual projects (whether owned directly or through SPVs), including those of its subsidiary Azureroof, are constructed and operated in a manner consistent with host country requirements, IFC’s Performance Standards and good international industry practice (GIIP) including those detailed in the relevant parts of applicable IFC’s Environmental, Health and Safety Guidelines.

Key elements of corporate ESMS integrate and meet IFC performance standard requirements including: applicable laws and regulations; social & environmental assessment and management systems; mitigation and monitoring plan; organizational capacity; auditing; training; emergency management systems; community engagement and grievance redressal; labour and working conditions; OHS requirements; and E&S issues integrated in contract documents etc.  Management targets set for current financial year include: minimum number of training programs defined to achieve 5 man-day average training man-hours per staff per year; external benchmarking of E&S performance; minimum number of internal audits; maintaining zero lost time injuries and undertaking ESIA studies for all upcoming projects. 

Azure is currently implementing an E&S Action Plan agreed with other lenders that specifically targets to strengthen existing ESMS elements.  The ESAP focusses on strengthening:  corporate ESMS; permitting and legal compliance; land and community risks; EHS performance; and social performance.  The external benchmarking study commissioned by Azure, through an external E&S consultant, has concluded that Azure's E&S performance has been above industry average on various ESMS aspects and identified two (2) areas for improvement which includes: instituting integrated management systems (IMS) and strengthen contractor management systems.

For rooftop projects, the country regulations and Azure's ESMS does not warrant sub-project specific E&S impact assessment (ESIA) studies.  To manage the risks and impacts in rooftop projects, Azure has formulated a generic E&S Management Plan (ESMP). The rooftop ESMP covers about eight (8) risks and impacts mostly focused on local regulation and practices. 

As part of IFC Project E&S Action Plan (ESAP) #1, company agrees to comprehensively review and update the Rooftop Project ESMP document on following aspects in order to meet IFC PS requirements:

a) provision for site-specific E&S risk assessment audit by in-house experts at project planning and design stage and incorporate site-specific risks and impacts in the generic rooftop ESMP; and

b) Revision and strengthening of rooftop ESMP to cover specific E&S risks such as: occupational health & safety; complying to client’s site specific OHS systems, procedures and regulations; resource efficiency (water conservation); emergency preparedness and response; procurement and management of human resources; E&S organizational capacity in project management team; waste management (during construction and decommissioning phase); infrastructure design and equipment safety addressing community safety aspects especially in public access buildings; review and self-certification of project design and construction by competent senior professionals; assess and mitigate sun glare effect on neighborhood communities; monitoring and review; enhancement opportunities (like rainwater harvesting) and stakeholder engagement and grievance process.

The company has in-house capacity to plan, design, construct and operate and maintain the rooftop projects and will procure specific contractor services during construction and operational phase of the project.  Along with the rooftop ESMP document discussed above, the existing elements of Azure's corporate ESMS will complement the E&S Management of the project and enable it to meet IFC PS requirements on a sustained manner through the project life cycle.

Human Resources Policies and Procedures

Azure's human resource (HR) policies are in line with IFC PS 2 requirements as a result of previous transactions with IFC. The company’s HR policies, systems and procedures are applicable to employees of its subsidiaries, including Azure’s roof division, are made available to all employees and communicated at the time of employee induction.  The HR documents are also posted online in the corporate intranet platform and physical copies are made available upon request.  Induction training focusses on HR systems; anti bribery and corruption; code of business conduct and ethics followed by the corporate.  In addition, training programs targeting behavioural aspects; interpersonal aspects; corporate governance; E&S; and technical aspects are provided to every employee of the corporate and subsidiary levels.  The management target for FY17-18 is to provide 5 man-days of training per staff per year and Azure has achieved 4.75 man-days of training effort in the middle of financial year.

Azure and its subsidiaries also follow a variety of HR management strategies and programs such as: HR connect (every individual staff of the corporate talks to HR personnel once in a year); customer connect; internal (A-News published quarterly with staff contribution to the content) and external newsletters (published quarterly and shared online as well as with customers); all-hands meet (site and corporate teams meet the CEO every quarter); out-bound programs; holiday parties; and CSR programs designed by corporate employees.

Working Conditions and Terms of Employment

About 560 staff are working with Azure and its group companies out of which 54 are contractual staff.  Azure has about 5% female staff in its employee profile and has about 12% annual turnover  rate among its staff. The appointment letter along with HR documents discussed earlier specifies the working conditions, terms of employment and employee grievance mechanism as required under PS 2.  Though HR policy does not prohibit formation of worker unions, there are no workers unions operating in any of Azure subsidiaries.  The rights of workers engaged by third parties are enforced through contractual obligations and managerial oversight during project execution at respective sites.

In the rooftop projects, the company estimates that labour engagement ratios will be: 15 workers per 100kW or per roof during construction phase and 1 worker per 25 roofs/sites during operational phase.  In operational phase, employment is generated specifically for cleaning the modules where the company estimates that 1 worker can clean 500 modules/day.  For 1MW plant with a cleaning frequency of 15 days about 14 man-days of work will be generated in a month. As per the empirical estimates about 30,000 worker man-days of employment will be generated during the construction phase of the 200MW Project and about 170 man-days of employment will be generated every year per MW (34,000 man-days/year for 200MW Project when fully commissioned).

The project plans to utilize local workers during construction and operational phase but also has back up plans for sourcing labour from outside the region in case the labour requirements are not met locally.  However, no labour accommodation is proposed under the project as all the sub-project sites will be in urban areas and the company plans to hire housing units available locally.  As per Azure's corporate ESMS and IFC PS 2, company will ensure that adequate amenities are provided in the hired housing units for construction workers including: adequate living/sleeping facilities and space per person; potable water that meets national standards; toilets, washing and cleaning facilities; canteen/mess or fuel for cooking; locker/storage facilities; and facilities for management and disposal of garbage, sewage and other waste. The company will periodically review and monitor the condition of the labour residential units hired by the contractors (refer to ESAP item #2).

Occupational Health and Safety (OHS)

Azure's corporate ESMS integrates general OHS risk management systems and procedures in a typical solar project.  Review of Azure's HSE statistics reveal that corporate staff have put in 1.92 million man-hours and contractor staff have put in 8.14 million man-hours over the last three (3) years (since FY15-16 to till date).  In the last 3 years, there has been no fatal or non-fatal accidents/incidents, lost time injuries, and fines/penalties imposed due to non-compliances on E&S aspects.

Occupational health and safety (OHS) issues such as: working at height; working on slanted/uneven roof surfaces; handling of sharp objects; working on slippery surfaces; obstructive work area; tripping hazard; structural integrity of roof structures and electrocution hazard are significant both during construction and operational phases of the project.  Specific safety provisions integrated in the rooftop project design and development for ensuring safety of workers during construction and O&M phase by the company include: enforcement of PPEs; display of safety signage’s; installation of fire extinguishers, fire buckets etc; provision of first aid boxes; enforcement of corporate ESMS manual and procedures; formulation of emergency response plan and conduct of regular mock drills; installation of safety lifeline as part of project design; provision of full body harness to all workers; safety net installation; enforcement of permit to work system (especially working at height permit); electric safety by implementation of LOTO; tool box talks before issuance of work permits; close monitoring and supervision of workers during working at height; and safety inspection and internal audit by EHS officer.

As part of ESAP#1, project ESMP will be updated and revised to address OHS issues at client sites.  Company's project personnel will not start work or access any site/ roofs without safety clearances and access permits issued by the client authorized personnel at each of the sub-project sites.  The client authorized personnel at each sub-project site will be consulted and taken along during the initial site-specific E&S risk assessment audit proposed to be undertaken by in-house company experts at project planning and design stage.  Any site-specific safety risks, rules and regulations, strict no-go areas, regulated hours of access, hazardous points/locations, structurally unsafe areas etc. will be identified as part of E&S risk assessment and jointly signed off for its effective implementation.

Resource Efficiency

As per company estimates, project water demand for each cleaning cycle during O&M phase will be about 1.5 liters per module (of 320Wp capacity) which when extrapolated indicates 4.69 cubic meters of water per MW of the project per cleaning cycle. There is no water demand during construction phase except for construction worker’s domestic needs like drinking, cooking, sanitation and bathing.  Depending on the geographical location of the projects and the season of the year, the cleaning frequency varies but on an average each module is cleaned manually once in 15-20 days.  Company is exploring various technological options available for module cleaning to mitigate the safety risks on high rise, slanting roof tops (such as railway stations).  The pressurized water jet systems and automatic wet sprinkler systems (as used in agricultural farms) are being explored to mitigate the safety risks and increase productivity and the company will integrate the same in the rooftop project ESMP discussed under PS1 (refer to ESAP#1). At all sub-project sites, company will source water provided by its clients/site owners.  As a project enhancement measure, company will work with its rooftop project clients to install and maintain rooftop rainwater and storm water runoff harvesting systems that will store rainwater and allow its reuse in cleaning of the panels.  Company will integrate this voluntary, enhancement measure as part of its rooftop project ESMP discussed under PS 1 (refer to ESAP #1).

A group of rooftop projects cumulatively producing 200 MW of electricity is expected to generate approximately 271 gigawatt hours (GWh) of electricity per year which is estimated could off-set CO2-equivalent emissions of 230,702 tons/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.  

Solid Waste Management

It is anticipated that the project will generate small volumes of hazardous wastes, mainly during construction, such as used oils, waste/residual paint, oil/paint soaked rags/material, filters, empty oil/paint/chemical drum/barrels, used batteries, and non-hazardous waste materials.  The hazardous waste will be managed as per Azure ESMS manual and disposed through authorized hazardous waste management agencies.  Non-hazardous solid wastes such as paper, wood, plastic, scrap metals, packing materials and glass will be generated during construction phase.  Solid and hazardous waste generated by the project during construction phase will be managed as per Azure ESMS manual established procedures.  Azure's waste handling procedure specifies percentage of waste recycled as a KPI to be monitored quarterly during construction and operational phases.  During the project life cycle, broken and end-of-life cycle solar panels could be a potential hazardous waste if not stored and handled properly which could lead to leaching of heavy metals. Azure will have arrangement with the suppliers of the solar panel to return the wastes (like broken panels) to their warehouses in India.

Infrastructure and Equipment Design and Safety

According to the Bureau of Indian Standard (BIS) requirements, specifically the National Building Code of India (NBC: 2016), the company is required to incorporate and comply with structural design requirements in the installation of rooftop solar panels.  These national requirements include provisions for structural loads, building materials, and fire and life safety as well as construction management practices and safety.  As the solar panels will be installed and operated on public access buildings such as railway and metro train stations under the project, in line with Section 3.2 of IFC General EHS guideline requirements on structural safety of project infrastructure, the engineers responsible for designing and constructing the project infrastructure including the safety structures/provisions should certify the applicability and appropriateness of the structural criteria employed post the construction phase inspection and prior to commissioning the plant (refer to ESAP #3).  As part of rooftop project ESMP discussed under IFC PS 1, company will document the infrastructure and equipment safety related self-certification issued by its engineering professionals as part of project documents.

As the project activities are confined to clearly demarcated spaces and roof tops inside the client premises, potential impacts to other stakeholders is limited.   The stakeholder engagement will be limited to interactions between Client site/facility management team or client identified management personnel and Azure project management team.  However, in case members of public, including occupants of neighbouring properties or other members of the public, need to contact Azure in relation to any aspect of the rooftop project, the rooftop project ESMP discussed under IFC PS 1(refer to ESAP#1), will include a means for Azure to receive and process inquiries (including complaints) from members of the public and to process those complaints.

The company will publish the IFC project documents (such as this ESRS, ESAP agreed with IFC, Summary of Project Investment) on its website (http://www.azurepower.com). 

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

Company:           Azure Power

Point of Contact Rajesh Puri

Title Sr. VP

Telephone Number 011-49409800

Email Rajesh.puri@azurepower.com

Mailing Address 3rd Floor, Asset 301-304 and 307

Worldmark 3, Aerocity

New Delhi - 110037

Website www.azurepower.com