This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012). Based on information reviewed by IFC, the proposed project will have limited adverse E&S impacts that are few, site specific, largely reversible and readily addressed through existing mitigation measures and good international industry practices (GIIP).  Key E&S issue and risks associated with the project include: (i) EPC procurement & contractor E&S management; (ii) cumulative impacts on water resources, and loss of agricultural land; (iii) construction phase impacts related to OHS, traffic risks, community safety & waste management; (iv) labour aspects in line with PS 2 requirements; (v) operation phase impacts related to water use, drainage, and waste management (broken solar panels); (vi) land procurement process & alignment with PS 5 requirements and physical/economical displacement from land acquisition (if any) for RoW of the T-line; (vii) supply chain aspects related to procurement of solar panels and cells; (viii) stakeholder engagement.

Brookfield RJ manage labor risks in their solar supply chain through several processes used to evaluate and monitor their supplier’s compliance with their ESG policies, including on human rights. These processes involve adherence to a Supplier Code of Conduct (CoC), implementing a Supply Chain ESG Assessment, integrating labor-related clauses in purchase orders, and as warranted, on-site audits by third-party inspection agencies.

Bird surveys conducted in March 2023 confirmed that there are no impacts on Critical Habitats (CH), and that the project area is located outside of the Great Indian Bustard (GIB) potential zone. There are wetlands nearby that may play host to migratory waterbirds and carcass dumping was identified in proximity to the transmission line which may act as an attraction for raptors (vultures and eagles).  Both risks related to the wetlands and carcasses will be managed using high-quality bird diverters on the transmission line.

Brookfield RJ Environmental and Social Management System (ESMS) is based on relevant policy commitments, effective management programs, and appropriate E&S organizational capacity. IFC’s E&S due diligence for the project identified only three material gaps between Brookfield RJ’s ESMS and the requirements of the IFC Performance Standards on Environmental and Social Sustainability (2012). These gaps are described in the respective PS5 (ESAP#1), PS6 (ESAP#2), and Stakeholder Engagement (ESAP#3) sections that follow. The measures required to address these PS gaps are described in the disclosed project Environment and Social Action Plan (ESAP).

Brookfield RJ corporate Environmental, Social and Governance (ESG) Policy and Health, Safety, Security, and Environment (HSS&E) Management System apply to all their business operations and help to ensure that their contractors and suppliers work to the same E&S standards as Brookfield RJ employees. Brookfield RJ HSS&E management philosophy emphasizes the importance of leadership, line management accountability, managed system approach, and the identification and elimination High-Risk hazards as the cornerstones to HSS&E performance excellence. Similar to IFC PS and WBG EHS, Brookfield risk assessment process follows a risk mitigation hierarchy that starts with the controls perceived to be most effective and moves down to those considered least effective (Elimination - Substitution - Engineering controls - Administrative controls - Personal protective equipment– Brookfield RJ identify E&S risks and opportunities relevant to their investments and adapt their due diligence and management work accordingly. Commensurate with the nature and scope of their project E&S risks and impacts, Brookfield RJ mobilize additional internal experts and/or third-party consultants as needed. For this proposed 400 MW solar power project Brookfield RJ engaged Deloitte Touche Tohmatsu India LLP (DTTILLP) to undertake the attached Environmental and Social Impact Assessment (ESIA). This ESIA is well aligned with IFC PS and WBG EHS requirements, the only gaps being those included in the project ASAP.

Brookfield RJ ESG Steering Committee sets corporate goals for priority ESG topics, shares best practices, monitors progress and performance (including of contractors), and seeks opportunities for continuous improvement. In 2021, Brookfield RJ priority ESG goals included performance targets related to climate change, biodiversity, Occupational Health and Safety (OHS), supply chains, and water and waste management, among others. The ESG Steering Committee is chaired by a Chief Operating Officer (COO) and includes the CEOs of regional businesses, the Chief Sustainability Officer (CSO), the Chief Risk Officer (CRO) and ESG and operations experts from across their businesses. The ESG Steering Committee monitors and reports on key performance indicators (KPIs) such as greenhouse gas emissions, gender diversity, Employee Lost Time Incident Rates, among others.

At the project level, Brookfield RJ Corporate HSSE Head supports the onsite Project HSSE Manager who works closely with the contractors’ HSSE Officers through daily inspections, weekly planning and review meetings, joint training sessions, and periodic HSSE audits. Brookfield RJ have site specific E&S management programs including worker induction and training, waste management, traffic management,emergency response, among others, that are aligned with IFC PS and World Bank Group Environment, Social, Health Guidelines (EHS). . The roles and responsibilities for various teams responsible for medical emergency, evacuation, rescue, firefighting etc. are defined and will be displayed at various locations across the site. The company’s E&S management systems are noted to be commensurate with the scale and E&S risks and impacts of its operations, and the implementation at the project level likely to be effective.    

Brookfield RJ have signed a Module Supply Agreement for the purchase of the proposed project solar panels from a large international module manufacturer. Brookfield RJ and IFC due diligence of this solar module supplier’s supply chain has confirmed significant evidence of compliance with all applicable labor and human rights requirements. The proposed project supply chain risks were found to be limited.  

Brookfield RJ have signed the Solar Industry Forced Labor Prevention Pledge to oppose the use of forced labor in the solar supply chain and raise awareness within the industry on this important issue. They also support the Solar Energy Industry Association’s (SEIA) solar supply chain traceability protocol as a tool for identifying the source of primary raw materials and inputs, and tracking their incorporation into finished solar products.

 IFC review of Brookfield RJ Human Resources (HR) policies and procedures confirmed that they are consistent with the national labor regulations and IFC PS 2 requirements. The Brookfield RJ Employee Handbook provides staff with a working guide to the day-to-day administration of HR policies and practices at Brookfield RJ, including on such topics as recruitment, selection and on-boarding, compensation and benefits, freedom of association, employee grievances, and various policies against sexual harassment, forced labor, etc.

Brookfield RJ’s grievance mechanism allows for submission of anonymous complaints, and is also available to the contractors’ workers who are included in training and awareness campaigns conducted by Brookfield RJ HR, ESG and HSSE teams. Brookfield RJ teams also assess and monitor their contractors and suppliers’ compliance with applicable labor laws and Brookfield RJ corporate policies. Where part of a contractor’s E&S management system does not meet the requirements of Brookfield RJ’s ESG and/or HSSE policy commitments, they sign gap bridging contract documents with these contractors to agree on how to jointly address the identified performance gaps.

Due to the presence of existing solar facilities and nearby villages and towns in the Bikaner district, the project contractors do not intend to provide any onsite worker accommodations. Local recruitment will be managed by Brookfield RJ and project contractors. Local male residents from the surrounding villages have expressed considerable interest in employment opportunities during the construction and operations phases. Women in this part of India typically have lower participation rates in formal employment. However, Brookfield RJ’s commitment to diversity and inclusion can help to provide a more equitable work experience for all potential workers. For more on project / community relations, see the Stakeholder Engagement section below.     

Brookfield RJ Occupational Health and Safety (OHS) management philosophy emphasizes the importance of leadership, management accountability, managed system approaches, and the identification and elimination of high-risk hazards as the cornerstones of excellent performance. Health and safety systems are tailored to business-specific risks and integrated into the management of the business. Policies and procedures apply to Brookfield RJ employees, contractors, and subcontractors, and focus on ensuring public safety.

Training and coaching programs help ensure that Brookfield RJ employees have the necessary skills to conduct their work safely and efficiently. Globally in 2021 Brookfield employee Lost-Time Injury (LTI) rate was a very respectable 0.8 per 200,000 hours worked. Again across all Brookfield international operations in 2021 they report one tragic contractor fatality involving a vehicle accident. Brookfield RJ responded to this incident by reinforcing their safety procedures and conducting a comprehensive safety investigation to determine both the immediate and underlying causes of the event and to highlight any potential improvements to be made to their HSS&E management system.

 IFC reviewed Brookfield RJ’s resource efficiency and pollution preventions measures for the proposed project and found these to be commensurate with the nature and scope of the project risks and impacts, and consistent with PS3 requirements and WBG EHS Guidelines. No PS3 related gaps were identified. The following paragraphs in this section identify key examples of Brookfield RJ actions that informed IFC’s PS3 compliance assessment.  

Aligned with their ESG policy, Brookfield RJ are implementing several initiatives to reduce energy and water consumption. For example, the company currently operate 14 solar sites in water-stressed regions of India. Three of these sites have deployed robotic dry-cleaning technology for their solar panels, which reduced water use by 85%. Brookfield RJ also plan to use this dry robotic technology at the proposed water-stressed Bikaner project site. Brookfield RJ and sub-contractors will purchase water for the project needs from authorized tankers utilizing the Indira Gandhi Nahar Pariyojana (IGNP) canal located 8 km from the project site, among other sources. By adopting these water reducing and responsible sourcing practices, Brookfield RJ will reduce the cumulative effects of increased demand for water from the several existing solar parks in the Bikaner District.    

The project will generate limited quantities of non-hazardous and some hazardous wastes. Hazardous and non-hazardous wastes will be collected for disposal by authorized service providers specialized in each type of waste. Brookfield RJ waste management procedures for sorting, handling, storage, and disposal are consistent with applicable legal requirements, Good International Industry Practice (GIIP), WGB EHS Guidelines, and will apply to all project sub-contractors.   

Brookfield RJ E&S management system provides all the critical elements required to successfully manage the proposed project community health, safety and security risks, including a Road Travel Safety procedure, a Security Management Plan, and a Health & Hygiene Checklist, among others. Brookfield RJ use noise control measures, warning signs, and water, air quality, and biological hazards monitoring implement these programs.

 The proposed project’s location and site characteristics will also help to reduce community health, safety, and security risks and impacts. For example, by choosing to lease privately owned arid scrublands and rainfed formal agricultural lands next to Kawni village in Rajasthan, the project will avoid potentially significant impacts on surrounding communities from migrant workers, increased traffic, movement of heavy equipment, and increased dust and noise during construction. Kawni is connected to Bikaner City - the District capital 28 Km away - by an existing two-lane asphalt road. This existing road will be used to access the project site during construction and operation phases of the project.

The project will have its own security guards who will be unarmed and trained in emergency response, human rights and engagement with workers and the public. Brookfield RJ’s comprehensive HSS&E management system further decreases the likelihood and significance of any community-related E&S risks and impacts by identifying, assessing, and avoiding them where possible, and minimizing and compensating were this is not entirely avoidable. Additionally, community members can anonymously report any concerns through the Brookfield RJ ethics hotline (see below under the Stakeholder Engagement section). For these reasons IFC review of the proposed project’s PS4-related risks and impacts did not identify any compliance gaps.

 The Project is located within the Thar Desert Ecoregion which is characterised by a desert landscape consisting of grasslands, tropical dry forests, sand dunes and rocky plains.  The Project area is not within any protected areas or internationally recognised areas for biodiversity but is located 10km north of the Great Indian Bustard (GIB) Potential Zone, although this area is designated for future use if the population recovers with the remnant population occurring approximately 200km further to the west and south.

The project area consists of mainly modified habitats consisting of agricultural areas and settlements that are traversed by existing transmission lines.  Areas of natural habitat are limited to dunes and small patches of grasslands as well as a natural waterway, none of which occur within the Project area.

Based on surveys conducted of the Project site, no priority biodiversity values were identified within the Project area.  The surrounding area does however play host to soaring birds and water birds, including vultures, eagles, and cranes.  Of interest is the presence in the vicinity of the project being migratory water birds, including Anthropoides virgo Demoiselle Crane (IUCN LC) which congregates in waterbodies as well as Egyptian Vulture Neophron percnopterus (IUCN EN) and Indian Vulture Gyps indicus              (IUCN CR) which may infrequently occur within the landscape.

Primary project related impacts are likely to be the result of potential collisions of soaring and water birds with the transmission line and incidental mortalities of ground dwelling fauna during construction activities.   Preparation of a Biodiversity Management Plan (ESAP #2) as part of the ESMS is therefore recommended to reduce risks to fauna values.  Installation of bird diverters and carcass management strategies to reduce risks to soaring and water birds will also be required.                           

  Not Applicable.                                                   

Not Applicable.                                           

Brookfield RJ ESG policy recognizes the importance of engaging with and providing value for the communities in which they operate. Brookfield RJ report publicly on progress achieved towards their corporate ESG targets and project level commitments through their annual ESG Report available on their website (https://bep.Brookfield RJ.com/bep/responsibility). They also maintain an ethics reporting hotline for employees, vendors, partners, community members and other interested stakeholders to anonymously report any concerns or raise any issues free of discrimination, retaliation, or harassment (see www.Brookfield RJ.ethicspoint.com).  

However, due to the early pre-construction stage of the proposed project in May 2023, stakeholder engagement had largely been restricted to the lease negotiations process with landowners, and permit processing with local regulatory authorities. Other relevant stakeholders, especially local villagers, have not been engage, despite having high expectations for project employment and development opportunities.  For this reason, Brookfield RJ will develop a Stakeholder Engagement Plan (SEP) and Grievance Mechanism that is tailored to the characteristics and interests of the members of the broader Affected Communities (ESAP#3). The SEP will identify key project-related employment and development opportunities and provide easy-to-understand summaries of the key issues and commitments adopted in Brookfield RJs corporate E&S policies, employment recruitment programs, Livelihood Restoration Plan, Corporate Social Responsibility initiatives, gender inclusion measures, Emergency Preparedness and Response Plan, and grievance mechanisms, among others.

Unit No 702, 7th Floor, Tower No 3, Equinox Business Park,

Kurla (West) Mumbai 400070, Maharashtra, India