Performance Standard 8 is not applicable as the selected Transmission Lines have either avoided or are not routed close to any Cultural Heritage sites

This project is Categorized as A according to IFC’s Policy on Environmental and Social Sustainability. The project consisting of 5 operational transmission line assets has  Critical Habitat triggers in certain segments which will need measures to manage critical habitat values to achieve net gain.  In addition, there are outstanding as well ongoing social impacts from the transmission line, including impacts on access to natural resources to IP communities that need to be managed and addressed in line with PS requirements. More specifically, key E&S risks and issues associated with this project include: implementation of environment and social management system (ESMS) and staffing to undertake the project in accordance with IFC PSs; engagement with stakeholders and affected community during project operations, primarily related to health and safety of the landowners and users and access to the right of way; assurance of fair, safe and healthy working conditions for employees and contracted workers and consistent management of occupational health and safety (OHS); ongoing mitigation of any damage to land and assets under the towers and Right of Way, management of biodiversity issues at a few locations across all the lines with longer term monitoring; and culturally appropriate engagement with Indigenous communities wherever the lines pass through IP areas. 

   Policy, Environmental and Social Assessment and Management System:

IndiGrid Investment Managers Limited (IIML) is the Investment Manager for IndiGrid. The Investment Manager is responsible for the operations pertaining to the Trust, including acquisition/divestment of assets etc. IIML executed Investment Management Agreement with IndiGrid on November 10, 2016. Through the provisions of the Investment Management Agreement, IIML is empowered to take all decisions related to the management and administration of IndiGrid’s assets and investment, as well take overall responsibility of asset management, Mergers & Acquisitions (M&A), capital raising, compliance, engineering, and finance.

IndiGrid has in place corporate Environmental and Social Management System (ESMS) which was developed in November 2020 and is compliant with IFC PS requirements. IndiGrid has an HSE Policy and is an ISO certified company with Integrated Management System certification covering ISO 9001:2015, 14001:2015 and 45001:2018 for management of assets including operation and maintenance.

The ESMS requires each of the assets to develop a site specific Environmental and Social Management Plan (ESMP), Stakeholder Engagement Plan (SEP) and Grievance Mechanism. The ESMS requires the Asset Acquisition Team to undertake an asset screening and risk assessment prior to any new acquisition. E&S risk assessment has  not been done prior to acquisition for assets that were acquired before the ESMS was developed.  The ESMS has adequate provisions in place for monitoring. This ESMS however is in the early stages of implementation at the SPV and asset level.

O&M is subcontracted to qualified and competent operators who are contractually required to meet IndiGrid’s policies and systems, as well as all compliance necessary for operations. Most of the staff at the asset level are employed by the O&M contractor, with IndiGrid represented by a small team overseeing the O&M Contractor.

Identification of Risks and Impacts:

IndiGrid has developed a Corporate Level Hazard Identification and Risk Assessment (HIRA) for all its business lines, which have been observed to be communicated at the asset level. Further, the ESMS directs every SPV/asset to maintain a risk register (ongoing basis during Operations and Management), identifying all the environmental and social risks.  This register is supposed to be reviewed and updated by the ESG Lead. As included in ESAP#1, IndiGrid will require the assets to develop and implement asset specific, ESMP, SEPs and grievance mechanisms. The stakeholder engagement (SE) planning and design of the Grievance Mechanism will include stakeholder mapping and analysis as well as plans. The Grievance Mechanisms will allow all kind of grievances to be received, and will have provisions to receive anonymous grievances, be confidential, safeguards against reprisal and retaliation, and be driven by a system of logging, tracking and analyses of the grievances on a regular basis. The GM will be reviewed based on agreed Key Performance Indicators (KPIs).

IndiGrid uses Legatrix for EHS regulatory compliance management. It is an IT-enabled legal support service software. The software provides a quick dashboard for asset wise status of compliance requirements. Legatrix has interactive features with comprehensive law content under categories of assets, corporate, human resource, commercial, environment-health and safety, regulatory and taxation etc. “Compliance Alert” are received in Legatrix system in advance to completing the compliance task. Regulatory documents, compliance proof and supporting documents can be uploaded in the Legatrix system. IndiGrid has a well-qualified legal team at the corporate level that monitors the status of compliance through this system and follows up on actions needed to reach compliance as alerted by the system. IndiGrid will prepare a detailed EHSS protocol agreed with IFC to drive internal monitoring on E & S performance (ESAP # 2) and receive and implement recommendations on strengthening compliance management as well resource capacity to service the 5 assets.

There are 9 pending litigations in JTCL and OGPTL.  In JTCL, all cases are pertaining to compensation claims for construction stage damages and lack of intimation about land procurement under the project. In OGPTL, there are 3 pending litigations. In two of the cases, petitioners have demanded the diversion of the transmission line from their land whereas in one case, the petitioner has claimed compensation for the right of way. Secondary information shows another litigation against OGPTL in Orissa High Court against construction of transmission line through forest area without obtaining consent from Gram Sabha which is pending. IndiGrid will track the progress of the pending as well as new litigations across the 5 assets and maintain detailed documentation of the same, including payment of compensation and other actions determined by the court of government agencies (ESAP #3)

Organizational Capacity and Competency:

There is a qualified and dedicated E&S team in place at the corporate level while the asset level O&M as well as HSES management has been sub-contracted to qualified contractors. The IndiGrid ESG Lead is the independent resource at the corporate level who is responsible not only for the ESMS implementation, but also for driving IndiGrid’ s E&S performance. As per ESMS manual, ESG and EHS positions are separate, but IndiGrid is still in the initial stage of ESMS implementation and till recently EHSS Lead’s responsibilities were managed by EHS Head who reports to VP Operational Excellence. As included in ESAP#4, IndiGrid will appoint an EHSS lead at the Corporate Level who will be overall responsible for the implementation of the ESMS and obligations under the ESAP and designate and define clear responsibilities for suitably qualified and accountable people for E & S performance and ESAP implementation for the portfolio.

Operations are managed by the O & M contractor and their contract includes compliance requirements. IndiGrid will develop and implement a Contractor Management Plan for all its contractors (and update its contracts with them appropriately) that will cover legal, environmental, and social obligations as well as cascading of the ESMS requirements on developing and implementing ESMPs, stakeholder engagement and grievance management processes as well as monitoring and reporting. The contractors already have HSE reporting obligations. This will need to be strengthened to include reporting on labour, HR issues described under PS 2, worker grievances as well as community engagement and grievances as detailed in the subsequent sections (ESAP #5).                                                

 Human Resource (HR) Policy and Procedures:

IndiGrid is governed by a Code of Ethical Business Conduct, which defines the nature of professional relationships between co-workers, competitors, customers etc. It covers elements of Whistle Blower, anti-discrimination, social media communication, anti-corruption as well. IndiGrid has prepared an Employee Policy Manual that is broadly aligned with PS 2 and consists of policies and procedures covering employee related aspects including induction to the job, attendance and leave, transfers, relocations and exit, loan and advances, medical insurance, compensation, among other employee benefits. The manual also consists of guidelines on prevention of sexual harassment (PoSH) in the workplace and has an Internal Complaints Committee (ICC) to handle concerns under this policy. For sexual harassment related violations, employees can approach an Internal Committee. There is an awareness training arranged for all its employees and staff every year on the PoSH Policy. As reported by corporate level employees as well as asset level teams, there has not been a complaint under this system till date. There is no specific reference in the current SH guidelines on addressing gender-based violence (GBV) at the corporate as well as asset level.

All employees have access to an online portal named Zoho People. Any queries with respect to the policies or their employment conditions can be posted on Human Resources helpdesk on this portal.

Working Conditions, Terms of Employment, and Contractor Management

O&M is managed through an O&M Contractor in all the 5 assets. At every billing cycle, the Contractor is required to share with IndiGrid several documents before their bills are cleared including attendance register, wage register, loans and advance, Provident Fund (PF) and insurance related challans (receipts) as well as inclusion/exclusions of workers for any reasons. The Contractor must share a written undertaking to paying minimum wages and meeting compliance requirements. The due diligence identified some inconsistencies in the payment of PF. It also identified that the contractor agreements on labour compliance were generic and needed to be specific, especially related to overtime wages, working hours, leaves, grievance redressal, prohibition of child labour and forced labour, non-discrimination, payment in bank accounts, provision of wage slips, recruitment process etc. The O&M contract requires the contractor to comply with national labour laws as well as IndiGrid’s EHS policy. In the Contractor Management Procedure (ESAP #5), IndiGrid will include regular reviews and payment of all dues under the Provident Fund and other compliance requirements, update the labor provisions / requirements in the contractor agreements and communicate the same on a regular basis to the workers, and get the ESMS requirements to be cascaded to the contractors, including monthly reporting of grievance log. IndiGrid will conduct labour and working condition assessment on the SPV and O&M contractors, on compliance on regulations as well as PS2 as a part of the internal EHSS monitoring (ESAP #6).

IndiGrid will develop a gender strategy to increase women’s participation in the workforce for IndiGrid India Trust (ESAP #7).

Retrenchment

When IndiGrid buys an operating asset it either absorbs the workforce or hires new employees in the case the developer of the asset wants to deploy their workforce elsewhere in their company. IndiGrid does not retrench people as a rule. However, for unexpected circumstances where this may be necessary, IndiGrid will include a Retrenchment Policy in its updated Employee Manual and add general procedures for fair treatment of the retrenched workforce including providing necessary support for the transition and their rehabilitation (ESAP#8).

Health and Safety at Asset Level

At a corporate level, IndiGrid has as HSE Training plan covering aspects like HIRA, Material Handling, Fire and Life Safety (FLSF), PPE, etc. Emergency Preparedness and Response Plan (EPRP) was prepared in 2020 which covers aspects like natural calamities, fall from height, medical emergencies, snake bite, etc. The ESDD confirms that at an asset level regular HSE training and mock drills are conducted. The site offices are equipped with an emergency exit and demarcated assembly points. A first-aid box has also been provided at site office in case of any emergency. IndiGrid maintains records of accident and incidents at site. During consultation and review of records, apart from one loss time incident resulting from bee bite there were no other Loss Time Injury recorded since initiation of project operations.  As a part of its Contractor Management Procedure (ESAP#5), IndiGrid HSE Manual will be a part of all Contracts with sub- contractors and compliance to which will be monitored as a part of the internal EHSS monitoring.

Freedom of Association

IndiGrid does not discourage employees to form a trade union (TU) or any other collective bargaining mmechanisms, however there are no registered TUs at any of the assets. There are Health & Safety Committees at each asset where employees are free to provide feedback and raise issues directly to their supervisors or through these committees. Such committees meet monthly and have representation from the O & M contractor management as well as IndiGrid regional management. IndiGrid management engages with the employees and their contractors/workers on a regular basis through townhalls, service award events and other engagement activities. As a part of its upgrade of its ESMS, IndiGrid will include a Policy on Freedom of Association that allows for worker representation and collective bargaining, tailored to the nature of the business (ESAP#8).

The Employee Policy Manual will be revised to include a) GBV procedures, ensuring anon, confidential and survivor centric handling of grievances, as well as training to staff handling such matter; b) a policy on Freedom of Association and c) a Retrenchment Policy.  Updated Employee Policy Manual will be accessible to all workers via the “Zoho People” portal (ESAP #8).

 IndiGrid has established an SOP on pollution control, providing guidance for control of pollution through various stages of O&M, emission from vehicles, domestic effluents, and oil and chemical spill management.

There is no requirement of water for maintenance activities. For drinking purposes at site office and worker’s accommodation, packaged drinking water is sourced from local water vendors and domestic wastewater generated is discharged into municipal public sewage systems.

During the operation phase, the primary source of energy at IndiGrid’s installations is grid electricity and standby diesel generator (DG) sets are provided only at some assets for backup power with proper acoustic enclosures. Emissions from DG sets are monitored through third party laboratory and noted to be compliant with host country guideline values. Pollution Under Check (PUC) certificates are maintained for the vehicles used for maintenance activities.

Hazardous wastes generated include spent transformer oil, used oil, dielectric containing equipment, batteries, and gaskets/other maintenance wastes. IndiGrid has developed an SOP on Procedure for Waste Management, providing guidance for disposal of the various kind of non-hazardous waste generated at all operating sites. The SOP also provides details on management of hazardous wastes including lead acid battery, e-waste, and biomedical waste. Going forward as included in ESAP#9, IndiGrid will implement procedures to store all hazardous materials and wastes in designated areas with adequate secondary containment and dispose hazardous wastes through authorized entities in accordance with host country requirements.

 The company has a corporate policy, endeavors to avoid habitations and densely populated areas while selecting route alignment and adheres to clearance norms prescribed in Electricity Act, 1910 and as amended till date. 

IndiGrid has developed corporate guidance on Hazard Identification and Risk Assessment (HIRA) which lists out hazards from various activities. Going forward as included in ESAP#10, IndiGrid will conduct periodic assessments based on ground patrolling, for critical towers once a month and for non- critical towers once a quarter across the five assets to identify health and safety as well as community risks. Based on the survey and if risks are identified, IndiGrid will update the HIRA to include the risks to community exposure from transmission line operations and impacts on the community due to electrocution; electromagnetic interference and implement appropriate mitigations measures. IndiGrid will also develop and implement a community awareness program.

Security personnel are deployed at site offices, transmission line segments, and other project facilities like labor camps, material storage areas etc. (during major maintenance phase). The corporate ESMS includes security personnel management procedures, and which mandate the requirement of deployment of security personnel through a reputed and competent third-party security agency, background verification to be carried out for the security personnel prior to recruitment and training on ethical behavior and use of forces (if armed guards are deployed). IndiGrid engages unarmed security personnel sourced from reputed security service providers. Going forward as included in ESAP#11, IndiGrid will strengthen the implementation of corporate ESMS at individual assets on security management and 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 human rights abuses, identifying, and preventing gender-based violence and on protocols for interaction with community members and workers .

Security Management will require that security incidents are recorded, investigated and corrective action implemented; complaints against security personnel are investigated and disciplinary actions 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.

To prevent safety incidences (which happens occasionally and mostly related to potential electrocution during agricultural or grazing activities under the tower or RoW) the O&M teams have an awareness campaign about the potential risks and safe behaviors, especially during the harvesting seasons, when in some location, farmers practice stubble burning after harvesting. In such cases, ESAP #12 where there are impacts on livelihood due to restriction in access or damages to crop/assets due to operations conduct an assessment of the impact on the landowners/users, including an assessment of the economic loss, and implement appropriate mitigation measures, including compensation at replacement value and livelihood restoration  where needed. IndiGrid will monitor these cases through the EHSS monitoring and ensure these are captured in the grievance mechanism records.

 JTCL

The JTCL Project is situated in Madhya Pradesh and Chhattisgarh states of central India that contains tropical and subtropical dry broadleaf forests that have been extensively cleared for agriculture and human settlements.  The transmission line route consists of modified habitats along the route itself, with 85% of adjacent lands. Natural habitats exist beside approximately 15% of the route.

There are several internationally recognized areas in the vicinity of the transmission line route with one that overlaps, being a 3.3 km section of the Jabalpur-Dharamjaygarh component of the Project that coincides with the nationally designated Kanha – Achanakmar Tiger Corridor, which is a critical movement channel for Bengal Tiger Panthera tigris ssp. Tigris, IUCN EN.  There are no protected areas that overlap with the Project route; however, the Amarkantak Achanakmar Man and Biosphere (MAB) Reserve is located within proximity to the northeast mapped boundary of the Jabalpur-Dharamjaygarh component of the Project.

Critical habitat screening has identified critical habitat values for the Bengal Tiger within the Kanha – Achanakmar Tiger Corridor.  Risks are be managed within the corridor to reduce existing induced impacts to the species, such as habitat clearance and wildlife conflicts.

Regarding Lesser Florican Sypheotides indicus IUCN CR, existing risks may include the potential for transmission line collisions.  Given the lack of contemporary data for this species, further monitoring over a period of 2 years is required to determine if critical habitat is triggered.  If the species is present, IndiGrid will be required to develop measures to contribute to the conservation of the species. These measures would manage threats to the existing population, such as habitat loss and predation, as well as contribute to ongoing monitoring of the species.

Several key species warrant further analysis to determine critical habitat status and to identify specific mitigations on the existing lines to reduce risks from collision and electrocution.  These species are soaring birds including Red-headed Vulture Sarcogyps calvus IUCN CR; Egyptian Vulture Neophron percnopterus IUCN EN; Indian Vulture Gyps indicus IUCN CR; Saker Falcon Falco cherrug IUCN EN; Pallas’s Fish-eagle Haliaeetus leucoryphus IUCN EN. Migratory and/or water birds include Indian Skimmer Rynchops albicollis IUCN EN), Black-bellied Tern Sterna acuticauda IUCN EN), Lesser Adjutant Leptoptilos javanicus IUCN VU and River Tern Sterna aurantia IUCN VU.  Mitigations for these species will include the use of bird diverters to reduce collision risks and anti-electrocution devices within proximity to habitats for these species.  IndiGrid will also be required to implement carcass management strategies along high utilization areas which have been identified.  Further survey and analysis to quantify the risks to these species and subsequent nature/location of mitigations will be required.

PKTCL

The PKTCL Project is located in Jharkhand and Odisha, which form part of the Chhota Nagpur Plateau. The area has been extensively cleared of natural vegetation with remnant natural habitats consisting of tropical moist forests. Modified habitats constitute the transmission line corridor itself as well as approximately 95% of the land adjacent. Natural habitats constitute approximately 5% of the area adjacent, including areas of locally designated forested land.

There are several internationally recognized areas and protected areas in close proximity to the PKTCL, however none overlap with the route itself. The lines intersect four nationally designated elephant corridors, deemed critical movement channels for Asian Elephant Elephas maximus IUCN EN.  The Chandil-Matha, Mahilong-Kalimati and Dumriya-Nayagram Elephant Corridors are intersected by the Ranchi-Purulia and Chaibasa-Kharagpur component of the line.  It is considered that these corridors constitute critical habitat for the species and hence IndiGrid will be required to incorporate measures to manage ongoing induced risks, such as habitat loss and wildlife conflicts.

Additional survey and analysis for potential critical habitat values for soaring birds/water birds will be required.  The analysis will also be required to identify any risks and the nature/location of mitigations that will be required. 

MTL and RTCL

MTL is located on Deccan Plateau region of southern India within Telangana State.  The region is highly cleared however remnant patches of tropical dry forests remain, as do inland wetlands. The transmission line easements are degraded habitat which also constitutes 80-90% of the land adjacent.  The remaining 10-20% of land adjacent would be considered to be natural habitat.

A 25 km section of the Nizamabaad- Shankarpally component of the MTL transmission line overlaps with the Pocharam Wildlife Sanctuary which is a nationally designated protected area and Key Biodiversity Area (KBA).  KBA triggers being Indian vulture Gyps indicus IUCN CR) and Indian Skimmer Rynchops albicollis IUCN EN). IndiGrid will be required to consult with the protected area manager and KBA secretariat as well as contribute to additional conservation programs for the protected area/KBA.

Screening for critical habitat identified potential values related to Lesser Florican Sypheotides indicus IUCN CR for both lines will be required. As with JTCL, IndiGrid will be required to monitor over a period of 2 years and develop measures to contribute to the conservation of the species, if found. 

Soaring birds and waterbirds will require further analysis to determine if critical habitat is identified as well as to identify required mitigation to reduce risks from collision and electrocution.

OGPTL

OGPTL passes through the states of Odisha and Chhattisgarh within the Mahanadi River Basin.  The habitat values along the transmission lines consist of undulating plains dominated by disturbed habitats (80%) with the remaining habitat consisting of tropical moist and dry forests and natural inland wetlands which are considered to be natural habitat (20%).The Jharsuguda-OPGC component of OGPTL passes through the Heerakund Reservoir and Debrigarh Wildlife Sanctuary IBA, however the IBA was established after the construction of the transmission line.

One nationally designated elephant corridor (Hemgir Forest Range) deemed a critical movement channel for Asian Elephant Elephas maximus IUCN EN coincides with the Raipur-Jharsuguda component of the line.  It is considered that this corridor constitutes critical habitat for the species and hence IndiGrid will be required to develop measures to manage ongoing induced risks, such as habitat loss and wildlife conflicts. 

Additional survey and analysis for potential critical habitat values for soaring bird/water birds will be required to identify any risks and the nature/location of mitigations that will be required. 

General ongoing management of impacts for all lines

As included in ESAP#14, a Biodiversity Action Plan (BAP) will be prepared by a suitably qualified consultant(s) for each individual transmission line outlining the requirements for additional survey and assessment to manage critical habitat and natural habitat values identified as described.  The BAP will include: (i) measures to manage and monitor critical habitat values to achieve a net gain outcome for habitat of the Bengal Tiger Panthera tigris ssp. Tigris, IUCN EN within the Kanha – Achanakmar Tiger Corridor (Relevant for the JTCL project); (ii) measures to manage and monitor critical habitat values to achieve a net gain outcome for habitat of the Asian Elephant Elephas maximus IUCN EN associated with elephant corridors transected by PKTCL and OGPTL; (iii) consultation with the KBA secretariat/protected area manager regarding the Pocharam Wildlife Sanctuary.  The BAP will be discussed and agreed between IndiGrid, IFC and the Biodiversity Consultant.

Additional conservation programs for the protected area/KBA are to be developed; (iv) survey for the Lesser Florican Sypheotides indicus IUCN CR, within suitable habitats associated with JTCL, MTL, RTCL for a minimum of two years; (v) surveys for soaring birds and waterbirds undertaken by a suitably qualified consultant for JTCL, MTL, PKTCL and RTCL to determine the critical habitat values (if any) for these species and recommend the design, location, installation, and maintenance requirements for bird diverter devices and anti-electrocution requirements in relevant soaring bird/water bird flyways/habitat.   Measures to manage carcasses in association with community and government stakeholders is also to be defined based on the survey results; (vi) measures to manage natural habitat values, including for: Yellow Monitor Varanus flavescens IUCN EN; Indian Pangolin Manis crassicaudata IUCN EN and Dhole Cuon alpinus IUCN EN; (vii) measures to manage ongoing risks with the maintenance of the transmission line and corridors, including vegetation clearance, soil erosion and use of herbicides; and (viii) monitoring and evaluation sub-plan to track and enable adaptive management for biodiversity values within the BAP in achieving no-net-loss/net gain outcomes

Three lines – JTCL, PKTCL and OGPTL cross Scheduled V areas while the remaining two (MTL and RTCL) do not have any Scheduled V areas under the Transmission Line. Scheduled V areas were designated by the Constitution of India and are areas with high Scheduled Tribe (ST) or IP population (along with general population) and enjoy special protection and welfare programs.  The Transmission Line developer acquired part of the ROW from ST landowners and they were treated at par with the general community in terms of compensation for private land as guided by statutory provisions. There are also locations where there were recognized communal lands as well as lands with individual rights that were settled under The Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006, also called the Forest Rights Act (FRA). Under this Act, before access rights to such lands are taken for a project, the District Administration must settle the rights of the forest dependent communities/ individuals. The Act covers a wide range of rights including rights to land for habitation and cultivation, rights over community resources like forest products rights, grazing and fishing rights, rights of cultural sites as well as Intellectual Property Rights. The FRA allows for the claims to be made by individuals and communities, first recognized, and verified by the Gram Sabha or the village council and then approved by a District Level Committee formed under the Act for such settlements. Any parties aggrieved by the Gram Sabha process can approach the District Committee with their grievance under the Act.

In JTCL, the TL has 80 km passing through Scheduled V area, intersecting with 86 villages and 3 districts and potentially impacting communities from the Gond and Dhoba tribes. In PKTCL, the line has 158 km in Scheduled V area, intersecting with 367 villages and 4 districts potentially impacting tribal communities like Santhals, Ho and Munda. In OGPTL, 95 km of line goes through Scheduled V area and intersects with 550 villages and 2 districts, possibly impacting communities from the Kisan, Sabara, Bhuiyan and Munda tribes. The construction of the transmission lines would have resulted in cutting down several trees as a part of the forest clearance process, some of which may have been used by the local tribal community, though it is expected that they would be able to continue accessing the rest of the forest area. In addition, the tribal community may have faced temporary disruption in accessing the forest during the construction. Activities such as grazing, collection of fodder and fuelwood as well as collection of NTFPs in and outside the ROW are not expected be impacted during operations and this was verified by the ESDD. Consultations during the ESDD process did not identify any communal rights outside forest areas. The developer has tried to avoid lands identified by the community as culturally important during construction. In one of the lines PKTCL, there is evidence to show the original line was crossing a grove or a cluster of trees considered by the community as sacred, locally called Sarna. When this issue was identified, the developer, through consultations with the community, rerouted the line to avoid the Sarna area. They also did some social investment in local development activities as a part of their engagement with the community. This was verified from the community during the ESDD consultations.

There is however no comprehensive documentation of these impacts or an assessment of their significance which can be relied upon or base further management actions on. As included in ESAP # 15, IndiGrid will commission a Social Assessment by an independent third party to identify residual and ongoing impacts due to IndiGrid’s operations on collectively/communally owned lands/assets of and resources of IPs in project affected areas in general and Schedule V areas in particular in each of the 5 transmission lines. In case of past impacts, the provisions described under the GM in ESAP #2 and ESAP #13 will apply. IndiGrid will develop and implement a Social Management Plan (SMP) based on outcomes of the assessment to address residual and ongoing community level impacts.  The SMP will be discussed and agreed between IndiGrid, IFC and the social consultant.

All 5 assets have had forest rights settlement under the Forest Rights Act. JTCL, with 36 settlements, has the highest number of settlements, followed by OGPTL (5), PKTCL (3), and MTCL and RTCL at 1 settlement each even though they do not impact Scheduled V areas. The certificates obtained from the developer do not have the detailed minutes and process documents of the settlement process under the FRA to determine what the claims were and how they were verified and settled. Therefore, there is very scattered information available about these settlements. IndiGrid will make reasonable efforts to obtain all the FRA certificates and the detailed minutes from the developer, recognizing that these rights were settled nearly 6-7 years ago, and the documents may be difficult to access.

Further to ESAP # 2 in all Scheduled V areas, IndiGrid will tailor the SEP and grievance mechanism to make them accessible to the tribal community in language and design that is culturally appropriate.

 The ESMS has an SEP at the corporate level with the commitment to roll it out to the asset level through development of an SEP for each of the SPVs. As of now, the SPVs have not yet developed or implemented SEPs. Consultations however regularly take place at the asset level through the O&M Contractor. They consult with the landowners and the local community to seek access to the towers and RoW for maintenance activities, to sensitize the community about safety risks, to address grievances, and for their CSR program implementation. These consultations are however not formally recorded or reviewed and do not feed into any systematic stakeholder engagement process. Grievances, including community complaints on damage to crops or assets, or occasional community resistance to access to their land for O&M is dealt with at site by the O&M team, though there is no grievance mechanism in place for recording these and resolving them in a consistent manner and as defined by the ESMS.  As provided in ESAP# 2 IndiGrid should ensure an SEP and grievance mechanism are put in place at each asset and will be included in the O & M Contractor’s responsibilities. The IndiGrid team at the SPV should review the implementation of these on a regular basis and ensure grievances are resolved according to the GRM process defined in the ESMS. The ESMS monitoring included in ESAP #2 should also review the implementation of the SEP and GRM at each of the 5 assets

 The company will make publicly available this ESRS and ESAP and will keep a copy available at each SPV office.