PS7: Indigenous Peoples does not apply because there are no communities of Indigenous Peoples in the project area.  The district (Bikaner) where the project is located is not a tribal area and does not have any significant presence of tribal communities. The same was confirmed by IFC E&S consultants through community consultations.    

PS8: Cultural Heritage does not apply because there are no (i) tangible forms of cultural heritage; (ii) unique natural features or tangible objects that embody cultural values; or (iii) instances of intangible forms of culture found or proposed to be used in the project area.  However, the project will develop a Chance Finds Procedure as part of its ESMS to address any encounter of archaeological / cultural artifacts.           

  This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability due to the potentially limited adverse environmental and social (E&S) risks and impacts that are generally site-specific, largely reversible, and readily mitigated through implementation of good international industry practices. Most of these E&S impacts occur only during the brief construction period. For example: air quality and noise impacts, community safety impacts from the temporary influx of project vehicles and non-resident workers, occupational health and safety (OHS) risks for workers, contractor management, resource efficiency, and waste management. During operations, the main risks and impacts are related to stakeholder engagement and biodiversity management – especially monitoring and mitigating potential soaring bird collisions with the transmission line.                                                  

  Enel S.p.A (“Enel”), owner of Enel Green Power, India (EGP India), is a global company specializing in the development, design, construction, and operation of power project including renewable energy (RE) projects and transmission and distribution networks. Enel commitments to effectively assess and sustainably manage the environmental and social risks and impacts of their operations are evident from the corporate policies, organizational capacity, and management systems and programs that they implement in their business activities. However, the Engineering Procurement and Construction (EPC) contractor (Siemens Gamesa) will be responsible for implementation of all E&S requirements at the project site. An Operation & Maintenance (O&M) contractor will then take over post commissioning. The remaining paragraphs in this section summarize how Enel use their Environmental and Social Management System (ESMS) to avoid, minimize, and/or mitigate the main project associated E&S assessment and management related risks and impacts.  

Policies: Enel E&S policy commitments are reflected in the following five key documents: i) Health, Safety and Environment, Quality & Energy Policy (HSEQ Policy) ii) Code of Ethics, iii) Policy on Human Rights, iv) Zero Tolerance of Corruption Plan, and v) Enel Global Compliance Program. These policy instruments identify environmental management, social responsibility, and health and safety in the workplace as key corporate priorities. They also assign clear institutional responsibilities and are formally endorsed by their Board of Directors and senior management. These commitments and responsibilities apply equally to all employees of Enel and its subsidiaries. Enel’s contractors, suppliers and commercial partners are also required to comply. IFC considers these policies to be appropriate for the nature and scope of this project, and consistent with PS1. The contract between the project company and the EPC contractor says that the EPC will follow Enel’s policies, and ensure that the sub-contractors engaged are also made responsible for policy compliance.

Identification of risks and impacts: As per the current Indian national and state regulatory frameworks, solar power generation through photovoltaic cells is exempt from Environmental Impact Assessment (EIA) notification, and therefore not required to obtain an environmental clearance (EC). Furthermore, as solar power is classified as a “White” industry, the project is not required to obtain either Consent to Establish or Consent to Operate. Despite not being required under India law, Enel’s Environment Archaeology and Biodiversity (EAB) department are responsible for preliminary internal screening and recommendations for additional studies, as needed. For this project Enel contracted the Environmental and Social Impact Assessment (ESIA) disclosed with this ESRS. IFC considers this ESIA to be consistent with IFC E&S Performance Standards. EAB also evaluates the qualifications and performance of sub-contractors who produce these additional studies, for example Environmental and Social Impact Assessments (ESIA), Critical Habitat Assessments (CHA), etc.

Due to the proximity of three additional solar plants within 10 km of the project site, IFC also reviewed EGP’s assessment of the project’s likely cumulative E&S risks and impacts. Although these cumulative impacts from the combined effects of all four existing or planned solar projects are unlikely to be significant, this will be confirmed as part of ESAP#1. For example, water is scarce in the region, but the EGP project is planning to use water delivered by authorized tanker trucks during construction and use dry robotic cleaning during operations. Cumulative impacts on access to land and agricultural livelihoods are also not significant, as poor soil conditions and unpredictable monsoon rains have left most people increasingly dependent on nonfarm livelihoods. Cumulative impacts on biodiversity from the new transmission line will be mitigated through management of animal carcasses in the landscape, the use of bird diverters to reduce risk of electrocution. Cumulative impacts are also expected to be positive. For example, local people have acquired many skills to work in construction and maintenance operations, and income revenues from employment in the local solar sector are financing investments in other commercial and productive activities.

Management programs: EGP has established an integrated management system (IMS) with various standard operating procedures (SOP) covering environmental, social and human resources issues. Enel corporate and its subsidiaries are certified to ISO 9001, ISO 14001 and OSHAS 18001 standards. Certifications for the Thar project site will be obtained post commissioning of the power plant. Key site level programs to be developed by the EPC and O&M contractors with Enel’s support include: i) Stakeholder Engagement (ESAP#9), ii) Emergency Preparedness and Response (ESAP#2), iii) Grievance Mechanism for Workers (ESAP#3), iv) Worker Conditions and Terms of Employment (ESAP#4), v) Traffic Management (ESAP#5), vii) Livelihood Restoration (ESAP#6), and vii) Biodiversity (ESAP#7-8). Additional details about why these programs are needed and what they should include are provided in the applicable Performance Standard (PS) sections of this ESRS that follow.     

Organizational capacity and competency: Enel assigns E&S responsibilities for each project across various departments at the global, country and project levels. For example, at the global level, the Sustainability department support Business Development, Engineering and Construction, and Operation and Maintenance departments through project level Social, Environmental, Economic Context Analysis (SEECA). EGP prepared a SEECA to inform the Creating Shared Value (CSV) vision for the project and developing a site-specific CSV plan, and Sustainable Construction Site Plan.  Enel human resources related functions, including defining employee rights and obligations, performance evaluation, training, etc. are managed by the People and Organization department.

At the project site, E&S responsibilities are vested with the EGP Construction Site Manager, supported by the Site EGP Health, Safety, Environment, and Quality (HSEQ) Officer, as well as national and global Enel HSEQ and Sustainability staff. The on-site EGP HSEQ officer also supervises EPC and sub-contractor HSEQ teams.               The EPC contractor will appoint a HSEQ specialist who will report to the site manager of EGP. The site manager will in turn report back to the Project Manager at the corporate level. IFC considers EGP E&S capacity and competency to be appropriate for nature and scope of this project, and consistent with PS1.     

Contractor management: Given the turnkey nature of the project, the project company will ensure that the EPC and O&M contractors develop all required site-specific management programs and plans to build and operate the project in a manner consistent with IFC E&S Performance Standards (PS) (ESAP#1). The contract between the project company and the EPC contractor says that the EPC will follow EGP policies, and ensure that the sub-contractors engaged are also made responsible. In addition to this, the Health, Safety and Environmental Terms (the “HSE Terms”) which govern the parties (project company and EPC Contractor) obligations in connection with health, safety and environment matters has also been added to the contract. The HSE terms provide significant health, safety and environmental aspects that the contractor and  subcontractors will address during their activity on behalf of EGP/project company and develop a suitable and sufficient HSE documentation, identifying the health, safety and environmental measures to be implemented during different project phases.

Emergency preparedness and response (EPR): EGP have an effective corporate EPR program for handling emergency situations like fires, serious accidents, earthquakes, etc. However, the guidance and response measures provided in this corporate program have not been sufficiently adapted to the Thar project context and location. For this reason, the project company will ensure that the EPC and O&M contractors develop site-specific EPR plans for construction and O&M phases (ESAP#2).

Monitoring and review: Different Enel departments and committees monitor and evaluate different elements of their business practices as part of a systematic approach to continuous improvement. For example, all contractors & subcontractors undergo Health, Safety, Environment, and Quality (HSEQ) evaluations & approvals before their onsite engagement. If they pass this evaluation, contractors are legally obliged to conduct daily inspections as required by the activities of the workplace to identify potential hazards, and to share this information with EGP onsite and compliance teams. EGP then performs monthly joint audits with checklists based on submitted information from the EPC to monitor contractor performance and ensure compliance. The contract between the project company and the EPC contractor requires the EPC to follow all EGP policies and programs, including monitoring and evaluation measures. The Enel Control and Risks Committee also monitors implementation of the Code of Ethics by reviewing periodic reports prepared by the Head of the Audit Function and submitting any modifications or additions to the Code for the approval of the Enel Board of Directors.                                                 

  Enel has many comprehensive labor and working conditions related policies and programs. These cover everything from workplace harassment and childcare support, to occupational health and safety and leadership training. IFC considers these policies to be appropriate for the nature and scope of this project, and broadly consistent with PS2. This section summarizes the key elements of EGP’s approach to managing the project labor and working conditions related risks and impacts. The contract between project company and the EPC contractor requires the EPC to follow all EGP policies and programs, including for labor and working conditions. 

HR policies and procedures: As mentioned briefly above under organizational capacity, Enel human resources functions, including defining employee rights and obligations, performance evaluation, training, etc., are managed by the People and Organization (P&O) department. The P&O department at the national level works to ensure that Enel HR policies and procedures are understood and adopted at the project level. For example, Enel Code of Ethics requires that the conduct of all its subsidiary enterprises, as well as its primary suppliers, comply with the general principles of the Code. Enel policy on Human Rights is based on the United Nations Guidelines on Business and Human Rights. This policy also sets out the human rights commitments and responsibilities that apply to both employees of Enel and of its subsidiaries, and promotes respect for the policy among contractors, suppliers, and commercial partners in its business relations.

Working conditions and terms of employment: Enel personnel are hired with regular employment contracts. No forms of irregular employment are tolerated. At the time the employment relationship is established, each employee receives accurate information regarding the characteristics of the function and the tasks to be performed. Written contracts specify the rules of employment and salary considerations, as governed by national collective bargaining agreements, and regulations and procedures to be adopted to avoid possible health risks associated with his or her duties. In the unforeseen event that contractors decide to provide worker accommodations, these will be consistent with IFC worker accommodation guidelines (ESAP#4).

Workers’ organizations: Consultations with EGP site representatives indicated that there will be no restrictions on workers to form or join any trade union or similar organization. EGP management is also committed to collective bargaining approaches with workers to address matters of mutual concern.

Non-discrimination and equal opportunity: In decisions that influence relations with its stakeholders and personnel, selection and management of suppliers and partners, relations with the surrounding community and the institutions which represent it, Enel avoids all forms of discrimination based on age, gender, sexual preference, health, race, nationality, political opinions or religious beliefs. This position is stated clearly in the Enel Code of Ethics that also applies to EGP contractors and suppliers. Staff and contractors will receive training on Gender Based Violence (GBV), and the Grievance Mechanism will have the capacity to manage any such complaints. 

Grievance mechanism: Peak construction workforce is expected to reach 400 staff and contractors. Much of this labor supply, especially for low and semi-skilled jobs, will be drawn from the surrounding villages and towns. EGP does not currently have a grievance mechanism for the project workers (and their organizations, should they exist) to raise workplace concerns. The project company will therefore ensure that the EPC and O&M contractors develop and implement grievance mechanisms for workers during the construction and O&M phases (ESAP#3). This mechanism will allow for anonymous complaints to be treated confidentially, provide timely feedback without retaliation, and be communicated and accessible to all workers, including those employed by subcontractors.

Protecting the work force: EGP have several measures in place to prohibit the engagement of child or forced labor at the project site. These include – review of workers identity documents at the entrance gate, frequent audits of the site for labor, ethics and human rights compliance, and contractual obligations for the EPC and O&M contractors to implement and report on their compliance with these policy and program commitments.

Occupational health and safety: EGP have a well-resourced integrated system for managing workplace health and safety. Core elements of this management system include continuous risk analysis, technological innovation, design and supervision of work process methodologies, and communications and training. Contractors are required to have weekly Health, Safety and Environment (HSE) meetings with EGP HSEQ staff and subcontractors’ HSE representatives. EGP reviews all contractor Safe Work Method Statements (SWMS) prior to authorizing the related actions to begin. HSE inductions are mandatory for all, including visitors. All HSE observation & incidents are digitized and reported through the HSEQ4U app.

EGP program to minimize workers risk of infection with Covid19 includes good practice mitigations like: formation of an onsite Covid19 task force, mandatory use of new Personal Protective Equipment (PPE), enhanced cleaning and disinfection standards, and ensuring social distancing in the workplace, transportation and accommodation settings, among others.                                                 

  The Environmental and Social Impact Assessment (ESIA) for the Thar solar project found that it is expected to produce limited amounts of emissions and wastes, primarily during the brief construction period. Temporary impacts on air quality are primarily linked to site preparation activities and vehicle movements. Mitigation measures proposed in the ESIA to minimize these impacts include avoiding disturbing vegetation, covered transportation of construction material, water spraying, and management of pollution from vehicles and equipment. During construction, major noise sources will include operation of cranes, excavation, movement of construction machinery, operation of generator sets and vehicle movements. 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 residential areas or other sensitive receptors.

The ESIA also identified efficient use of water, a scarce resource in the region, to be a key priority. EGP have a detailed Waste Management Plan that will minimize risks and impacts to human health and the environment. EGP/project company will adopt sustainable measures to reduce onsite water consumption as discussed in section below. The EPC contractor will be responsible for implementing these measures during construction. Further monitoring of air, noise, water and wastewater, soil, etc. will be undertaken during construction to verify these impacts. The plant is expected to generate 793 GWh annually which is estimated to result in avoidance of Greenhouse Gas (GHG) emissions of approximately 753733 tonsof CO2 equivalent annually. IFC considers these plans and measures to be appropriate for nature and scope of this project, and consistent with PS3. This section summarizes the key elements of EGP’s approach to water consumption and waste management.

Water Consumption: Groundwater will not be used for any project activity. Water required for civil works and domestic purposes will be supplied through authorized water tankers. The source of this water is expected to be from the nearest Indira Gandhi Canal tributary. EGP will audit water providers authorizations. Generated wastewater will be recycled and reused. During operation, the use of dry panel-cleaning robots will significantly reduce water consumption.

Waste and Wastewater management: Project construction activities such as site clearance, excavation works, installation of modules, etc. will generate limited types of solid and hazardous wastes. For example: domestic waste and sewage, hazardous waste such as used oil from machinery, scrap metal, etc. According to the project Waste Management Plan, solid waste will be segregated and stored onsite in color coded bins. Waste recycling will be mandatory, and appropriate trainings will be provided. Storage areas will have appropriate labelling and secondary containment. These will also be inspected frequently. Hazardous waste will be collected and disposed through approved vendors. Broken solar panel will be returned to the supplier. Associated records for generation and disposal of hazardous waste will be maintained onsite. The main source of wastewater generated during construction will be domestic wastewater from the toilets and wash basins. Septic tanks will be used to manage discharge of wastewater.                                                 

  Given the manageable size of the total peak construction workforce (i.e. 400), the fact that a significant percentage of project labor requirements will be sourced locally, and the relative proximity with the city of Bikaner, IFC does not expect that the area will experience any significant project-related population influx or associated social impacts. Project risks and impacts on public health, safety, and security – primarily among the six villages located within a 5 km radius - are expected to be limited, short-lived, and easily mitigated through standard good international industry practices. For example, dust emissions during construction will be controlled by limiting vehicle speeds and using upgraded access roads. Safety risks associated with construction of the 10 km transmission line will be avoided by sensitizing nearby communities to the risks and controlling access to active construction sites. One of the most prominent risks is from the simultaneous use of local access roads by both villagers and project construction workers. Apart from traffic management, IFC considers these plans and measures to be appropriate for the nature and scope of this project, and consistent with PS4. This section summarizes the key elements of EGP’s approach to infrastructure design and safety, community exposure to disease, and security personnel. 

Infrastructure and Equipment Design and Safety: The main community safety risk during project construction is associated with road safety, including the transport of components and heavy equipment to the site. The project company will ensure that EPC and O&M contractors develop Traffic Management Plans for the construction and O&M phases (ESAP#5). These plans should be based on detailed route assessments to identify and map locations with potential community risks, and specify where to install signals, deploy flagmen or adopt other measures to track project vehicle movements and ensure speed control. Additional awareness of road safety measures should be promoted amongst the local community. Construction and operation of the transmission line could also present a risk of electrocution or serious injury. Appropriate hazard signs will be installed along the route and at substations. The EPC will implement a community awareness campaign focused on risks of electrical origin or other risks that may be generated by the presence of the line. 

Security Personnel: The EPC contractor will hire security personnel from the surrounding villages. Security personnel will be trained to support implementation of the project’s environment, health, and safety measures. These personnel will not be provided with firearms.                                                 

  The project is located in the Thar Desert landscape which covers the majority of the Indian State of Rajasthan. The landscape consists of sandhills, grasslands and scrublands and plays host to desert dwelling fauna, including soaring birds.  Near settlements, the desert landscape has been extensively modified by humans for grazing and seasonal cropping. The habitat at the project site is a mosaic of modified and natural habitats, consisting of barren ground, grasslands and seasonal agricultural fields.  The project will result in the loss of a small amount of natural habitat for the solar array and along the transmission line route right of way. 

The nearest Protected Area (PA) and internationally recognized area (IRA) to the Project are the Jor Beer Bird Sanctuary which is an Important Bird Area (IBA) and the Gajner Bird Sanctuary. Both sites are located to the south east of the Project at a distance of approximately 40km and 35km respectively.  The IBA has been designated due to populations of IUCN listed Critically Endangered (CR) and Endangered (EN) soaring birds, including vultures and eagles. 

Several biological surveys were completed in late 2020 and early 2021, focusing on soaring and migratory birds that are of concern due to potential collision with the transmission line. Other surveys were also completed for herpetofauna, mammals and flora.  The results identified two species of IUCN EN listed bird species, being the Egyptian Vulture (Neophron percnopterus) and Steppe Eagle (Aquila nipalensis) and one IUCN Vulnerable (VU) listed species, the Eastern Imperial Eagle (Aquila heliaca). Other migratory bird species were also detected, including Cinerous Vulture (Aegypius monachus) (IUCN Least Concern) and Eurasian Griffon (Gyps fulvus) (IUCN Near Threatened). Given the presence of potential critical habitat species, a critical habitat assessment was completed, however no critical habitat values for these species were identified. To ensure survey coverage completeness and assist in defining baseline values for ongoing monitoring, an additional survey has been recommended to occur in March 2021 (ESAP#7).

The assessment of impacts according to the mitigation hierarchy identified that mortality of birds due to collision with the transmission line wires was a potential risk to local soaring bird populations. To manage these risks, the project will use bird diverters to improve visualization of the strung wires to soaring birds.  The project will also be required to work with the community to manage carcasses within the landscape, so that they are moved away from the transmission line to reduce potential collision risks, particularly for vultures and eagles. Other impacts considered included construction related impacts to resident fauna. To mitigate these impacts, demarcating the project area to stop clearing outside of the project footprint and education of the workforce to reduce risks will be applied. Management of invasive alien species will also occur to reduce risks of transmission into any areas of natural habitat.

Considering cumulative impacts to biodiversity values, there are two existing and one planned solar park and transmission lines in the area. Cumulative impacts to local bird populations is possible, however this is likely to be a low risk. This conclusion about the limited significance of cumulative risks will be confirmed as part of the actions required for ESAP#1. Coordination of monitoring activities to determine cumulative impacts is recommended. To monitor and respond to potential ongoing risks during operation of the facility, the project will be required to prepare a Biodiversity Management Plan, that will include a Carcass Management Strategy, Fatality Monitoring Program and a Soaring Bird Adaptive Management Plan [ESAP#8]. The plan will be prepared at least one month prior to operations. The Plan will be required to outline detailed measures to manage risks to soaring birds, including measures to respond to any mortality events detected through operational monitoring by adapting mitigations utilized by the project, if required.