IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Environmental and Social Impact Assessment and Management
Policies and Management Procedure.
IndiGrid has an HSE Policy committed to zero harm to people, the environment, and the community. The company recently revised its E&S Management System (ESMS) manual to encompass the broader scope of operations in greenfield project development and other asset classes, such as solar and energy storage systems. This ESMS manual encompasses policies, impact and risk assessment tools, and management programs, including those for OHS management, contract management, security personnel, emergency preparedness and response planning, stakeholder engagement, external communication, and monitoring and management reviews. These are aligned with the IFC PS and WGB General EHS guidelines. Following ESAP #1, GBPL will develop and execute project-specific management procedures to assess and mitigate the impacts and risks associated with the BESS project.
Impact Identification and Assessment.
IndiGrid’s ESMS manual outlines a management framework for impact identification and assessment, which includes E&S Impact Assessment (ESIA). Per national legal requirements, battery energy storage system projects do not require prior environmental impact assessment and environmental clearance. IndiGrid is a conducting an E&S Assessment and Management Plan (limited ESA) for the BESS project to identify E&S risks and impacts aligned with IFC PS requirements related to project design, project location (climate risk), supply chain, construction, operations, and decommissioning of the BESS Project, including Quantitative Risk Assessment (QRA). The ESA study is in progress and is pending completion. Per ESAP # 2, the GBPL will implement the E&S management plan aligned with IFC PS prepared as a part of a limited ESA and QRA study. It will maintain a risk register to identify all E&S risks continually during operations and management.
The company will be working with multiple contractors, including civil contractors, electrical contractors, battery and equipment suppliers, and a system integrator to commission the BESS Project. After commissioning, IndiGrid plans to handle the operation and management of the BESS Project internally and is developing in-house capability and experience by implementing the pilot BESS project in New Delhi. The company has a Health, Safety, and Environment (HSE) contractual requirement document specifying the contractors' obligations and outlining the procedures they need to follow. The HSE contractual document defines the duties and responsibilities of contractors, the appointment of HSE resources, HSE inspection and audits, contractor’s site HSE committee, requirement on storage of hazardous material, health hazard, and environmental control, welfare measures (toilets and drinking water), and includes HSE procedures on a range of issues includes a permit to work, electrical installations, LOTO, fire prevention and protection, PPEs, accident investigation and reporting, emergency response plan, etc. In addition to the general HSE contractual requirement document, GBPL will incorporate a construction E&S management plan that will be prepared as a part of limited ESA and other project-specific E&S provisions into the contractual agreements with the contractors and suppliers (ESAP #2).
Organizational Capacity and Competencies. At the corporate level, IndiGrid has established the EHSS/ESG team led by the ESG Head, who reports to the Chief Operating Officer. The corporate team is responsible for implementing the ESMS and driving E&S performance. At the operational level, IndiGrid follows a regional and cluster approach to environmental health and safety (EHS) management. The regional heads, supported by EHS representatives, are responsible at the asset level for the overall implementation of E&S procedures outlined in the ESMS during operation and maintenance activities and for reporting on E&S performance to the corporate team. GBPL will depute an EHS resource for the BESS project for E&S management and ESAP implementation and ensure that the contractor deploys adequate EHS resources for the project. (ESAP #3)
Emergency Preparedness and Response. IndiGrid has prepared a general Emergency Preparedness and Response (EPR) Plan, which is applied at the asset level. The EPR plan covers emergencies such as fire and explosion, animal attacks (including snake bites and insect attacks), oil and chemical spills, electrocution, falls from height, bomb threats, health-related emergencies, medical or accidental emergencies, and natural disasters and severe weather responses such as flooding. As part of ESAP #2, GBPL will customize the general EPR for the BESS Project and prepare a specific on-site EPR plan for fire and explosion in line with the QRA findings and ESMS manual, in consultation with GETCO and the other neighboring BESS developer. The EPR plan will encompass all potential emergencies, including fire, explosion, and toxic gas release from batteries due to fire. The plan will identify areas where accidents and emergencies may occur, communities and individuals that may be impacted, response procedures, provision of equipment and resources, designation of responsibilities, communications, and periodic training to ensure an effective response. The EPR plan will be aligned with the Disaster Management Plan for the area/region developed by state agencies.
Monitoring and Review: IndiGrid’s monitoring and review system includes ISO-related internal and external audits that meet national regulatory requirements. The annual sustainability reporting has yet to commence. As a part of project-specific ESMS, IndiGrid will develop the key performance indicators aligned with IFC PS and Good International Industry Practices along with targets and timelines for the E&S performance.
PS 2: Labor and Working Conditions
Human Resource (HR) Policies and Procedures. The BESS Project will not require a large labor force and is expected to employ fewer than ten people directly during operations. IndiGrid has implemented a set of corporate-level policies, including the Code of Ethical Business Conduct and an Employee Policy Manual that complies with national/state labor laws. The Employee Policy Manual covers various employee aspects, including induction, attendance, leave, transfers, relocations, exit procedures, loans and advances, medical insurance, compensation, and other benefits. It also includes the Diversity, Equality, and Inclusion (DEI) policy and guidelines for preventing sexual harassment in the workplace (POSH). The Code of Ethical Business Conduct includes elements on Whistle Blower, anti-discrimination, social media communication, and anti-corruption. IndiGrid has included a policy related to child and forced labor, freedom of association, and retrenchment in its updated ESMS manual, which is aligned with IFC PS. GBPL will ensure that IndiGrid’s HR policies and procedures applied to the project comply with the IFC PS2 requirements.
Grievance Mechanism. The grievance redressal mechanism is outlined separately as part of the company's stakeholder engagement policy and applies to internal and contractor employees. Grievances are received through email and addressed by the internal stakeholder grievance redressal committee, which is chaired by senior management and includes representatives from HR, legal, EHS, and governance. There is a separate Internal Complaint Committee (ICC) for POSH complaints. There is no heightened GBV risk in the project.
Occupation Health and Safety (OHS): As part of EHS policy, IndiGrid has established the process for assessing OHS-related hazards and risks and ensures that appropriate measures for elimination, reduction, and control of risks are in place, including the incident management procedure. The OHS procedures include Safety Committees, OHS training, provision of PPEs, incident management, and OHS performance monitoring. Besides general training on fire safety, first aid, emergency preparedness and response, incident reporting, and PPEs, IndiGrid OHS training includes specific training on electrical safety, permit to work, Hazard Identification and Risk Assessment (HIRA), and Job Safety Analysis (JSA). Its current OHS procedures are tailored to TL and solar operations. Per ESAP # 2, GBPL IndiGrid will prepare and implement the climate-responsive OHS procedure for the BESS Project based on the OHS risks and hazards assessment.
Supply Chain: The project supply chain includes one-time procurement of BESS and electronic components from international suppliers with connections to China. The internal due diligence process has identified suppliers up to the battery cell level. IFC due diligence indicates that the shortlisted supplier has a policy on modern-day slavery and a supply chain management system.
IndiGrid has no explicit supplier code of conduct, and its supply chain management system (SCMS) is tailored for the transmission line business. In accordance with ESAP# 4, IndiGrid/GBPL will update/develop SCMS for equipment procurement to ensure that a due diligence process is established to assess suppliers before entering a commercial relationship and that their practices are aligned with legal and IFC PS requirements. The SCMS will include an IFC PS-aligned code of conduct for suppliers, mapping of the supply chain, a procedure for due diligence of the potential equipment suppliers, contractual clauses requiring suppliers to comply with the code of conduct, engagement and disengagement procedure for when suppliers are found to be in breach of contractual obligations, supplier evaluation and verification procedure for compliance with code of conduct. IndiGrid/GBPL plans to appoint the Owners’ Engineer at the production site in China during the manufacturing period to ensure product quality. This gives IndiGrid/GBPL leverage to monitor and verify compliance with the PS2 requirement at the primary supplier’s manufacturing site. Further, IndiGrid/GBPL will extend the scope of the Owners’ Engineer for the BESS project to ensure compliance with the terms of the supplier agreement.
PS3: Resource Efficiency and Pollution Prevention
Resource Consumption: The BESS Project requires water solely for domestic purposes. It will not emit air pollution or generate waste. The project is expected to reduce greenhouse gas (GHG) emissions by charging the batteries with renewable energy. GUVNL has guaranteed that 85% of the energy used for battery charging will originate from renewable energy sources within the grid. The remaining 15% will likely come from non-renewable sources. Batteries will be charged using surplus energy available during the day, and the stored power will be discharged during evening or peak demand hours. This process facilitates the large-scale integration of renewable energy into the main grid systems. The projected annual GHG emissions for the BESS Project are 14,900 tons, with approximately 186,000 tons of GHG savings expected.
Pollution Prevention: The BESS project may generate white noise characterized by buzzing and humming sounds, during the charging and discharging process associated with the site’s high-voltage electrical equipment (inverters and transformers). The nearest residential area is located about 300 meters from the project site. Under ESAP #2, as a part of the limited ESA, GBPL will assess the noise impacts on the nearby sensitive locations, develop and implement a noise management and monitoring plan, and ensure compliance with the WBG General EHS standards.
Battery Waste Management: As per the project agreement with the GUVNL, GBPL is required to decommission the project at the end of the agreement period. This entails developing a draft decommissioning plan and ESMP that align with IFC PSs, EHS guidelines, current national regulations, and IFC responsible exit mechanism before exiting the IFC (ESAP #5). GBPL will update the draft decommissioning plan one year prior to the start of the decommissioning commencement date and ensure its execution follows the plan.
The project is expected to generate battery and electronic waste during operations and decommissioning. According to ESAP #2, GBPL will develop and implement battery waste and e-waste management procedures to comply with national regulatory requirements and adhere to recognized international good industry practices. It will integrate appropriate contractual clauses in the supplier agreement to provide an “end-of-life” plan and recycling responsibilities. Under the local Battery Waste Management Rules 2022, the battery importer is considered a “Producer” and must obtain registration from the Central Pollution Control Board for battery import activities, even for in-house use. The producer is responsible for Extended Producer Responsibility to fulfill the recycling or refurbishment commitments directly or via authorized agencies. IndiGrid will fulfill these regulatory obligations and battery waste management.
PS 4: Community Health, Safety, and Security
Community Health and Safety. The BESS Project operations don’t involve any hazardous material and are not expected to impact community health and safety. The BESS risks fire and explosion due to thermal runaway and off-gassing from batteries. The project site is in the GIDC industrial area. The nearest habitation is about 300 m from the project site. The relevant portion of the EPR plan will be shared with relevant government agencies and external stakeholders who could potentially be affected. The project will train the community in the nearest village on the EPR. The transportation of containerized batteries for installation during construction may involve safety risks. GBPL will ensure adequate safety measures and an off-site EPR plan in the supplier’s agreement to address the safety risk during transportation and construction.
Life and Fire Safety (L&FS): The Life and Fire Safety (L&FS) measures for the battery container include a fire detection and suppression system, combustible gas detection and venting system, deflagration provision for explosion mitigation, HVWS provision, and early thermal runaway detection. IndiGrid is required to comply with UL-1973 (batter safety certification), IEC 62281 / UN 38.3 (certification for safety of lithium-ion batteries during shipping), IEC 61850 / DNP3 (computer communication), IEC 61508 (functional safety of electrical and electronic systems), and UL-9540 (certification for thermal runway prevention) certifications as per the project agreement with GUVNL. As per the company information, the project will be designed with the NFPA 855 code for energy storage system installation, with every container equipped with fire safety provisions. GBPL will integrate the recommendations of the QRA study into the project design and EPR plan. IndiGrid will design and implement the BESS Project according to standards, including NFPA 70E Standard for Electrical Safety in the Workplace, NFPA 69 (standard on explosion prevention systems), and IEC 62619 (tests for the safe operation of batteries used in industrial applications).
Security Personnel. In compliance with previous investment ESAP requirements, IndiGrid has developed a security management procedure aligned with IFC requirements. IndiGrid hires unarmed security personnel through licensed third-party security agencies. These agencies conduct screening and submit police verification certificates to IndiGrid. The security personnel are trained on POSH and community interaction. The IndiGrid procedures and practices will be applied to the BESS project.
