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.   

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.

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 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 ESIA process was undertaken by RUMSLs 3rd party consultant (AECOM India) between December 2015 and May 2016.  The solar park ESIA report including E&S Management Plan (ESMP) prepared in May 2016 was shared with all prospective companies that bid for the project including MRPL as part of tender documents.  The solar park 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 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 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 ESIA identified 462 farmers as private land sellers with no physical displacement.  The key social impacts of land purchase are 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.

MRPL has instituted an integrated management system (IMS) covering quality, environment and health & safety aspects since November 2013 and are certified to ISO/OHSAS standards (ISO 9001:2015; ISO 14001:2015 and OHSAS 18001:2007) till November 2019.  The IMS consists of: company policies for managing environment, health & safety and corporate social responsibility (CSR) aspects in its project activities; E&S management targets for FY18 through FY20; sustainability council at COO level; operational control procedures; and an organizational structure both at corporate and project offices.  The operational control procedures cover the requirements of IFC PS 1 such as: identification of risks and impacts through E&S impact assessment (ESIA) and hazard identification and risk assessment (HIRA) processes; formulating site specific E&S management programs/plans (ESMP); deployment of appropriately trained and qualified staff to manage E&S aspects at site; ensuring legal compliance; emergency preparedness and response; monitoring and review mechanisms; and stakeholder engagement and grievance redress mechanisms.  

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. Hence, as part of IFC investment and as per the agreed E&S Action Plan (ESAP), the company will formulate detailed E&S management plans based on the solar park level ESIA/ESMP and corporate IMS manual for construction and operational phases. These plans will cover, among others, the following aspects: livelihood enhancement plans for local community members including IP members (refer to discussions under PS7); 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 with specific focus on IP community (refer to discussions under PS7); chance find procedures and environmental  monitoring.  The company will ensure that the sub-contractors/O&M team of Mahindra Susten implements these management plans and programs and is involved in monitoring and reporting on E&S performance through the construction and operation phase respectively.  

Organizational Capacity and Competency

The company has instituted corporate level E&S and safety teams that own and operate the elements of IMS across the company operations.  At project level, each construction team is supported by a team of environment, health and safety (EHS) staff who also reports to corporate teams in parallel.  The EHS staff currently engaged by the company appear to be well qualified and to have adequate experience.  During O&M phase, the O&M team is trained to manage EHS risks and impacts and no exclusive EHS staff are deployed.  The corporate E&S and safety team is responsible for managing E&S aspects and providing support to the O&M team through the project life cycle.  

Monitoring and Review

Company senior management undertakes periodical EHS performance reviews of all the projects in a pre-fixed time schedule.  The IMS manual provides for internal auditing once in a year by corporate team across all company sites.  At site, EHS staff is responsible for: daily and weekly site walk through audits; tool box talk; monitoring HSE incidents and records; continual improvement system and following up weekly safety report observations.  Company has been publishing corporate sustainability reports in line with Global Reporting Initiative (GRI)  (http://www.mahindrasusten.com/philosophy.php#reports-policies) since FY2015. 

Human Resources Policies and Procedures

There are 569 staff on company rolls (14% company staff are females) and 249 staff on third party contract rolls. In total about 1615 staff (5% female) are employed across company offices and project sites.  The company’s HR management systems and procedures comply to IFC PS 2 requirements. Some of the HR initiatives are briefly presented below.

Company has instituted systems and deployed IT tools for 24×7 reporting of employee grievances. A WhatsApp number for registering any grievances or discriminatory treatment has been propagated.  Every staff is encouraged to report any grievances or uncomforting incidents and the system assures for complete anonymity and confidentiality. Per company’s sustainability report for FY17, about 560 grievances were received in FY 2016-17 and about 87% were resolved within 3 working days.  Besides, company also engages with its staff through periodic engagement tools like SUSTENx and the Communique.

Company’s HR policies with its Year 2020 mission to become preferred employer of choice provide for: biometric attendance system to reflect accurate working records and overtime capture; employee health and wellness; HR Council; diversity and inclusion; initiatives for differently abled; annual health check-up; personal accident insurance policy; mediclaim policy; life insurance policy; critical illness cover; nutritionist consultation; employee benefits; employee assistance program; policy on prevention of sexual harassment; learning and skill development; and annual reward and recognition programs.

Working Conditions and Terms of Employment

During the project implementation, the company estimates that about 500-550 strong workforce (peak labor demand) will be required during construction phase.  During the operational phase about 65 technical staff (Plant Head, Project Leads, Engineers and Technicians) on full time basis and 100 solar panel cleaning staff on part time basis  will be required.  The Mahindra Susten (O&M Contractor) will have its own operational team ..  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 especially during construction phase. A worker accommodation camp with capacity to house 200 workers will be constructed within the project boundaries and maintained till the completion of construction phase.  

The working condition and terms of employment, worker organization, non-discrimination and equal opportunity, retrenchment, grievance mechanism, prohibition of child and forced labor provisions as required under IFC PS 2 are covered and satisfactorily meets the requirements.  However, as per the ESAP #2, the company will ensure that HR management systems and procedures of its contractors and their sub-contractors is compliant to its corporate HR management systems and procedures. This will include, amongst other items, prevailing labor law compliance, mandatory minimum wages and social security schemes for each staff; worker grievance mechanism that caters to both contractor staff and company employees. 

As per the ESAP #3, the company will contractually ensure that adequate worker accommodation facilities and amenities are provided onsite by the EPC contractor to its workers in line with IFCs worker accommodation standards (Refer:http://www.ifc.org/wps/wcm/connect/9839db00488557d1bdfcff6a6515bb18/workers_accomodation.pdf?MOD=AJPERES&CACHEID=9839db00488557d1bdfcff6a6515bb18)    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 worker accommodation camp.

Occupational Health and Safety (OHS)

As discussed above, company has instituted OHS management systems and procedures in line with OHSAS 18001 requirements.  IFC reviewed company’s OHS management systems and procedures as part of the project appraisal and it is found to comply with IFC PS and General EHS guideline requirements. OHS incident statistics reported in the sustainability report for FY17 indicates that company has cumulatively achieved 12.5 million safe man hours without a lost time incident and 7,877 near misses since its inception covering all project sites and offices of the company till FY17.

As part of emergency planning and response (ERP), company under the OHS systems and procedures establishes ERP systems that includes: site specific emergency response plan, emergency key person team, emergency response training, mock drills, 24x7 ambulance provision, 24x7 resident medical practitioner (RMP), hospital tie-up and emergency evacuation plan.  

The project site being former army gunnery training site concerns regarding unexploded ammunitions was reported during local community consultation process.  Though the safety risk is reportedly minor, as part of ESAP #1 discussed above, company will review and update its occupational health and safety management systems to include risk mitigation measures to address unexploded ammunitions encountered if any during site clearing and foundation work.

Water Resource

Company has instituted water consumption monitoring mechanism at every project site.  Based on the data available on water consumption, many water conservation and augmentation efforts have been implemented across its project sites.  Company has explored the use of water injection wipers instead of conventional jet sprays and dry cleaning method with nylon sponges to reduce water consumption during solar cell cleaning cycles which has resulted in overall reduction in specific water consumption at 46% as on FY17 per its sustainability report.

As per company estimates, project water demand will be about 30 kilo liters per day (KLD) during construction phase and 350 KLD during operational phase depending on rate of cleaning cycles adopted per month.  Company plans to install pressurized module cleaning system with a cleaning frequency of: 3 cycles per month during summer months (Feb to Jun); 1 cycle per month during monsoon season (July to Aug); and 2 cycles per month during winter season (Sept to Jan).  As the site is rocky and barren, cleaning frequency could be still optimized to conserve water resource.  

the project region receives about 860mm of annual rainfall and site has favorable topography to store storm water run-off.  Due to rocky terrain, rainwater harvesting is not envisaged.  However, company will undertake hydrogeological studies and if found suitable RWH plans will be integrated as part of the project.  

Solid Waste Management

Company follows an integrated waste management approach and has implemented zero waste to land fill approach including hazardous wastes.  The waste streams are segregated into ferrous, non-ferrous & organic wastes and managed individually to achieve the goal of zero waste to land fill. The organic wastes are composted through onsite organic composter machines mobilized at site. Wooden packaging wastes are being used to manufacture school furniture under company’s CSR programs starting from FY18.  

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 IMS manual and disposed through authorized hazardous waste management agencies.  Non-hazardous solid wastes will be managed as per company’s integrated waste management procedures described above. 

Energy Efficiency & GHG Emissions

Per the company’s FY17 sustainability report, through renewable energy projects executed and operated by the company, about 452 million units of electricity has been generated in FY17 which has avoided emission of 0.47 million tons of CO2 which would have been generated from coal fired thermal power plants for generating equal amount of electricity. 

Company has commissioned WRI (World Resource Institute) for monitoring Scope I, II and III emissions. Mahindra Susten in its commitment to become a carbon neutral company has implemented several initiatives for reduction in energy consumption including: internal benchmarking and capacity optimization of DG sets, opting for grid connectivity

at early stage, system design changes for reduction in transformer loss, 100 % LED

lights installation, design and usage control of HVAC systems, Go Paperless mission and diesel

benchmarking (resulted in 40% reduction of diesel consumption).

In the Rewa project, Company estimates that the 250MWac capacity solar project is expected to generate approximately ~535 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

Company undertakes ambient environment monitoring across all its project sites to assess the background environmental quality and effectiveness of pollution control measures.  As per company’s IMS, ambient monitoring program covers: ambient noise monitoring, DG stack emissions, ambient air monitoring, temperature monitoring, vehicle & equipment monitoring (PUC) and drinking water quality testing.  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 its IMS manual to mitigate the risk of any pollution as discussed under ESAP Action Item #1.

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, 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 #1 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.

The solar park site does not fall within a Scheduled Area (Indigenous Peoples (IP) lands) as defined in the Fifth Schedule of the Constitution of India.  The total population in the five project affected villages is 10,285 as per 2011 census which is 8% of Gurh tehsil population and 0.4% of Rewa district population.  In the five project villages, the proportion of scheduled tribes (IP) is 20.9% and scheduled castes (vulnerable people) is 9.7%.  Among the five villages, IP community predominantly lives in Etar Pahad (53.80% of total population) followed by Badwar (9.98% of total population).  

Among the 462 farmers who sold their lands for solar park project, 5 IP community farmers were identified as land sellers.  The solar park ESIA report has documented that: the IPs in the villages do not practice any distinct beliefs; had legal title to the land parcels owned by them and have merged with the mainstream community and live together.  From the census survey undertaken during ESIA process it was assessed that IP community members are not economically or physically displaced and not adversely impacted by the project.  The solar park ESIA has also recorded that adequate consultation and engagement was undertaken with the IP farmers regarding the project plans, extent of land required and compensation amount details prior to obtaining their consent.  The 5 IPs provided their land voluntarily after giving consent in writing to government authorities and received compensation amounts like other land sellers.  

No requirement for Free, Prior and Informed Consent has been identified because the solar park ESIA has documented that there are no project-related impacts on common property resources that were subject to traditional ownership or under customary use of Indigenous Peoples community; there is no physical relocation of Indigenous Peoples from lands and natural resources subject to traditional ownership or under customary use; and there are no impacts on critical cultural heritage that is essential to the identity and/or cultural, ceremonial, or spiritual aspects of Indigenous Peoples lives; and the project does not intend to use the cultural heritage, including knowledge, innovations or practices of Indigenous Peoples for commercial purposes.

As part of project level ESMP required under ESAP#1, the company will formulate and institute grievance redress mechanism with specific focus on IP and other vulnerable community members in the local community.  Company will formulate and institute sustained engagement and consultation mechanism with IP community members through the project in line with Para 10 of PS 7 regarding project activities, grievances, livelihood enhancement opportunities available from project activities and community development requirements under company CSR programs.

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 to reach agreement on compensation 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 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 affected villages. The solar park ESIA process identified and engaged with stakeholders including: head of land seller households and their family 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. However, the company will also institute its community engagement & grievance mechanism procedure as outlined in its IMS manual and the company HR management staff at site will be made responsible for the same.  The grievance redress cell at project site will co-operate and co-ordinate with RUMSL in addressing any community grievances related to the project. Minutes and proceedings of the meetings of this grievance cell 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 project execution, 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 IFC ESRS/ ESAP and project related E&S reports at RUMSL office and 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 Mahindra Renewables Private Limited

Site Address:

RUMS Pariyojna Unit No. 1, Tehshil Gurh

District Rewa, Madhya Pradesh - Pin code: 486553

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

Company   Mahindra Renewables Pvt Ltd

Point of Contact   Roshan Gandhi

Title   Director

Telephone Number   +91 22 6174 1529

Email   GANDHI.ROSHAN@mahindra.com
? Mailing Address   6th  Floor, Lok Bharati Complex, AFL House, Marol  Maroshi  Road, Marol, 

Andheri (E), Mumbai 400059, India

Website   www.mahindrasusten.com