Most of land required for the project is revenue land (barren and unirrigated) owned by the government and the companies have a land use permission and possession rights over it for 25 years. About 79 ha of privately owned land (including 70 ha for right of way of the transmission line) was purchased/leased on a willing-buyer, willing-seller basis at a mutually agreed/negotiated rate. There was no physical displacement associated from the setting up of the project and its associated utilities. Since contiguous land was not purchased, continued access for grazing, pasture or access to agricultural fields was ensured. Hence, PS5 (Land Acquisition and Involuntary Resettlement) is not applicable to the project.

With regard to PS7 (Indigenous Peoples), no diversions, material degradation or adverse impact resulted on land resources on which indigenous peoples are dependent. No tribal land was purchased for the development of the project and its associated facilities.

No cultural heritage has been adversely impacted as the site does not contain any archaeological monuments/sites, or any structure that have paleontological, historical, cultural, artistic or religious values. No unique natural features/forms, tangible or intangible are present in the project area which could be materially impacted by the project and its activities. Some temples and mosques are located in the villages close to the project sites; however, these are not impacted and there is no disturbance or access disruption resulting from the project. Hence, PS8 (Cultural heritage) is not considered to be applicable to the project. Cultural heritage protection plan/chance find procedure however has been developed as part of the Environmental and Social Impact Assessment (ESIA) and will be implemented as needed.                                                  

 This is a Category “B” project according to IFC’s Policy on Environmental and Social Sustainability because the project involves limited site specific environmental and social impacts, which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria.                                

 DJEPL and UUPPL (the companies) carried out before the start of construction an Environment and Social Impact Assessment (ESIA) including the development of an Environmental and Social Management Plan (ESMP), undertaken by a third party, to assess potential impacts and to design appropriate avoidance, mitigation and compensation measures for project-related risks and impacts in a manner consistent with IFC Performance Standards and WBG EHS Guidelines. The companies developed and are implementing a project specific environment and social Management system (ESMS) both for construction and operation phases based on the outcome of the ESIA/ESMP.

In addition to the mitigation measures delineated and discussed in the ESIA, Inox (the “E&C” and “O&M” contractor) has in place an environment, health and safety management system covering both construction and O&M activities and which is being satisfactorily implemented at the project site as verified during supervision visits undertaken by IFC. The Continuum Group has an approved HSE policy, HSE manual and Safety handbook in place. DJEPL and UUPPL contractually required the contractors to ensure that the avoidance and mitigation measures described in the ESIA are fully implemented during project construction and operation phase. Contractor oversight procedures were developed and are currently being implemented by the companies to ensure monitoring and compliance to the needed requirements.

The ESIA (dated February 2014) assessed impacts and designed appropriate avoidance, mitigation and compensation measures for project related risks and impacts (across the project life cycle) in accordance with IFC Performance Standards and good international industry practice (GIIP). These included impacts (including relevant cumulative impacts) pertaining to a)  ecology including on flora, fauna, birds and wildlife habitat, b) ambient noise levels including cumulative noise, c) land use pattern, d) ambient air quality, e) water and soil quality, f) wastewater; hazardous and solid waste, g) traffic including impact on local infrastructure and community health & safety, h) socio-economic, i) cultural resources, j) electro-magnetic interference and air aviation, k) shadow flicker, glint and visual intrusion, m) blade throw and n) labour engagement and influx.

The ESIA included an ESMP that outlined a) the avoidance & mitigation measures for the identified adverse impacts, b) monitoring and reporting framework and c) management responsibilities to implement the ESMP. The ESIA also included a summary of stakeholder consultations and community engagement (undertaken as part of the ESIA). Further, the company has developed a stakeholder/community engagement plan along with stakeholder analysis and a grievance redress mechanism. The ESIA also outlined specific management plans covering traffic and road safety, occupational health & safety, wastewater management, emergency management and response, stakeholder/community engagement, community development, cultural heritage protection that is being implemented by the project.

An Emergency response plan developed as a part of the ESIA is being implemented at the site to deal with emergencies such as electrocution, fire, fall of structure, medical emergency, civil disturbances, sabotage/vandalism and natural disasters. Emergency numbers are displayed at site (viz. nearest police station, health center) at the site for use by staff.

DJEPL and UUPPL have been ensuring adherence to IFC Performance Standards and WBG EHS Guidelines as applicable to its project and operations by implementing the mitigation, monitoring and management measures outlined in the ESIA and those highlighted by IFC during the supervision visits. The contractual agreement with contractors (E&C/O&M and others) includes appropriate E&S provisions including putting in place a robust oversight mechanism (deputing personnel, regular monitoring, internal audits and reporting). DJEPL and UUPPL contractually require the contractors to put in place a social and environmental organization consisting of qualified E&S personnel with appropriate responsibility to implement a) the ESMP, management plans and the bird/bat monitoring programme, b) community engagement and grievance redressal system/mechanism, c) labour and health & safety related requirements, d) regular training of employees and contractors and e) emergency preparedness and response procedures. DJEPL and UUPPL, as a part of its own contractor oversight procedure, undertake periodic monitoring/review and reporting of E&S performance of the project to management and investors. At the site there is one safety officer and one Heath, Safety and Environment (HSE) head for overseeing HSE matters.

Throughout the construction phase and during the current operations phase, DJEPL and UUPPL have ensured that the contractors fulfil their environment, health & safety and labour related obligations/requirements including the use of relevant personal protective equipment, implementation of work permit and tag out/lock out systems (for working at height, confined space, electrical works etc) and incident/accident recording/reporting systems etc).

The company reports to IFC annually on environmental, social and safety performance of the operations via the Annual Monitoring Report.                                                  

 COVID-19 Impact: The project has been in operation throughout the COVID-19 pandemic with strict enforcement of protective safeguards. There has been no significant health impact reported due to COVID-19 on the workforce and the company has developed detailed safety guidelines related to COVID which is strictly implemented (e.g. adequate PPE, temperature checks, social distancing in employee transport, disinfection facilities, safety at canteen etc.). The Company has allowed work from home for employees and medical insurance policy has been provided to all employees covering COVID.

The companies adhere to the Human Resource (HR) policies and procedures of the holding company Continuum Green Energy (India) Private Limited (formerly known as Continuum Green Energy (India) Private Limited (“CWEIPL”) and Surajbari Windfarm Development Pvt Ltd (“SWDPL”)). IFC at the time of its first investment required the company to undertake a review of its HR policies/systems and procedures and strengthen and upgrade it to meet the PS 2 requirements as a condition of disbursement and which was successfully completed. This included (but not be limited to); a) a clear policy on non-discrimination and equal opportunity; b) contract labor management; c) security; d) disciplinary procedures and code of conduct; e) training and employee welfare; f) collective bargaining; g) grievance mechanism in line with PS2 to raise workplace concerns and h) retrenchment. The company’s HR Policies and procedures are made available/accessible to all employees and communicated at the time of employee induction.

DJEPL and UUPPL had on its rolls 30 to 40 employees at the site during the construction phase. The construction phase (lasting around 12 months), involved deployment of 150-200 construction workers on an average (engaged through contractors). The construction workers (mostly unskilled and semi-skilled) were hired by the contractor from the local area mostly. Construction workers from outside the area/region were provided accommodation in nearby villages or accommodated in labour camps set up by contractors in the project area. The skilled workers (around 25-30%) were hired from outside and accommodated in rented houses at nearby towns. DJEPL and UUPPL contractually required its contractors, to make available to the migrant workers: living conditions with basic amenities and electricity; potable water; mess facilities for food; where workers desire self-cooking, provision of fuel and arrangement for cooking; provision of toilets and bath including separate toilets and baths for women family members of workers; appropriate sewage disposal facilities and/or septic tank and soak pit; and primary medical care for all workers engaged at site.

Currently there are 25 employees of the companies at the site and 147 employees of the contractor engaged in O&M operations. About 18-20 security staff have been locally hired through third party agency in the operations phase of the project.

The contract labour management process developed as a part of the ESMP was implemented for the project. As a part of the contractor oversight procedures, DJEPL and UUPPL review the contractors’ HR policies and procedures and communicate to them specific provisions of its own HR policy and PS 2 requirements that are applicable to contractors’. It also includes detailed requirements including audit procedures to ensure that: contractors comply with applicable statutory requirements; worker accommodation is consistent with IFC Guidance on Worker Accommodation; workers have access to appropriate grievance mechanism; and migrant workers are engaged on substantially equivalent terms as non-migrant workers performing same work, all in accordance with Performance Standard 2 provisions. DJEPL and UUPPL provided training and capacity building support to the contractors to understand and meet the aforesaid requirements.

The project has obtained membership from National Safety Council (NSC) and a safety audit was conducted by NSC in March 2017. Weekly safety walks are organized wherein safety committee members participate and safety related observations are shared. Monthly safety MIS reports are prepared which lists the number of lost time incidents, fatalities and near misses in addition to training details. Review of safety data reveals that there have been no lost time incidents till date. The company has HSE training calendar in place and has organized training sessions on first aid, firefighting, LOTO preparedness, HSE awareness etc. Mock drills are conducted on a regular basis.                                                  

 Temporary impact on ambient air quality during the construction phase was linked to site preparation activities (foundation and road excavation, levelling, land clearing, etc), vehicle movement and other activities. Mitigation measures, to minimize this adverse impact, were implemented including minimization of disturbance of vegetation, covered transportation of loose construction material/excavated earth and stockpiles, water sprinkling, and management of pollution from vehicular and equipment emissions. Current ambient air quality parameters in the project area are well within national standards.

Baseline noise levels as noted in the ESIA at nearest habitations exceeded the permissible limits (national ambient noise standards) both during day and night time for some locations attributed mostly to the commercial activity and traffic movement in the area unrelated to the project. Major project-related noise sources during the construction phase included operation of cranes, excavation, movement of construction machinery, operation of DG sets, vehicular movement, etc. Noise level increases during construction were temporary and limited to the vicinity of the noise generating source, except in case of movement of material through/near habitations or other sensitive receptors. 

During operations, DJEPL and UUPPL have been implementing a traffic management plan and other mitigation measures for noise (including restriction on traffic movement during night time hours, regular maintenance of vehicles, minimizing ground vegetation clearance etc). DJEPL and UUPPL, undertake monthly monitoring of ambient noise level at 10 locations (both during daytime and night time) in order to understand the increase in noise levels due to the project operation. Based on the data obtained from these monitoring programs, ambient noise levels are observed to be within national/IFC guideline values at all receptor locations.

Water requirement for the construction stage was about 62.1 kilo litres per day (KLD) and is 1.35 KLD during the operations phase (sourced from approved vendors). Domestic waste water is disposed through septic tank and soak pits and there is no discharge of waste water to any surface water body.

Construction waste related to the project such as packaging and crating material of turbines, construction debris like small concrete, metal, bins, scraps and debris was collected, stored, segregated and disposed in accordance with the Waste Management Plan (recycling of packaging waste and disposal of inert waste to landfill). Hazardous waste generated from use of heavy machinery /equipment  like waste oil, gearbox oil, hydraulic oil, lubricant, cleaning fluids, paints, degreasers and other similar substances are disposed as per the Hazardous Waste (Management, Handling & Trans boundary Movement) Rules, 2008 and in accordance with the Waste Management Plan through authorized entities. DJEPL and UUPPL, as a part of contractor oversight, require the contractor to implement the waste management plan and ensure that the solid and liquid waste generated at the site are securely stored, handled/used with appropriate care and personal protective equipment; segregated; and disposed of in accordance with the waste management plan requirements. The plan requires that transformers do not use PCB containing oils; and ozone depleting substances banned/phased out under Montreal Protocol are not used.                                                  

 The turbine sites are generally located atleast 300 m away from human settlements and other sensitive receptors. The project is located in a moderate seismic hazard zone, which has been taken into account in the design of turbine foundations. The site is not located on any air traffic route and turbines are not located within any airport obstacle limitation area.

Though the construction sites were generally away from local settlements, adverse impacts on the local community during project construction and operation to minimize community health and safety risk were included in the ESIA (including traffic planning, managing influx related issues, sourcing water from authorized vendors, appropriate disposal of sanitary wastewater and hazardous waste, appropriate accommodation and facilities for migrant workers) and the management plans (emergency, community development, stakeholder engagement) which were implemented during construction and are being implemented during operations. DJEPL and UUPPL ensures that the O&M contractor of the wind farm implements the mitigations measure detailed in these management plans. Traffic management measures like movement during daytime, speed limits, restricting on honking, driver training in defensive driving, as discussed in the traffic management plan, are undertaken. DJEPL and UUPPL implement an Emergency Response and Preparedness Plan to deal with emergencies such as electrocution, fire, community safety incidents and natural disasters. Emergency numbers are displayed at site at various locations (viz. nearest police station, health center) at the site for use by staff.

The construction phase of the project did not result in community exposure to disease either due to changes in land/hydrologic other terrestrial/air quality/hydrologic regimes or through large influx of migrant labor. DJEPL and UUPPL nevertheless required and currently requires the contractor to have measures in place to identify and mitigate risk of community exposure to disease due to influx of labor and any other community health, safety and security risks. Overall, road and access infrastructure in the area is good (the site is well connected by road network) hence, during construction, no significant pressure on infrastructure resulted due to the project.

DJEPL and UUPPL allow grazing activity in most part of the site. The transformers are fenced and cables insulated to avoid any electrical hazards. Access to agricultural fields, villages, communities and their networks are not disrupted/hindered. The project does not hamper the activities or access to the temples/mosques in the project area.

The modeling results carried out as part of the ESIA (including cumulative modelling) for shadow flicker suggested that four proposed turbine locations were likely to result in shadow flicker impacts on nearby sensitive receptors).  Based on this, DJEPL and UUPPL revisited the micro-siting of these four locations and shifted them to other nearby areas so as to ensure no adverse impact occurred on receptors.

The project employs unarmed security personnel which are engaged through an outsourced and authorized security agency. No security related incidents were reported during the construction phase and there have been no incident involving security forces till date as well. DJEPL and UUPPL require the security agency to implement procedures to ensure that: past records of security personnel employed are screened; security personnel have clear objectives and permissible actions laid out; security personnel are trained in avoidance of abusive behavior; security incidents are recorded, investigated and corrective action implemented; bona fide complaints against security personnel are investigated and appropriate disciplinary actions are implemented; and there is a grievance mechanism for aggrieved members of community or employees, in the event of a violation of the code for security personnel. Contractor oversight procedures of the company ensure compliance to the aforesaid requirements.                                                  

 The project does not fall within any conservation areas/protected areas/World Heritage sites or Eco Sensitive Zone. No forest land is involved in the right of way (ROW) of the transmission corridor for the project. A rapid assessment of avifaunal species (with focus on birds and bats) carried out as part of the ESIA suggested that no significant adverse impacts on faunal and avifaunal species were expected from the project and planned developments.

The ESIA studies stipulated that the project site does not harbor high biodiversity of flora and fauna, including endemic species. Analysis of secondary data and consultations with relevant stakeholders suggested that the project area falls in a low bird activity area and has low intensity with regard to migration routes of large bodied birds. No known major avian migratory flyway coincides with the project area. One roost of a common bat species i.e. Indian Flying Fox (listed as Least Concerned species by IUCN) was identified at a reasonable distance (about 2 kms) from two of the turbine locations. The majority of turbine locations maintain safe distances (500-1000 mts) from the water bodies in and around the project area. These water bodies do not hold water on a long-term basis and thus are not likely to serve as bird staging or nesting areas.

While a significant impact on birds and bats were not expected based on ESIA findings, during the operations phase, DJEPL and UUPPL conduct bird/bat strike monitoring through a third-party E&S consultant (Green Support Services, Gandhinagar) which visits the site twice a year. The consultant carries out refresher training for staff at site and bird and bat carcass search monitoring is carried out by security guards stationed at the WTGs. Data is recorded and monthly data so collected is shared with E&S consultant which then compiles an annual report. Based on the results of the monitoring program, it has been observed that bird and bat fatality numbers are very low (< 50/year) and does not include any species of conservation value (most of the species are of least concern category). The company has taken a number of initiatives such as installation of bird guards to further reduce the incidences of bird electrocution (covering maximum electric poles) and application of high tension insulation tapes.