india infrastructure finance company limited

INDIA INFRASTRUCTURE FINANCE COMPANY

LIMITED

ENVIRONMENTAL SAFEGUARDS DUE DILIGENCE REPORT (50 MW Solar PV Project’ of Welspun Solar AP Private Limited, Jodhpur, Rajasthan)

WELSPUN SOLAR AP PRIVATE LIMITED

September 2013

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India Infrastructure Finance Company Limited

Due Diligence Report on Environmental Safeguards

Due Diligence Report on Environmental Safeguards I

CONTENTS

1. PURPOSE OF THE REPORT ..................................................................................................... 1

2. INTRODUCTION ......................................................................................................................... 1

3. APPRECIATION OF THE SUB-PROJECT ................................................................................ 1

3.1 PROJECT DESCRIPTION .................................................................................................................................................................. 1 3.1.1 Site Setting ................................................................................................................................... 2 3.1.2 Technology & Design ................................................................................................................... 4 3.1.3 Solar PV modules ......................................................................................................................... 5 3.1.4 Power Conditioning Units (PCU)/ Inverters .................................................................................. 5 3.1.5 Circuit Breakers ............................................................................................................................ 5 3.1.6 Transformer .................................................................................................................................. 5 3.1.7 Cabling ......................................................................................................................................... 5 3.1.8 Control Room ............................................................................................................................... 6 3.1.9 Power Evacuation ........................................................................................................................ 6 3.1.10 Energy Yield Prediction ................................................................................................................ 6 3.1.11 Operation and Maintenance ......................................................................................................... 6 3.1.12 Manpower ..................................................................................................................................... 6 3.1.13 Utilities and Infrastructure ............................................................................................................. 6

4. APPROACH AND METHODOLOGY ......................................................................................... 7

4.1 ACTIVITY1: PROJECT SITE VISIT ................................................................................................................................................ 7 4.2 ACTIVITY2: CONSULTATION WITH DEVELOPER ............................................................................................................... 7 4.3 ACTIVITY-3: PREPARATION OF EDDR ..................................................................................................................................... 7 4.4 ACTIVITY 4: JOINT SITE VISIT WITH THE WORLD BANK AND UPDATING DDR ................................................... 8 4.5 SCOPE OF WORKS............................................................................................................................................................................. 8

5. ENVIRONMENTAL BASELINE OF THE PROJECT SITE ........................................................ 8

5.1 TERRAIN ............................................................................................................................................................................................... 8 5.2 LAND USE ............................................................................................................................................................................................ 9 5.3 SURFACE WATER ............................................................................................................................................................................. 9

5.3.1 Interpretation of Surface Water Quality Results ........................................................................... 9 5.4 GROUNDWATER ............................................................................................................................................................................... 9 5.5 CLIMATE & METEOROLOGY ....................................................................................................................................................... 9 5.6 AIR AND NOISE QUALITY ........................................................................................................................................................... 10 5.7 SOIL ...................................................................................................................................................................................................... 10

5.7.1 Interpretation of soil testing results ............................................................................................. 10 5.8 SEISMIC HAZARD ........................................................................................................................................................................... 10 5.9 GEOLOGY ........................................................................................................................................................................................... 10 5.10 HYDROGEOLOGY ........................................................................................................................................................................... 11 5.11 ECOLOGY ........................................................................................................................................................................................... 11

5.11.1 Floral Diversity ............................................................................................................................ 11 5.11.2 Faunal Diversity .......................................................................................................................... 11 5.11.3 Ecologically Sensitive Area ........................................................................................................ 11

5.12 SOCIO ECONOMIC PROFILE ....................................................................................................................................................... 11 5.13 DEMOGRAPHIC PROFILE ............................................................................................................................................................. 12

5.13.1 Education and Literacy ............................................................................................................... 12 5.13.2 Economic Activity and Livelihood Pattern ................................................................................... 12

Welspun Solar AP Private Limited

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Due Diligence Report on Environmental Safeguards II

6. ENVIRONMENTAL SAFEGUARD DUE DILIGENCE .............................................................. 12

6.1 POLICY, LEGAL AND REGULATORY REQUIREMENTS .................................................................................................. 12 6.1.1 Legal Setting .............................................................................................................................. 13 6.1.2 Policy Setting .............................................................................................................................. 14 6.1.3 Other Legislations Applicable to Construction Activities: ............................................................ 14 6.1.4 Compliance to Clearance Requirements .................................................................................... 15

6.2 ANALYSIS OF ALTERNATIVES – SITE SELECTION ........................................................................................................... 15 6.3 ASSESSMENT OF ENVIRONMENTAL IMPACTS & MITIGATION MEASURES ........................................................ 16

6.3.1 During Construction Activities ..................................................................................................... 16 6.3.2 During Operational Activities ...................................................................................................... 21 6.3.3 Decommissioning Phase ............................................................................................................ 22

6.4 PUBLIC CONSULTATION DURING PLANNING AND CONSTRUCTION STAGE ...................................................... 22 6.5 ENVIRONMENT MANAGEMENT ACTION PLAN ................................................................................................................ 23

6.5.1 Environmental Monitoring Plan ................................................................................................... 28

7. FINDINGS AND RECOMMENDATIONS .................................................................................. 29

LIST OF TABLES

Table 1: Project Highlights ................................................................................................................................................................. 1

Table 2: Statutory clearance required and present status of clearance .............................................................................................. 15

Table 3: Key outcomes of the Consultations during Planning and Construction stages ................................................................... 22

Table 4: Key Outcomes of the Consultations during Planning and Construction stages................................................................... 23

Table 5: Environmental Mitigation Action Plan ............................................................................................................................... 23

LIST OF FIGURES

Figure 1: Project Location .................................................................................................................................................................. 3

Figure 2: Project Site Layout – 50mw Solar Power Plant ................................................................................................................... 4

Figure 3: Grid Connected System – Basic System Design ................................................................................................................. 5

LIST OF APPENDICES

Appendix 1: CTE under Water Act

Appendix 2: CTO under Water Act

Appendix 3a & b: MOEF Memorandum

Appendix 4: Tree cutting

Appendix 5: Ground Water Guidelines

Appendix 6: Site Plan including Landscaping Plan

Appendix 7: Plantation Plan

Appendix 8: EHS Policy

Appendix 9: Occupational Health & Safety

Appendix 10 : Corporate Social Responsibility

Appendix 11 a & b: Contract between WSAPPL & Karnimata Construction Company

Appendix 12: Quarterly Compliance Report to RPCB


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Due Diligence Report on Environmental Safeguards III

ABBREVIATIONS

CGWA : Central Ground Water Authority

CRZ : Coastal Regulation Zone

CSR : Corporate Social Responsibility

CTE : Consent to Establish

CTO : Consent to Operate

DFO : Divisional Forest Officer

EDDR : Environmental Due Diligence Report

EHS&S : Environmental, Health, Safety & Sustainability

ESIA : Environmental and Social Impact Assessment Report

ESSF : Environmental and Social Safeguards Framework

IIFCL : India Infrastructure Finance Company Limited

JNNSM : Jawaharlal Nehru National Solar Mission

LASA : LEA Associates South Asia Private Limited

MoEF : Ministry of Environment & Forests

NAAQS : National Ambient Air Quality Standards

NVVN : NTPC Vidyut Vyapar Nigam Limited

O&M : Operation and Maintenance

OHS : Occupation Health and Safety

PPA : Power Purchase Agreements

PPE : Personal Protective Equipment

RoW : Right of Way

RREC : Rajasthan Renewable Energy Corporation

RSPCB : Rajasthan State Pollution Control Board

RVPNL : Rajasthan Rajya Vidyut Prasaran Nigam Ltd.

SEIAA State Environment Impact Assessment Authority

ST : Scheduled Caste

WSAPPL : Welspun Solar AP Private Limited

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Due Diligence Report on Environmental Safeguards 1

ENVIRONMENTAL SAFEGUARD DUE DILIGENCE

1. PURPOSE OF THE REPORT

1. This Environmental Due Diligence report has been carried out by India Infrastructure Finance

Company Limited (IIFCL) in consultation with the Project Developer, Welspun Solar AP Private Ltd.

(WSAPPL) (50MW at Phalodi) to assess the adequacy of the project with the applicable National and

World Bank Social Safeguard policies. The report has been prepared as per the documents received from

project developer and site visit observations.

2. IIFCL as part of its infrastructure scheme has approved Rs 80.00 Cr. to Welspun Solar AP Private

Ltd. (WSAPPL) out of the total project cost of Rs 472.68 Cr. Out of the approved Rs 80.00 Cr., IIFCL has

already disbursed Rs 79.53 Cr. to WSAPPL.

3. World Bank has sanctioned US$ 195 million line of credit to IIFCL to encourage flow of private

investments into infrastructure. The sub-project has been considered for refinancing by IIFCL from

Bank’s line of credit. In order to be eligible for funding from the WB loan facility, IIFCL has prepared the

Environmental Due Diligence Report (EDDR) for the sub-projects on behalf of WSAPPL, and all the

information given in the EDDR is agreed by WSAPPL.

2. INTRODUCTION

4. India Infrastructure Finance Company Limited (IIFCL) has retained LEA Associates South Asia

Private Limited (LASA) as Consultant for the review of sub-projects from social, environmental,

procurement, technical and legal perspectives for its credit review process and post-sanction monitoring of

sub-projects. LASA has been carrying out detailed due diligence of sub-projects to be financed by IIFCL

in order to ensure that the sub-projects comply with social safeguard operational policies of the World

Bank. This is the due diligence report on environmental safeguards for the sub-project ‘50 MW Solar PV

Project’ of Welspun Solar AP Private Limited (WSAPPL).

3. APPRECIATION OF THE SUB-PROJECT

3.1 PROJECT DESCRIPTION

5. WSAPPL is in the process of establishing a 50 MW Solar Photovoltaic Power plant at Phalodi

Taluka of Jodhpur district in Rajasthan. The solar plant will be based on advanced PV technology with

highest conversion efficiency, wherein solar energy is converted directly into electricity. The Project will

be developed under Jawaharlal Nehru National Solar Mission (JNNSM) and will generate 91.98 million

units of electricity every year. The entire power generated from the project will be purchased by NTPC

Vidyut Vyapar Nigam Limited (NVVN) through state DISCOM. The life of the project is 25 years and the

proposed land will be leased from Government of Rajasthan for a period of 30 years. Three separate power

purchase agreements (PPA) will be signed with NVVN to this effect and the PPA will be based on the

Tariffs offered by WSAPPL in the JNNSM bidding and will be applicable for the entire life of the Plant.

Summary of project information is provided in Table 1.

Table 1: Project Highlights

Sl. No. Parameter Information

1 Project Owner Welspun Solar AP (P)Limited

2 Project Capacity 50 MW

3 Technology Photovoltaic

4 Total Investment Rs 472.68 cr

5 Generation per annum 91.98 million units

6 Capacity Utilization Factor 21%

7 Project Life 25 years

8 Tariff Period 25 years

9 Debt Equity Ratio 75:25


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10 Construction Period 12 months

11 Commercial Operation Date 26th February 2013

12 Levelized Tariff for 25 years

20 MW @ Rs 7.97/kwh

15MW @ Rs 8.05 /kwh

15MW @ Rs 8.14 /kwh

13 Power Evacuation RVPNL

14 Project Site Kanasar and Rawra Village in Phalodi Teshsil, Jodhpur District

15 Total area 1080 bigha1

16 Type of land Government land allotted by Government of Rajasthan

17 Ecologically Sensitive Area No legally notified ecologically sensitive area viz national parks, wild life

sanctuaries etc. existing within 10km radius of the project site

18 Site coordinates Between latitude 270-06 to 270-09 North and 720-20 to 720-23 East

Source: Information Memorandum, 2012. Welspun Solar AP Private Ltd.

3.1.1 Site Setting

6. The proposed project site lies in Phalodi Tehsil of Jodhpur District which is surrounded by Bikaner,

Nagaur and Jaisalmer Districts. This area forms a part of the Thar Desert region. The altitude of the site is

270 meters above MSL. The total area of the proposed project site is 350 acres. It is well connected by

roads and railways. National Highway NH-15 (Pathankot-Kandla) and State Highway SH-2 (Jodhpur-

Jaisalmer) passes through Phalodi town. The nearest railway station is Phalodi RS located at a distance of

38 kms from the project site in southeast direction. The proposed project site is levelled and favourable for

setting up a solar PV plant. Figure 1 shows the location of the project site. The project site layout plan is

shown in Figure 2.

1 ~ 350 acres


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Figure 1: Project Location


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Figure 2: Project Site Layout – 50mw Solar Power Plant

3.1.2 Technology & Design

7. The proposed 50 MW solar power plant is of Grid Connected System type, producing a large

quantity of photovoltaic electricity at a single point.

8. The system consists mainly of the following:

Solar PV array – Solar PV arrays are used to produce DC electricity when solar rays are incident on it.

Power Conditioning Units (PCU) – PCU helps in converting DC (Direct Current) electricity into AC

(Alternating Current) electricity and facilitate synchronization with the grid power.

Transformers – which transform the AC output of the Power Conditioning Units to the level required at

the grid.

9. A grid connected SPV power plant consist mainly of the following components:

Solar PV Modules

Module Mounting System

Power Conditioning Units/Inverters

Circuit Breakers

Transformers


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Figure 3: Grid Connected System – Basic System Design

3.1.3 Solar PV modules

10. A solar photovoltaic module is constructed from individual solar cells. Modules connected in series

are known as strings. The strings are connected to the String Monitoring Units (SMUs) and the SMUs are

connected to the PCUs which convert DC to AC power supply.

11. Thin film type PV modules will be used in the proposed project having south facing orientation,

tilted at 22° from the horizontal plain to maximize the total annual incident solar irradiation.

12. The course of the transmission line will be selected based on techno-economic feasibility.

3.1.4 Power Conditioning Units (PCU)/ Inverters

13. The Power Conditioning Units used in grid connect SPV systems consist of an inverter and other

electronics for MPPT, Synchronization and remote monitoring. Inverter is the most complicated part of the

PV system. It has to act as the interface between the PV array and the Grid.

3.1.5 Circuit Breakers

14. The circuit breaker will be restrike free under all duty conditions and will be capable of breaking-

magnetizing current of transformer and capacitive current of unloaded overhead lines without causing over

voltages of abnormal magnitudes.

3.1.6 Transformer

15. The AC power from the PCUs are fed into lower voltage panel and then to transformers through

isolators and circuit breakers. Transformers have been selected to operate at maximum efficiency and

withstand a maximum temperature rise of 50°C with a daily average ambient temperature at 45°C.

3.1.7 Cabling

16. Modules will be interconnected to form a string of modules using these leads. For further

connections, single core, 6mm2 multi-stranded copper cables will be used to connect the strings to the

String Monitoring Unit (SMU). These cables will be cross-linked polyethylene insulated with ultraviolet

(UV) and temperature resistant solar grade cables.


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3.1.8 Control Room

17. The objective of control room will be to house all electronic equipments like PCUs, low voltage

panels, high voltage panels, metering and protection, etc.

3.1.9 Power Evacuation

18. Power will be evacuated from proposed 50 MW solar power plant to electric sub-station at Bap

village. The SPV array (constituting solar PV modules of selected rating connected in series to build up the

required voltage in parallel to build up the required current) of the designed DC power produces DC

electricity when Solar insolation is incident on it. The DC power thus produced is taken through various

junction and isolators and connected to the PCU.

19. The PCU houses the inverter circuitry which converts DC power supply into AC power supply, the

synchronization circuitry which actualizes the tie-up of solar PV source to the grid source and the remote

monitoring and control circuitry. A number of PCUs are connected in parallel to buildup the required AC

power, and combiners permit AC output power at 3 Ph, 315 V, 50 Hz to be fed into transformers. Power

generated will be stepped up to 132 kV level and from the switchboard located in main control room, will

be evacuated to sub-station through overhead transmission line.

3.1.10 Energy Yield Prediction

20. Total annual generation from the 50 MW Power plant is expected to reach 92,166 MWh.

3.1.11 Operation and Maintenance

21. Depending on the O&M requirements, the firm will make necessary arrangements for proper

implementation of O&M. During the commissioning of the plant, training will be imparted to the Engineer,

Supervisor and Operators. Theme of the training will be according to the plant’s O&M manual. This

operational training will cover (i) the nature, purpose and limitations of all plant and equipment; (ii) the

detailed operating instructions on each section and equipment of the plant; and (iii) the emergency

procedures and all related HSE issues according to the standards.

3.1.12 Manpower

22. The proposed 50 MW power plant proposed to create employment opportunity for approximately

600 persons during construction phase and approximately 15 persons during operation phase at the project

site. During the construction phase, a labor camp was organized with relevant capacity, facilities including

sanitation. Since the project is now in operational phase, there is no longer a labor camp and currently

employed persons have their own arrangements of stay.

3.1.13 Utilities and Infrastructure

23. Water is mainly required to clean up the module during the operation phase. Assuming a minimum

of 2 to 3 liters of water per module, the water requirement for cleaning of the whole plant (4,31,950

modules) and other needs is around 12,95,850 liters. However, the cleaning of modules will be undertaken

once in 30 days. Annual requirement will be around 1, 55, 50,200 litres of water.

24. For solar module cleaning, 3 PVC tanks (each of 10 cum) are proposed to be provided and built at a

suitable location. Near the tanks, pump (of capacity 10 cum/hr) will be provided which will pump water

into piping network that will be laid around the plant having pipe tapping at regular intervals.

25. Power: A minimal LT power is required for the project at the time of plant construction. Estimated

power requirement for project is 100 kW.


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4. APPROACH AND METHODOLOGY

26. The EDDR reviews the available documents and assesses the compliance of the subproject with

respect to (i) regulatory clearances (environmental clearance, forest clearance, etc.), (ii) Environmental

safeguards as per Environment and Social safeguard framework (ESSF) of IIFCL and applicable

operational policies of World Bank (iii) analysis of alternatives; (iv) the process of identifying

environmental impacts and integration of environmental management measures; (v) public consultation

and information disclosure etc. The approach adopted for the preparation of EDDR are as follows:

4.1 ACTIVITY1: PROJECT SITE VISIT

27. A site visit was conducted by the DDR consultant on 20th Dec 2012 to

(i) appreciate the project site and environmental conditions and understanding key environmental issues

including: presence of any ecological hot spots like sanctuaries and wildlife areas in the vicinity of the

project site ;

(ii) interaction with project authorities

(iii) understand the environment management measures undertaken, details pertaining to project team to

implement such measures;

(iv) assess the health and safety practices adopted and preparedness of the team to address the emergency

situation if any; and ,

(v) monitoring and evaluation arrangements w.r.t environment safeguards at the project site.

4.2 ACTIVITY2: CONSULTATION WITH DEVELOPER

28. Subsequently, a meeting of the due diligence consultants has been held with the Developer- Welspun

Solar AP Private Limited Ltd. on 19th January 2013 to collect information and discuss on the compliance

to the various clearance conditions by the State Pollution Control Board apart from discussions on the

capacity of the EHS team of Welspun and the roles and responsibilities in effectively implementing the

EMP provisions.

(i) ESIA Report prepared by Senes consultants

(ii) Carry out discussions on The Consent to Establish, under Water (Prevention & Control of Pollution)

Act, dated 24th August 2012, issued by Regional Office, Jodhpur of RSPCB and the Consent to

Operate, under Water (Prevention & Control of Pollution) Act, dated 04.01.2013, issued by Regional

Office, Jodhpur of RSPCB.

(iii) Application to Tehsildar for felling of Khejri trees at the site for placing the solar modules

(iv) Green Belt Development Plan, Landscaping plan within the premises of the Solar power plant

(v) Plantation programme of WSAPPL outside the plant premises, along the approach road for 5km.

(vi) Details of Rainwater harvesting system proposed at the site

(vii) Whether environment management, health & safety (EHS) measures had been incorporated in the

contract and has been adequately addressed during construction

(viii) Role of EHS department personnel in monitoring effective implementation of environment measures

proposed.

(ix) Project implementation arrangements for implementation of environmental measures.

4.3 ACTIVITY-3: PREPARATION OF EDDR

29. Preparation of EDDR which included

(i) Review of available documents and collating information from various documents to assess the possible

environmental impacts of the project and

(ii) Compilation of EMP by taking information on several measures integrated in the project documents.


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4.4 ACTIVITY 4: JOINT SITE VISIT WITH THE WORLD BANK AND UPDATING DDR

30. A joint site visit has been carried out to the project site during 23rd April to 25th April 2013, along

with the World Bank and IIFCL officials on the basis of review of draft ESDDR submitted by due diligent

consultant. The comments received based on review of ESDDR and observations made by the World Bank

during the site visit have been considered to update the ESDDR.

4.5 SCOPE OF WORKS

31. The Environmental Due Diligence Report (EDDR) includes:

A description of the project including details of solar technology adopted for the project

Environmental profile of the project area (the site and its immediate surroundings) based on secondary

information and detailed site visits. Detailed description of features of the site, physical features in terms

current land use of the site (open/agricultural / forest etc.) and its surroundings, presence of any temporary

/ permanent structures, any features such as water bodies, streams / nalas, etc and other sensitive features

at / around the site (religious structures/schools/ hospitals / settlements etc.)

Legal framework for solar projects (including the laws relevant to the site features), also supported by

copies of various clearances as obtained from Project Developer like forest clearance if applicable and

NOC from various authorities. Other state level regulatory authorities for establishing the facility and

construction equipment running DG Sets and storage of fuel any tree cutting permission. Permission for

ground water use. Hazardous substances management/Hazardous waste authorisation etc.

Analysis of environmental impacts (if any) both during construction and operation phase of the project and

formulation of remedial measures with relevant implementation arrangements addressing: (a) sensitive

environmental features (forests/national parks/sanctuaries/wildlife. CRZ and cultural heritage sites) and

impact of project on such areas; and (b) aspects like impact on community properties like grazing lands

water bodies and community severance. etc

Criteria for site selection or any alternative analysis study done for project site

Details of the public consultations during planning and construction stage (if not. then carry out focus

group discussions during the project to assess community issues related to the project)

Environmental Management Plan for construction and operation phase and the management measures

need to be built in to the project implementation measures/management.

Details of Institutional arrangement for environmental safeguards implementation and define components

for periodic monitoring of health, safety and Environmental aspects (parameters and frequency for

environmental monitoring);

Environmental management plan related clauses as per project contract documents which can be obtained

from project developer for the concerned project.

5. ENVIRONMENTAL BASELINE OF THE PROJECT SITE

32. This section briefly describes the baseline environmental profile of the study area of the Solar PV

Power plant. The proposed site lies in Phalodi Tehsil of Jodhpur District in Rajasthan, covering a land area

of 1080 bigha (land belonging to villages Kanasar & Rawra). The environmental baseline of the site has

been compiled from the ESIA report prepared by Senes Consultants and supplemented with findings

from the field surveys and consultations carried out as part of the preparation of the due diligence

report.

5.1 TERRAIN

33. The proposed project area is characterized by flat terrain with an average elevation of around 225 m

above the Mean Sea Level. Regional slope is from northwest towards eastern direction.


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5.2 LAND USE

34. The proposed project site lies on flat land with seasonal grazing as the main land use. During

monsoon, few pockets of surrounding land are cultivated and rest of the year, left as fallow land. A small

pond is located at about 1 km towards north of the proposed site. Study of land use and land cover in a 10

km area around the project site shows that major portion (approx. 54%) of the area is agricultural land.

Approximately 45 % of the land is in the category of open scrub land. Settlements and roads account for 1

% (approx.) of the area. Seasonal water bodies constitute only around 0.04 % of the land use. The site is

located on almost flat barren land with no distinct vegetation around. Seasonal grazing is carried out during

monsoon season. There is no vegetation or any inhabitants on the land acquired.

5.3 SURFACE WATER

35. Drainage pattern around the site is characterized by a network of ephemerally rain fed natural

drainage channels ultimately discharging into a pond in southern direction of the project site. The pond

serves as the major domestic water source for the inhabitants of nearby village. It was observed, during site

visit, that locals have made small sand bunds in their fields to stop rainwater running through their fields

for post monsoon usage. Indira Gandhi Canal passes at radial distance of 12 kms (approximately) from the

project site towards the north-east of the site.

36. Surface water sampling was carried out by the EIA consultants at two locations in the study area.

Surface water sample taken from the existing ponds in Kanasar and Rawra village near the project site was

analysed by EIA consultants. The pond water is used for drinking and washing purposes by domestic (cow,

sheep, goats) as well as wild animals.

5.3.1 Interpretation of Surface Water Quality Results

37. Analysis of collected samples of surface water showed that pH of the surface water sample in

Kanasar and Rawra villages are 9.58 and 9.12 respectively, indicating the water is alkaline in nature in

both the locations. The DO level in both the water samples is 6.2 mg/L at Kanasar and 6.0 mg/L at Rawra

village, while BOD is absent in both water samples, indicating good water quality. The coliform count

recorded is 94 MPN/100ml in Kanasar and 84 MPN/100ml in Rawra village.

5.4 GROUNDWATER

38. The groundwater in the area mainly occurs in unconfined state and the water levels are normally in

the range of 4 to 13 m below ground level (bgl) in hot weather while they are in the range of 2 to 13 mbgl

in Rabi season. As per CGWB, 1.59 m has been recorded as maximum rise in groundwater level for Bap

block. According to the District Groundwater Brochure (2008), the groundwater in the Bap block has high

concentration of Nitrate (more than 100 mg/l), Fluoride (1.5 -3.0 mg/l) and electric conductivity (4000-

6000 micromhos/cm).

39. Groundwater sampling was carried out at two locations within the study area. The concentration of

turbidity, PH, total hardness, chloride, calcium, magnesium, sulphate for the sample was observed to be

higher than the desired limit but was well within the permissible limits of IS: 10500. However, TDS is

little higher than the desirable as well as permissible limit.

5.5 CLIMATE & METEOROLOGY

40. Jodhpur district forms part of the Great Thar Desert of Rajasthan. Hence, the district experiences arid

to semi-arid type of climate which is hot and dry. The rainy days are limited to maximum 15 days in a

year. Almost 80% of the total annual rainfall is received during the southwest monsoon, which enters the

district in the first week of July and withdraws in the mid of September.

41. Phalodi is the nearest available monitoring station of IMD in Jodhpur district and located at 35 kms

(approx.) southeast of the project site. Some of the meteorological parameters are discussed below.


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42. Rainfall: The annual average rainfall recorded in Phalodi is 265.7 mm with the maximum rainfall

during the months of July and August and minimum rainfall in December. This is significantly low as

compared to the national average of 1200 mm.

43. Temperature: The meteorological data of Phalodi station shows that, the maximum temperature

occur in the month of May (45.20C), where as the lowest temperature was observed in the month of

January (3.10C).

44. Wind Direction: According to IMD data of Phalodi monitoring station, predominant wind direction

over the 30 year period (1951-1980) was recorded South West.

5.6 AIR AND NOISE QUALITY

45. Air Quality: Ambient concentrations of major air pollutants viz. particulate matters (PM10 and

PM2.5), sulphur dioxide (SO2), nitrogen oxides (NOx) and carbon monoxide (CO) were monitored twice a

week at three locations in the project area by the EIA consultants.

46. Monitored concentrations of each parameter at all the three locations have been compared with the

National Ambient Air Quality Standards (NAAQS) stipulated by the Ministry of Environment and Forests.

Concentrations of all the ambient air quality parameters (PM10, PM2.5, SO2 and NOx ) at all monitoring

stations were observed to be well below the NAAQS.

47. Ambient Noise Quality: The project site is located amongst barren fields with no continuous noise

generating sources in the vicinity of the project site. The ambient noise levels in the area were monitored at

three locations in nearby settlement (known as Dhani) of Ravara and Kanasar village. Monitored results for

day & night were within the applicable CPCB standards for ambient noise.

5.7 SOIL

48. Soil investigation carried out by EIA consultants at project site reveals that soil type is sandy silt.

Soil sample was collected from project site and analyzed during the ESIA study for the project.

5.7.1 Interpretation of soil testing results

49. Based on the particle size distribution obtained from the soil analysis, the texture of soil at the

project site is sandy silt type. Soil of the project site is slightly alkaline with a pH value of 9.10. Soil

sample contains high concentration of sodium and chloride ions, and soil is saline in nature. Soil sample

also contain high concentration of other minerals like Ca, Mg and show high value of TDS, which reflect

low nutrient holding and cation exchange capacity and poor fertility of soil. Concentration of organic

carbon and nutrient element like nitrogen is also low.

5.8 SEISMIC HAZARD

50. As per the Zoning map published by the Disaster Management and Relief Department, Government

of Rajasthan, the project site is located in the earthquake low damage risk Zone II (MSK VI) with low

seismicity hazard.

5.9 GEOLOGY

51. The geological set-up of Jodhpur district is represented by various igneous, metamorphic and

sedimentary rocks. Delhi Super Group litho units are very limited and in the form of isolated pockets.

Erinpura granites and Malani igneous rocks cover large area in the southern part of the district. Marwar

Super Group of rocks occupies maximum geographical area of the district lying in the central, western, and

eastern parts of the district. The rock units of various formations belonging to Cenozoic epoch represented

in very small area lies in the North-Western parts of the district. In the entire district, the hard rocks are

overlain by thin blanket of alluvium and windblown sand.


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52. Jodhpur district forms part of Great Thar Desert of Rajasthan. In this arid region, there are sand

dunes, alluvial areas dotted with few hillocks and hill chains scattered in the area.

5.10 HYDROGEOLOGY

53. The ground water in Jodhpur district occurs under unconfined and semi-confined conditions in rocks

of Delhi Super Group, Jodhpur sandstones, Bilara limestone, Nagpur sandstones, Lathi sandstones and

unconsolidated sediments (valley fills and alluvium). These form the chief source of groundwater in the

district. Confined conditions exist at deeper levels in north-western part of the district.

5.11 ECOLOGY

54. Ecological profile in the study area is based on the site survey, literature review and the ESIA report.

The study area characterized by arid climate and sandy soil does not support abundant growth of

vegetation. While some area comprises of scrub land with thorny bushes, majority of the area is barren

land. Natural vegetation therefore represents xerophytic community. With the first shower in late July, a

few grass species grow and shrubs and dwarf trees become green. But soon after the retreat of monsoon in

mid September, the vegetation dries up, leaving only few perennial shrubs and thin pads of pale green

grass on the landscape. There are no endangered species in the project area. In any case, being a solar

plant, project activities do not have any significant adverse effect on any living flora or fauna.

5.11.1 Floral Diversity

55. Babool, Aak, Kair, Khejdi, Senia and Neem were recorded as major vegetation in the areas the

project site during site visit. Sewan grass, a perennial drought tolerant species, was also identified as

commonly found species in the area. Aak and dry Sewan grasses were observed as major vegetation on the

proposed project site.

5.11.2 Faunal Diversity

56. The wild animals living in these harsh and dry climatic conditions belong to the Thar desert region.

The area is suitable for the burrow and low water consuming animals. Domestic animals like camel, cow,

dog, sheep and goat are seen in nearby Dhani during the site visit. Animals such as Indian Fox (Vulpes

bengalensis), Desert Fox (Vulpes vulpes pussila), Jackal (Canis aureus), Hyena (Crocuta crocuta), Wolf

(Canis lepus pallips), Nilgai (Boselaphus tragocamelus) are present in the study area (10km radius around

the project site) as per the records of forest department but has not been sighted.

57. Avifauna: Occurrence of low number of avian species in the study area is due to hostile climatic

factors, sparse vegetal cover, very little tree cover with small canopy and less availability of water bodies.

58. Reptile Diversity: Goh, Sanda, Sand mouse and Girgit are the reptilian species recorded and

confirmed by local villagers in the study area. In addition to this, lizard and snakes are the commonly

observed reptiles. In The Thar Desert region, lizard species which are abundant and without any threat are

Stenodactylus orientalis, Crytodactylus scaber,Crytodactylus watsoni, Hemidactylus brooki, Hemidactylus

leschenaultia etc. Among snakes, saw scaled viper, large rat snake, Viper, Indian Krait, Cobra and sand

boa are common.

5.11.3 Ecologically Sensitive Area

59. There is no existing legally denoted ecologically sensitive area like national parks and wildlife

sanctuaries within the 10 km radius of project site.

5.12 SOCIO ECONOMIC PROFILE

60. Considering the scale and nature of the solar power plant, a study area of 5 km from the project site

had been identified for profiling of socio-economic environment of villages.


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61. Identification of the study area had primarily been based on reconnaissance surveys, understanding

of the project and professional judgment during the EIA study. Villages selected for socio-economic

profiling include Kanasar at 5.23 km and Rawra village at 5.0 km.

5.13 DEMOGRAPHIC PROFILE

62. The demographic profile includes total population, household size, sex-ratio and scheduled

population of the selected villages in the study area of the district with respect to the proposed solar plant

of the study area villages, Kanasar has the highest population (2,806). The highest sex ratio within the

study area is found in Rawra village (941). The highest SC population is recorded in Kanasar village (759).

Scheduled Tribes are not found in the villages.

5.13.1 Education and Literacy

63. The highest literacy rate is observed in Kanasar village (35%) while average male and female

literacy rate in Kanasar is recorded at 80% and 20 % respectively.

5.13.2 Economic Activity and Livelihood Pattern

64. The workforce participation rate in the target villages of Jodhpur varies between 1.0 % to 88%.

Majority of inhabitants (about 88%) in the study area are employed in the category of cultivators. Other

workers’ category comprises the second most important work category in the study area constituting about

10% of the total workforce. Employments in agricultural (1.0 %) as well as workers working in household

industries (1.0 %) are low in number.

6. ENVIRONMENTAL SAFEGUARD DUE DILIGENCE

65. This chapter presents the findings of the due diligence on the following issues (i) policy, legal and

regulatory requirements, (ii) analysis of alternatives considered in selection of the project site, (iii)

assessment of environmental impacts and mitigation measures (iv) consultations carried out and (v)

provisions in the environmental management plan. Apart from a review of the corresponding issues as

outlined in the ESIA document, consultations with WSAPPL and site visits were carried out to assess the

compliance of the measures outlined in the EMP.

6.1 POLICY, LEGAL AND REGULATORY REQUIREMENTS

66. This section briefly describes the policy, legal and regulatory requirements for implementing the

solar photovoltaic power project. A solar power project requires assessment for applicability of the

following:

(i) The Air (Prevention and Control of Pollution) Act 1981

(ii) The Water (Prevention and Control of Pollution) Act 1974

(iii) Water (Prevention and Control of Pollution) Cess Rules, 1978

(iv) The Environmental (Protection) Act 1986 and Rules

(v) Environmental Impact Assessment (EIA) Notification 2006, MoEF Office Memorandum dated 13th May

2011 and 30th June 2011

(vi) Environment (Protection) Seventh Amendment Rules 2009 on AAQ standards

(vii) Noise (Regulation and Control) Rules 2000 amended in 2010

(viii) Forest Conservation Act, 1980

(ix) Conservation of Natural resources related laws

(x) Hazardous Waste (Management, Handling and Trans-boundary Movement) Rules 2008

(xi) The Building and Other Construction Workers’(Regulation of Employment and Conditions of Service) Act

1996

(xii) Central Electricity Authority (Safety Requirements for Operation, Construction and Maintenance of Electric

Plants and Electrical Lines) Regulations 2008

(xiii) Workmen’s Compensation Act, 1923 and Rules 1924


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(xiv) Employers’ Liability Act No. 24 of 1938

(xv) The Contract Labor (Regulation and Abolition) Rules, 1971

(xvi) Environment safeguard requirement of IIFCL as per their Environmental and Social Safeguard Framework

(ESSF) and environmental safeguard requirements of its development partners; and

(xvii) Other legislation applicable to construction activities.

6.1.1 Legal Setting

6.1.1.1 Environment (Protection) Act, 1986:

67. The Environment (Protection) Act, 1986 (EPA-1986) provides holistic framework for the protection

and improvement of the environment. Under the EPA-1986 certain development projects have been

identified requiring environmental clearance (as defined under EIA notification dated 14th September 2006

including all its amendments). Since the solar power projects are non polluting in nature and do not involve

disposal of solid waste, effluents and hazardous substances on land, air and water, such projects are

exempted from environmental clearance as per the EIA notification.

68. This Act is an umbrella legislation providing the coordination of Central and State Pollution Control

Boards established under the Water (Prevention and Control of Pollution) Act 1974 and Air (Prevention

and Control of Pollution) Act 1981. Under the powers conferred by this Act, the central government has

formulated a set of Rules known as the Environment (Protection) Rules and published Notifications

directed at the following aspects:

Restricting and prohibiting new, expansion and modernization project activities on their potential

environmental impacts;

Regulating the location of industries and the carrying on of processes and operations in different areas.

Setting standards for air emissions, waste water discharges, and hazardous waste management;

Setting standards for the ambient air quality and ambient noise levels, and

Protection of public health and welfare.

69. The other applicable rules & regulations under EPA 1986 includes

The Hazardous Wastes (Management and Handling) Rules, 2003;

The Ozone Depleting Substances (Regulation and Control) Rules, 2000;

The Batteries (Management and Handling) Rules, 2001 as amended;

6.1.1.2 The Air (Prevention and Control of Pollution) Act 1981

70. The Air Act prohibits any person to establish or operate any industrial plant in an air pollution

control area, without previous consent of the State Pollution Control Board. Under the above Act,

industries are mandatorily required to apply for Consent to Establish and Consent to Operate from the State

Pollution Control Board. State Boards are responsible for granting and renewing the consents and are

empowered to revoke such permits and order closure of a project in case of noncompliance with the

provisions of these Acts and/or the general or specific consent conditions. Any Establishing or Operating

Industrial Plant is required to ensure under the Act, that the emissions from the activities within the plant

site comply with the Specific Emissions Standard as laid down by Central Pollution Control Board as part

of the Act.

Applicability

71. As per the Industry Classification published by the Rajasthan Pollution Control Board, solar power

projects are classified as Other Category industries requiring Consent to Establish & Consent to Operate

from the Pollution Control Board. CTE & CTO under Air Act has not been applied for by WSAPPL.


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6.1.1.3 The Water (Prevention and Control of Pollution) Act 1974

72. The Water Act prohibits any person from knowingly causing or permitting any poisonous, noxious

or polluting matter, determined in accordance with standards laid down by the State Board, from entering

directly or indirectly into any stream or well or sewer or on land; It also prohibits any person from

knowingly causing or permitting to enter into any stream any other matter which may tend, either directly

or in combination with similar matters, to impede the proper flow of the water of the stream in a manner

leading or likely to lead to a substantial aggravation of pollution due to other causes or of its consequences.

Under the above Act, industries are mandatorily required to apply for Consent to Establish and Consent to

Operate from the State Pollution Control Board (also called No Objection Certificates). The State Boards

are responsible for granting and renewing the consents and are empowered to revoke such permits and

order closure of a project in case of non-compliance with the provisions of these Acts and/or the general or

specific consent conditions. As per the Industry Classification published by the Rajasthan Pollution

Control Board, solar power projects are classified as Other Category industries requiring Consent to

Establish from the Pollution Control Board.

Applicability

73. CTE has been obtained from RSPCB via F(Tech)/Jodhpur(Phalodi)/109(1)/2012-2013/999-1001

dated 24-08-12.

74. The CTO under Water (Prevention & Control of Pollution) Act, dated 04.01.2013, has been obtained

from Regional Office, Jodhpur of RSPCB (Copy enclosed as Appendix 1 & 2)

6.1.1.4 Noise (Regulation and Control) Rules 2000 amended in 2010

75. The Rules stipulate ambient noise limits during day time and night time for industrial, commercial,

residential and ecologically sensitive areas. Under this Rule, Areas/ Zones have been categorized into

industrial, commercial, residential or silence areas/zones for the purpose of implementation of noise

standards. The ambient air quality standards for noise specified in the Schedule need to be complied with.

An area comprising not less than 100 meters around hospitals, educational institutions and courts is

declared as silence area/zone for the purpose of these rules.

Applicability

76. For construction activity as well as plant operations, ambient noise quality will have to be monitored

and maintained on a regular basis a part of the implementation of the Environmental Management Plan.

The conditions stipulated by the Rajasthan Pollution Control Board in the CTE & CTO will have to be

adhered to- Industrial standards of Leq 75 dB (A) during day & Leq 70 dB (A) during the night.

6.1.2 Policy Setting

77. The Environmental and Social Safeguard Framework (ESSF) of IIFCL provides the enabling

mechanism to IIFCL to deliver its policy objectives and applies to projects funded by IIFCL throughout the

Project Cycle (PC). The ESSF defines procedures, roles, and responsibilities, at various project milestones

for managing the adverse environmental impacts. Projects financed by IIFCL need to undergo an

environmental and social due diligence process utilizing the procedures described in the ESSF to ensure

sustainable project investment.

6.1.3 Other Legislations Applicable to Construction Activities:

78. Contract Labour (Regulation and Abolition) Act, 1971 - the Act provides for certain welfare

measures to be provided by the contractor to contract labour.

79. Minimum Wages Act, 1948 - the employer is supposed to pay not less than the Minimum wages

fixed by appropriate Government as per provisions of the act;


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80. Child Labour (Prohibition and Regulation) Act, 1986 the Act prohibits employment of children

below 14 years of age in certain occupations and processes and provides for regulation of employment of

children in all other occupation and processes. Employment of child labour is prohibited in Building and

Construction industries).

81. The building and Other Construction Workers (Regulation of Employment and conditions of

Service) Act 1996 and the Cess Act of 1996 - all the establishments which carry on any building or other

construction work employs 10 or more workers are covered under this Act; the employer of the

establishment is required to provide safety measures at the building or construction work and other welfare

measures, such as canteens, first-aid facilities, ambulance, housing accommodation for workers near the

workplace etc.

82. Central Electricity Authority (Safety Requirements for Operation, Construction and

Maintenance of Electric Plants and Electrical Lines) Regulations 2008: This regulation lays down

broad safety requirements for construction, operation and maintenance of electrical plants and electric

lines, which includes development and implementation of a safety management system.

83. Workmen’s Compensation Act, 1923 and Rules 1924: The Act gives requirements related to

employer's liability of compensation to any personal injury caused to a workman by accident in the course

of his employment. The Act also gives a framework for calculating amount of compensation and wages.

Notice of accidents resulting in death or serious bodily injury is required to be given to the government.

The Rules give provisions for application and review of compensation after death or serious injury of a

workman at site or on duty. The reporting of accidents needs to be done in prescribed forms. The Rules

give the procedures for the handling of claims.

84. Employers’ Liability Act No. 24 of 1938: The employer needs to maintain all the works, machinery

or plant connected with or used in his trade or business, in good and safe condition to avoid personal injury

to any workman, who may sue for damages in respect of the injury. A contract of service or apprenticeship

cannot limit any liability of the employer in respect of personal injuries caused by negligence.

6.1.4 Compliance to Clearance Requirements

85. Solar Power Projects do not require EIA/Environmental Clearance as per the EIA notification

2006 by the Ministry of Environment & Forests (MOEF), Government of India. The statutory clearances

required as part of the proposed project was assessed and the current status of availability of such

clearances is given in Table 2. The project site does not include any forest area, thus no forest clearance is

involved in the project.

Table 2: Statutory clearance required and present status of clearance

Clearances Status

Consent to Establish & Consent to Operate Obtained under Water Act (Enclosed as Appendix 1 & 2)

Environmental Clearance Not Applicable (MOEF office memorandum 13th May 2011&

30th June 2011 (Enclosed as Appendix 3 a & b)

Forest Clearance Not Required

Provisions under Biological Diversity Act 2002 Not Required as project site does not lie within 10km of any

National Park, Wild Life Sanctuary

Permission for Tree cutting Application submitted to concerned Tehsildar (Enclosed as

Appendix 4)

Permission for Ground water use Ground water will not be required

Hazardous Waste (Management, Handling & Trans boundary

Movement) Rules, 2008

Not Applicable as no Hazardous Waste generation is expected

during operation of the Solar PV Power plant.

6.2 ANALYSIS OF ALTERNATIVES – SITE SELECTION

86. The project site has been chosen based on evaluation criteria which included (i) solar radiation, (ii)

land use, (iii) available infrastructure, (iv) distance to nearest substation, (v) connectivity to site, (vi)

availability of water, (vii) approvals and clearances, (viii) proximity to development and (ix) site shading.

Preliminary data collection, evaluation and detailed technical investigation of identified sites have been


16




carried out. Afterwards detailed analysis of top three sites – Pokhran, Jaisalmer and Phalodi have been

done to finally choose the present project site at Phalodi in Jodhpur district. The first two sites had issues

with respect to access, transmission line proximity with respect to evacuation, partly forest land, presence

of sandy soil and also lower levels of solar radiation. Government land has been allotted for setting up of

the project and the land is barren in nature.

87. The site satisfies the basic principles of site selection in that:

No historical and culturally important place lies adjacent to the project site;

The proposed project does not affect any public utility services like playground, schools and other

establishments;

There are no ecologically sensitive areas like Wild life Sanctuary, National Parks etc. adjacent to the

project site;

No protected /reserve forest area present within or adjacent to the project site.

No habitation/settlements within the project site, thus there are no rehabilitation issues

No water bodies affected as a result of the project, no ground water sources affected by the project

Proposed location will not create any severance issues at the site.

6.3 ASSESSMENT OF ENVIRONMENTAL IMPACTS & MITIGATION MEASURES

88. WSAPPL has carried out an environmental and social impact assessment of the proposed project.

The present section presents the observations of the due diligence consultant regarding the mitigation

measures taken against the potential environmental impacts.

6.3.1 During Construction Activities

6.3.1.1 Land Use

89. 350 acres of land has been allotted to WSAPPL for the proposed project by the government of

Rajasthan. This is entirely Government owned land and remains fallow throughout the year except during

monsoon period when it is used for grazing. Thus the proposed project does not involve loss of livelihood.

ESIA study observes that there is another patch of land in the vicinity which is used for grazing, which can

be used by the villagers. Thus impact on land use is not significant in nature.

90. Transmission lines and 54 towers have been erected from the power plant to the substation, which is

located 14.5 km away. Land required for Transmission Line has been obtained on ‘Right to Use’ contract

and permanent land acquisition is not involved. For this purpose, the land required to erect towers has been

‘used’ as per the State Government regulations. There were 41 compensation agreements in place against

private land and those encroached into government land. Compensation was given to people, having

possession/using the piece of land, considered beneficiary and were suitably compensated during

transmission line erection for the larger interest of villagers and society as well as timely completion of the

project. WSAPPL had deputed Karnimata Construction Company for the Erection, Testing and

Commissioning of transmission line. Karnimata Construction Company will arrange Right of Way (RoW)

and also compensate for the crop damages, for the installation of transmission line, as per Clause 4 of the

Technical Specification and Scope of Work of the work order provided by WSAPPL. The crop damage

compensation due to erection of towers was paid by the contractors through a person agreement. The

agreement includes details of the owner, total ownership of land, type of crop impacted and amount of

compensation payable. The relevant Clauses with respect to obtaining the RoW are presented in Box 1.


17




Box 1: Extract from the Work Order for transmission lines

6.3.1.2 Drainage

91. There is no natural drainage in the project site. However, to avoid alteration of the contour level

which may cause local flooding in the area during the monsoons, storm water drainage has been

constructed in the project site. Discussion with the WSAPPL team reveals that there are definite plans in

place for rain water harvesting in the project site, as recommended by the RPCB in the CTE & CTO. The

environment and social management and monitoring plan provided as part of the ESIA carried out by

WSAPPL also suggests that “during operation phase, surface run-off from project site will be channelized

to recharge the ground water table through rain water harvesting system.

6.3.1.3 Ambient Air Quality

92. The increase in air pollution concentration caused by fugitive dust generated due to excavation work

and material handling, DG set operation for power supply during the construction phase is expected to be

short-lived and insignificant. However, cumulative air impact, though intermittent, is anticipated from area

development activities by other solar power plants operating in the area.

93. Contractors had obtained valid pollution under control (PUC) certificates for all construction

equipment / vehicles and complied with the latest applicable emission norms. WSAPPL have ensured that

the relevant certificates are obtained by the contractors.

94. Spraying of water during construction is being carried out by the Contractors to reduce dust emission

to a great extent.

6.3.1.4 Ambient Noise Levels

95. During construction phase, the sources of noise pollution are primarily limited to movement of

vehicles transporting construction material and equipments to the site. The project sites are however away

from settlement areas of villages; hence the villagers are not affected due to increased noise level. Use of

low noise generating equipments and restriction of construction activity for limited periods (as per the

stipulation & noise standards mentioned in the CTE & CTO obtained from RPCB) further reduced the

disturbance from noise pollution.

6.3.1.5 Water

96. Water use during construction & operation phase is less in a solar power plant. During discussion

with WSPPL officials, it was revealed that water is being provided by EPC contractor through water tanker

for both construction and operation phases. During operation phase, water will be required only for

cleaning the modules which is only once a month.

97. Due Diligence Consultant has observed that only a tube-well is established in the project site for

construction purposes. However, the discussions revealed that since the alkaline content is higher, the

water is not suitable for construction & operation activities. It is also informed that the tube-well was

established following CGWA guidelines (Guidelines enclosed as Appendix 5).

98. WSAPPL also ensured that drinking water for labour and staff during construction and operation

phase is meeting IS: 10500 quality standards.


18




6.3.1.6 Water Quality

99. As per the Consent To Establish under the Water (Prevention and Control of Pollution) Act 1974-

WSAPPL shall discharge domestic effluent in soak pits through properly designed septic tank. (A

maximum of 1600 KLD domestic sewage generated during construction phase is disposed in Septic tank &

soak pit &38KLD water generated from vessel, equipment washing will be used in plantation,

horticulture).

100. WSAPPL shall comply with the general conditions of CTE under Water (Prevention & Control of

Pollution) Act 1974.

101. WSAPPL shall submit cess returns in case the water consumption is more than 10 KLD under the

provision of water (Prevention & Control of Pollution) Act – 1977 and as amended from time to time.

102. WSAPPL has also designed rain water harvesting pond inside the plant boundary integrated with

drainage plan which would collect plant drain/storm water drain during monsoon. The pond is being

designed wherein the rain water shall be collected & treated suitably to make usable as for domestic use

purpose. As a part of the scheme, 6 nos of storage tank with capacity of 875 (6x875 = 5250 m3) cubic

meter is being constructed at drain exits for utilization of rain water for washing of solar modules.

Overflowed water from storage tanks will be passed to the 8 nos recharge pond/well, which will recharge

1075.76 m3/day & will ultimately enhance self sufficiency in water resource as well as positive impact in

the vicinity. Optimum utilization of water through systematic water supplying network has been tendered

to reputed company M/s Jain irrigation. An illustration of rain-water harvesting structures is given in the

figure.

6.3.1.7 Soil

103. The probable impacts and mitigation measures taken at the project site are related to:

i. Felling of trees at project site which may enhance soil erosion due to loss of soil binding source.

WSAPPL had initially sought permission from concerned Tehsildar, Bap, district Jodhpur, for removal

of Khejri trees since it obstructs the installation of solar panels but later decided to retain the trees within

the layout for solar panels due to ecological & religious significance (after discussion with Revenue

Department).

ii. In labour camps, there might be degradation of soil quality due to improper sanitation facilities.

WSAPPL has provided adequate sanitation facilities in the labour camp located within the construction

site.

104. Sufficient landscaping is being carried out within the plant premises to compensate for the tree loss

and binding the soil.

Template 1: Illustration of Rainwater harvesting

structures

Template 2: Retaining Khejri trees within the layout

of solar modules


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6.3.1.8 Ecology & Biodiversity:

105. There are no legally notified ecologically sensitive areas viz. National park, wildlife sanctuary etc.

within the 10 km radius of the project site, therefore impacts on biodiversity are not expected due to the

proposed project.

106. During the transmission line route selection for the proposed project (by Karnimata construction

Company), necessary consideration has been made to avoid forestland & ecologically sensitive areas.

107. Flora: 20 Khejri trees are falling within the layout of solar panels. Initially the plan was to cut them

to enhance power generation and permission for the same had been sought from the Tehsildar, Bap, district

Jodhpur (Appendix 4). But after discussion with the Revenue department it emerged that the species is

ecologically important in arid & semi arid areas and also has religious importance, so it was decided that

the trees would not be cut but would be accommodated within the layout of solar panels sacrificing the

power generation potential within the area of spread of each tree canopy. Landscaping has also been

proposed within the plant premises to serve aesthetic purpose and act as pollution sink.

108. Road side plantations are taken up for about 10-15 km of the road length. While the survival rate of

these plantations is a significant issue, the current corrective measures adopted by the developer could

improve the local/community vegetation.

109. Green Area Development: The ESIA recommends developing plantation in the project area in

order to strengthen the biodiversity in the region. Accordingly, WSAPPL has developed a site plan of the

proposed power plant and the proposed green area (in part) has been enclosed as Appendix 6. A plantation

plan has also been planned at Rawra village in land allotted by forest department/local administration in

consultation with DFO Jodhpur, ADM Phalodi, Sarpanch Rawra, Nursery-in-charge Bap, nursery-in-

charge Phalodi. About 3000 trees will be planted through this programme. The plan also includes

plantation along 5 km of village road. The plan is enclosed in Appendix 7.

110. The landscaping plan in the plant site comprises of low height plants, shrubs, trees (at certain

locations), ground cover and use of local materials for aesthetic beauty. The landscaping is being

developed at the site presently. Species recommended are indigenous to the project area.

Low height plants have been proposed as tall

trees will block sunlight. The low height

plants recommended include: Plumeria alba,

Palm (Royal Palm), Hibiscus (white, pink,

red), Kaner.

The shrubs recommended are: Sadabahar,

Motiya, Madhumalti, Giloy, Amarbel.

Ground cover will be provided by grassing

(mainly Siwan grass-found in the project

area, Burberry crimson & Pygmy. Aloe vera

plants have also been recommended because

of their medicinal value.

Tree species include Ficus panda (yellow

colored bushy plant), Ficus benjamina

(tolerance of poor growing conditions).

The small height trees, plants are to be planted in the north east part while the large trees in the south west

portion of the power plant.

Besides plants, playing with local materials like stones, slabs & mud pots have also been included in the

plan to improve aesthetics.

Template 3: Aloe Vera planted in a nearby Plant

owned by Welspun


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Template 4: Plantation carried out along the roadside Template 5: Landscaping done in another nearby

plant site owned by Welspun

111. Perimeter Landscaping is currently being developed at the site with two rows of plantation all along

the boundary for about 8 km. These measures will not only reduce the dust at the site but would also add to

regenerating vegetative cover in the desert condition. In addition, the ongoing Aloe vera plantations

below/foot of the panels would improve the site vegetation.

112. Fauna: The project site has boundary wall & fence to avoid entry of wild animals such as Deer,

Nilgai, etc within the plant premises, also to avoid the risk of electrocution of animals and also the risk of

these animals damaging solar panels. Further, night time movement of vehicles during construction phase

will be restricted to avoid any direct interaction with wild animals (deer, nilgai), which are common in this

region.

6.3.1.9 Health and Safety

113. WSAPPL has developed a comprehensive Environmental, Health, Safety & Sustainability Policy

(EHS&S) – The Policy is enclosed as Appendix 8.

114. Safety at work has been ensured by the Contractor as per the Occupational, Health & Safety

Conditions of Contract (Refer to Appendix 9 between WSAPPL & Piling Work Contractor) during (a)

manual excavation during construction (cut hazard), (b) manual loading and unloading of materials such as

modules, inverters, (c) work at height during construction and repair and maintenance work (fall hazard),

and (d) working on electrical equipments during repair and maintenance work (electrocution hazard).

115. The health and safety of workers is ensured as required by Building and other Construction Workers

(Regulation of Employment and Conditions of Service) Act 1996; Contract Labour Act, 1970 and the

Central Electricity Authority (Safety Requirements for Operation, Construction and Maintenance of

Electric Plants and Electrical Lines) Regulations 2008. Aligned to specific provision of the aforesaid Act

and Rules, adequate measures are being taken by WSAPPL to ensure proactive efforts being made by the

civil contractors towards provision of welfare facilities for contract workers viz. canteens, restrooms,

sufficient supply of drinking water, creches, latrines and urinals, washing facilities etc.


21




116. WSAPPL enhances awareness of the contractor

workforce on occupational health and safety risks through

implementation of training programme in accordance with

EHS&S.

117. During the office visit to Welspun & on discussion

with the environment team, it has been recorded that the

EHS&S document of WSAPPL is confidential and the

EHS&S monitoring at the plant site is carried out

regularly & documented. There are meetings every month

in WSAPPL -Senior Management meetings & Internal

Engineering meeting where environmental compliances &

work progress of contractor & WSAPPL are discussed.

6.3.1.10 Socio economic Condition

118. The project has provided employment opportunity the local people during construction phase, when

manual, un-skilled labours are required for civil and mechanical work. About 40% of the total workforce

comprises of locals.

6.3.1.11 Resettlement

119. The proposed project lies on Government land only. As there is no private land involved for the

project, social impact due to land acquisition on land owners and involuntary settlement is not envisaged.

6.3.1.12 Cultural Sites

120. No significant area or building of cultural heritage is present near the project site; hence no impact is

envisaged.

6.3.2 During Operational Activities

6.3.2.1 Land Use

121. Contamination of land during the operation phase is not envisaged. Waste generation during the

operation phase is minimum in a solar power plant. The solar panels will be taken back by the supplier

after a period of 25 yrs, when they become defunct.

6.3.2.2 Air and Noise Quality

122. The operation of a solar power plant does not involve emission of gases and generation of dust

particles, hence the impact on ambient air quality is anticipated to be very less. Similarly impact on noise

quality is envisaged to be very low.

6.3.2.3 Water

123. There is scarce resource consumption during the operation phase. Water is required for cleaning the

solar modules once a month. Suitability of ground water is being tested for the purpose. If water is found

suitable, necessary permission will be taken from the Central Ground Water Board. If not found suitable,

water will be supplied by tankers.

6.3.2.4 Flora

124. No impact on flora envisaged. Rather, the plantation program will enhance the vegetative covering in

the project area.

Template 6: Workers safety ensured during

construction through use of helmets


22




6.3.2.5 Fauna

125. The project site is fenced to avoid entry of wild animals such as Deer, Nilgai, etc within the plant

premises so as to avoid the risk of electrocution of animals and also the risk of these animals damaging

solar panels. Reflection from solar panels may impact flight pattern of local birds.

6.3.2.6 Health and Safety

126. No significant Health & safety issues envisaged during the operation phase. Only the solar power

plant panels could generate reflection which could cause a nuisance to the nearby settlements. Most of the

health impacts are beneficial, due to a reduction in toxic emissions arising from the otherwise combustion

of fossil fuels.

6.3.2.7 Socio-Economic Condition:

127. Socio-economic condition of the villages in the project area is expected to improve due to an overall

increase in power supply in the grid and hence an increased power supply in the villages. Increase in power

supply to these rural areas will beneficially impact the socio-economic conditions thereby

directly/indirectly triggering the growth of agricultural up gradation, health and education facilities,

infrastructural development etc. Therefore, the overall impact on socio-economic condition will be

positive.

6.3.3 Decommissioning Phase

6.3.3.1 Proper Maintenance & Disposal of Solar PV Panels

128. Photovoltaic panels may contain hazardous materials, and although they are sealed under normal

operating conditions, there is the potential for environmental contamination if they were damaged or

improperly disposed upon decommissioning.

129. Measures: It has been learnt from WSAPPL that all the damaged/dormant photovoltaic modules &

its accessories will be sent back to the manufacture as per their recycling policy. The supplier will be

taking back the solar PV panels at the end of their life cycle to ensure their proper disposal.

6.4 PUBLIC CONSULTATION DURING PLANNING AND CONSTRUCTION STAGE

130. Consultations with the village community were carried out by WSAPPL during planning as well as

construction stages. The community suggested employing them in the non-skilled works at the project site.

Apart from providing direct employment to the villagers, WSAPPL has taken initiative in involving the

machinery and trucks and other transport vehicles, etc., owned by the villagers. This was revealed during

the discussion with the Project Team at site.

Table 3: Key outcomes of the Consultations during Planning and Construction stages

Key Issues Suggestions by the Community Integration into the Project work

Employment to villagers

in the project work Developer should employ villagers in

suitable non-skilled jobs.

Hiring of vehicles, water tankers, and

other construction equipments from

villagers.

About 40 percent of the total workforce at the site

has been mobilized from local villages.

Trucks and tractors for transporting of solar panels,

water tankers, earth-moving equipments, etc., have

been sub-contracted to village residents. The hiring

rates are though not competitive, WSAPPL has

taken such an initiative to ensure the participation

of the villagers in the overall functioning of the

project.

Upgradation of road

leading to the proposed

project site

Contract of road construction should be

given to resident villagers.

Villagers should be employed in the

road construction work.

The level grading of the earthen road leading to the

project site was carried out by WSAPPL for which

sub-contract was given to Contractor based in

Rawra village.

The contractor has employed villagers in the road

construction work.

Boundary wall of the A pond near the boundary wall requires Renovation works of the pond is in progress. The


23




Key Issues Suggestions by the Community Integration into the Project work

Project Site obstructs free

movement of villagers for

toilet purposes and

grazing of animals

to be deepened and should be kept as

source of drinking water for cattle.

Toilet facilities need to be provided for

the households reside adjacent to the

boundary wall of the project site.

small pond is located adjacent to the boundary wall

of the project site. The expenses will be met by

WSAPPL.

About 13 families will obtain toilet facility within

their homestead and at a location preferred by the

household. The expenses towards construction will

be met by WSAPPL.

131. Approximately 70 persons would be required to continue providing the following services during

Plant’s operational period for the next 25 years.

Table 4: Key Outcomes of the Consultations during Planning and Construction stages

No. of Personnel Purpose Rate/Month (in Rs.)

40-45 Cleaning of solar modules 6000 to 7000 (at Rs.350/day)

10-12 Security services for plant 10000

8-10 Housekeeping 6000 to 7000

3-4 Drivers 6000 to 7000

3-4 Cooks 6000 to 7000

5-6 Personnel for water supply 6000 to 7000

6.5 ENVIRONMENT MANAGEMENT ACTION PLAN

132. The EMAP has been prepared by collecting the information on several measures integrated in project

documents towards minimizing negative environmental impacts. The major components of the EMP

include:

Mitigation of potentially adverse impacts;

Monitoring during the project implementation and operation; and,

Institutional arrangements.

133. The environmental issues and action plan with institutional arrangements for implementation,

supervision and monitoring mechanism have been provided in Table 5. The construction phase is over and

the project has commissioned from 19th February 2013.

Table 5: Environmental Mitigation Action Plan

Environmental

Aspect Action Plan Responsibility

Realistic Time Frame [start

date, end date, if periodic,

mention the period (daily,

weekly, monthly, etc)

Monitoring Mechanism

Safeguard of

occupational

health of the

workers

onsite

Provision of adequate

hygiene facilities like

drinking water, toilet

O&M contractor under

the supervision of

WSAPPL’s staff

Drinking water & Toilet

facilities to be provided at

control room by 31/07/2013

Completion report of Drinking

water & Toilet facilities with

photograph , signed by project

executor and O&M Incharge will

be sent to Head- E,H&S.


24




Environmental







Health and safety

of

Workers

First Aid boxes provided at site; hazard signs placed

near energized

components; provision of

sufficient fire

extinguishers at site to

tackle fire hazards;

adequate use of Personal Protective Equipments

during work; ensuring

implementation of proper

occupational health and

safety

programmes/procedures

viz. Permit to Work, etc

and safety inductions and trainings to prevent safety

hazards at work prior to

commencement of any

operation and maintenance

activities.

Construction workers provided with requisite

shelter, drinking water and

sanitation in accordance

with requirements of the

Building and other Construction Workers

(Regulation of

Employment and

Conditions of Service)

Act, 1996, the Central

Electricity Authority

(Safety Requirements for

Operation, Construction and Maintenance of

Electric Plants and

Electrical Lines)

Regulations 2008 and the

guidelines published

jointly by International

Finance Corporation (IFC)

and the European Bank for Reconstruction and

Development (EBRD).


the supervision of

WSAPPL’s Personnel

Initiated all possible Safety &

Health measures mentioned in the

action plan at site. Monthly

reporting system to be initiated

from September 2013.

Construction work completed,

now plant is in O&M phase.

Adequate facility of drinking

water & toilet facility adjacent to

two inverter rooms.

Completion date : 30.9.2013

Completion report of Drinking

water & Toilet facilities with

photograph , signed by project executer and O&M Incharge will

be sent to Head- E,H&S.


25




Environmental







Proper handling

and

disposal of wastes

and

protection of local environment

Construction debris after completion of major

construction phase reused

in paving site approach

road or filling of low lying

areas.

Domestic waste water disposed off in septic

tanks.

Waste water from cleaning of Solar

Modules, during

operational phase used

for plantation &

horticulture as per

suitability.

Local waste recyclers identified for disposal of

recyclables viz. packaging

Materials, metal scrap generated primarily during

construction phase.

Solar PV technology is a green technology therefore

generation of hazardous

waste in the project site

not anticipated.

EPC contractor and


the supervision of


Completion date :31.12.2013

Completion date 30.9.2013

After washing of Solar

Modules waste water will be

used in plantation beneath the

solar panel.

Effective Date : December,

31 2013 throughout life

cycle

Packing materials of solar

modules and other associated

equipments have already

been disposed/sold to local

recycler

Not Applicable as there is no scrap generated from project.

Not Applicable

Completion report on suitable use of construction debris

signed by project executor

and O&M Incharge will be

sent to Head- E,H&S.

Completion report with no. of soak pits and septic tanks,

photographs , signed by

project executor and O&M

Incharge will be sent to Head- E,H&S.

Monthly Progress report of

Aloe vera plantation beneath the solar modules

with photographs will be sent

to Head- E,H&S.

Proper disposal of

Solar PV Panels Proper transportation of

PV panels, maintenance &

disposal of these panels

considered.

The damaged/dormant photovoltaic modules &

accessories will be sent

back to the

manufacturer/recycling

agency/supplier.


the supervision of


During decommissioning Stage

All damaged/ broken modules

to be kept in a Steel Closed container on a concrete

platform. Whenever the

container will be full of broken

modules, it will be sent to

appropriate

recycling/manufacturing

agency/ supplier etc.

Proposed Effective date :

31.12.2013 throughout life

cycle

Photographs after installation of Steel Closed container on a

concrete platform will be sent

to Head- E, H&S. Records of

damaged Cell to be kept with

O&M incharge and records to

be sent to Head-E,H&S at the time of final disposal


26




Environmental







Developing own

Water Resource

during operation of

the Solar project

Rain Water Harvesting, storage cum Recharge

scheme integrated with

drainage plan is being

implemented at the project

site. As a part of the

scheme, 6 nos of storage

tank with capacity of 875 (6x875 = 5250 m3) cubic

meter is being constructed

at drain exits for

utilization of rain water

for washing of solar

modules. Overflowed

water from storage tanks

will be passed to the 8 nos recharge pond/well, which

will recharge 1075.76

m3/day & will ultimately

enhance self sufficiency in

water resource as well as

positive impact in the

vicinity. Optimum

utilization of water through systematic water

supplying network has

been tendered to reputed

company M/s Jain

irrigation.


the supervision of


Completion date : 31.12.2013 Completion report of Rain

Water Harvesting, storage

cum Recharge scheme

integrated with drainage plan

with photograph , signed by


Incharge will be sent to

Head- E,H&S.

Implementation of

site drainage

system & water

harvesting structures

Suitable drainage system implemented & integrated

with rain water harvesting,

storage & recharging

scheme at project site.

EPC contractor and


the supervision of

WSAPPL’s personnel

Completion date : 31.12.2013 Completion report of Rain

Water Harvesting, storage

cum Recharge scheme

integrated with drainage plan



Incharge will send to Head- E,H&S

Prevention of soil

and

groundwater

contamination

Spillage of materials e.g.,

Transformer oil on soil

will be prevented, by

placing these materials in safe places with

impermeable liners during

storage, handling and use.

Adequate spill control arrangements viz. sand

bucket, etc is to be

provided onsite to address

accidental spills.


the supervision of

WSAPPL’s personnel

Storage facility will be

developed for Storage of

Transformer Oil.

Completion date : 30.11.2013

Completed

Completion report of

Storage facility for

Transformer Oil with

photographs, signed by project executor and O&M

Incharge will be sent to

Head- E,H&S.

Prevent any

disturbance to flora

and fauna near the

project site

Fauna: Temporary nature of construction phase

(approx. 6-9 month) not

likely to create significant

impact. However, impacts

managed through

implementation of

appropriate mitigation

measures viz. avoiding construction activity and

traffic movement at night

time and during early

hours of morning. Also,

proper fencing around the

site deter animals from

entering the site and getting hurt.

Flora: Plantation

programme proposed in

neighbouring Rawra village in discussion with

DFO & other authorities

in govt/forest land allotted

for the purpose. About

3000 trees to be planted.

WSAPPL personnel

during both construction

and operational phase

Proper boundary has been constructed around the site

Caution Boards displayed at

strategic area

Completion Period :

30.11.2013

Progress report for plantation of 3000 saplings in

nearby areas of the project

site & road side with

photographs, signed by Head

( CSR ) will send to Head-

E,H&S.


27




Environmental







Action to increase

survival rate of

road side plantation

Ensuring survival rate of plants that have been

planted by consulting with

Forest Department for

methods to increase

survival rate of plant

species.

WSAPPL personnel

During operation phase Planning to undertake repair

work on the fencing, regular

supply of water via water

tankers, spraying of

pesticides, gap filling where

ever required.

Effective date: 30.9.2013,

through out life cycle.

Progress report for repair work gap filling plantation


Head ( CSR ) will be sent to

Head- E,H&S

Develop positive

perception among local

communities about

project

Open dialogues maintained with the

community members and

all other local stakeholders

of the project to communicate details of the

project, its utility in a

national and sectoral

perspective, extent of

benefits and opportunities

the project can present to

the local communities and

plans/measures the project proponent is taking to

address the community

concerns about social and

environmental impacts.

Project specific Community

Development Plans

enclosed in Appendix 10.

WSAPPL Management

and EPC Contractor

The process is ongoing and

implemented as per CSR plan. Monitoring will be done as

per CSR plan, progress report

with photograph will be

signed by Head ( CSR ) and

will be sent to Head- E,H&S.

Legal compliance Consent to Establish (CTE) and Consent to

Operate (CTO) has been

obtained from Rajasthan

Pollution Control Board

(RPCB) under the Water

Act.

The conditions of the CTE and CTO to be complied

with and the compliance

will be reported to the

Pollution Control Board, periodically, as mentioned

in the aforesaid

permits/consents.

Permission from Central Ground Water Board to

tap ground water for plant

operations

WSAPPL personnel

during both construction

and operation phase

Consent to Establish (CTE) and

Consent to Operate (CTO) has

been obtained.

Quarterly compliance report of CTO is being submitted to

RPPCB (10/04/2013)

Depending on the outcome of scientific study by deputed

consultant, CGWB permission

shall be taken if required

Quarterly compliance report of

CTO is being submitted to

Rajasthan Pollution Control

Board, acknowledgement of the

same will be kept as ready reference & records.

Quarterly Compliance report as

submitted in April 2013 is

enclosed as Appendix 12.

Impact specific to Transmission line Construction & Operation

Air Pollution Taking precaution to reduce

dust & emission levels (if

any).

Contractor (appointed by

WSAPPL under the

supervision of WSAPPL

)

During construction &

Operation

Project commissioned on

19/02/2013

Noise pollution –

during Transmission line

operation- corona

noise

from the

conductors

The transmission line

alignment selected as defined in Electricity Act

2003

The Contractor

appointed by WSAPPL under the supervision of

WSAPPL

During

Planning Not Applicable as there is no

noise generation from the

transmission line & plant activity.

Noise pollution –

during Operation

of transformers- Transformer

noise

The transformer location

selected as defined in

Electricity Act 2003

Contractor appointed by

WSAPPL under the


Not applicable in our project area


28




Environmental







Occupational

Health & Safety-

Physical hazards

related to working

at height - Erection of towers, line

stringing

Safety practices adopted to

prevent physical hazards

Contractor appointed

by WSAPPL under the


.

During

Construction.


19/02/2013

Public Health &

Safety - Exposure

to electromagnetic

Fields when the

Transmission line

is operational

The transmission line

alignment fixed at a distance

of 30 m from village

settlements at a minimum.

Karnimata Construction

Company in discussion

with WSAPPL.

(Contract between

WSAPPL & Karnimata

construction company-

Refer General Clause 3.03.00 of Contract

Enclosed as Appendix

11a & b)

During planning. Completed &

Complied.


19/02/2013

Effect of Haul

Roads on

Agricultural lands-

Destruction of

standing crops and loss of top

soil, productivity

After completion of

erecting towers and stringing, the haul roads to

be restored.

The owners of the lands compensated for the loss

of standing crops.

The haul roads sprinkled

with dust suppressants to prevent re-suspension of

dust and their deposition

on agricultural lands and

crops.

Contractor (Karnimata

Construction Company)

appointed by WSAPPL

under the supervision of

WSAPPL.

During

Construction

Completed & Complied.


19/02/2013

Safety of Localities

& Traffic during

construction

Carrying out site works in a manner creating least

interference to local

community & flow of

traffic.

A passage for traffic created either along a part

of existing carriageway

under improvement or a

temporary diversion close

to the highway


Construction Company)

appointed by WSAPPL

under the supervision of

WSAPPL.

During

Construction

Completed & Complied.


19/02/2013

Legal Compliance The Statutory clearance

applications have been

submitted by WSAPPL. Assistance provided by


Construction Company).

Approvals with respect to

CEIG, PTCC, CEA,

RRVPN, Railway, Electrical

inspector handled by Contractor (Karnimata

Construction Company.

WSAPPL & Contractor

(Karnimata Construction

Company)

During

Construction

Completed & Complied. Project commissioned on

19/02/2013

6.5.1 Environmental Monitoring Plan

134. The Plant-in-charge at the project site supported by EHS Department of WSAPPL monitors the

implementation of Environment Management and Monitoring Plans at the plant site.

135. Responsibilities include:

Implementation of Social and Environmental Management Plan

Conducting and coordinating meetings as required with local communities

Conducting and facilitating EHS awareness and management trainings to the project and operations teams

Liaising with Rajasthan State Pollution Control Board for obtaining and/or renewing consent with the

support of corporate EHS.


29




136. Apart from the in-house monitoring being carried out, WSAPPL has devised a monitoring plan in

which third-party monitoring will be carried out (given low environmental impacts, once every three years)

in order to monitor the environmental parameters & comparing them with benchmarks set by the

regulatory authorities to help WSAPPL assess the environmental performance and identify gaps ensuring

immediate actions. WSAPPL has initiated the process of selecting the third-party monitoring agency.

7. FINDINGS AND RECOMMENDATIONS

137. The project is a Category B project in line with IIFCL’s safeguards framework. The site allotted for

the proposed project is on a barren government land and is not located in the vicinity of any protected

/environmental sensitive areas.

138. An environmental assessment has been carried out for the project through an external environment

consultant. No significant impacts pertaining to the project implementation are identified, and

environmental impacts are largely construction related and have been addressed through integration of the

environmental management measures outlined in the EMP as part of the bid documents of the civil

contractors.

139. Environmental clearance from MoEF/SEIAA is not required for this project as Solar Power Projects

do not require EIA/Environmental Clearance as per the EIA notification 2006 by the Ministry of

Environment & Forests (MOEF), Government of India.

140. Statutory clearances and approvals in line with the requirements of Water Act and other legal

requirements have been obtained by WSAPPL. Compliance to the requirements laid down in the

clearances by the Rajasthan State Pollution Control Board is being taken up, first quarterly compliance

report submitted to RPCB in April 2013.

141. WSAPPL has supervisory staff at the project site to ensure conformance of the contractors to the

PPE and safety measures to be adopted during construction & operation. Site visits indicated a satisfactory

compliance by the construction workers to the safety norms and PPE.

142. WSAPPL is developing its own Water Resource during operation of the Solar project. Rain Water

Harvesting, storage cum Recharge scheme integrated with drainage plan is being implemented at the

project site.

143. Application to the revenue department seeking the felling of 20 khejri trees had been submitted to

revenue department. But the trees would be retained now and no permission is required.

144. WSAPPL confirmed that all panels damaged will be taken back by the suppliers and replaced.

Therefore, the need for disposal of those panels is not triggered. Developer has identified a space within

the site which shall be earmarked for storage of such panels.

145. The alignment of the transmission line passes through government lands for a major length. Along

stretches through private lands, the contractor has worked out arrangements with the landowners prior to

the construction of the transmission lines. No outstanding grievances were reported by the local

communities to the due diligence team.

146. Consultations with the communities at the project location revealed extensive participation of the

local population as construction labour and in the provision of construction equipments and vehicles. The

CSR policies of WSAPPL are being implemented towards upliftment of the local communities including

improvements to the school buildings, development of water sources for cattle apart from development of

toilets for a group of households closer to the boundary wall of the site;

147. The environmental assessment study included monitoring of the environmental attributes including

air, water noise and soil quality at the proposed project site. The environment assessments include a

monitoring plan, wherein monitoring of air, water, noise is proposed through the appointment of an

external monitoring agency during operation stage. The appointment of monitoring agency by WSAPPL is

underway.


30




148. A landscaping plan is proposed to be implemented by WSAPPL, once the civil works at the site is

completed.

149. Overall, the development of the solar power plant including the transmission lines will not have any

significant impact on the environment.

APPENDIX

Appendix 1: CTE under Water Act

Appendix 2: CTO under Water Act

Appendix 3a & b: MOEF Memorandum

Appendix 4: Tree Cutting

Appendix 5: Ground Water Guidelines

Appendix 6: Site Plan including Landscaping Plan

Appendix 7: Plantation Plan

Appendix 8: EHS Policy

Appendix 9: Occupational Health & Safety

Appendix 10: Corporate Social Responsibility

Figure1 : CSR Initiatives Architecture (Source: Corporate Social Responsibility – 2011, Welpsun India Limited – Copy of the Document given in Appendix 7)

Details of Project Specific Community Welfare measures carried out by the Developer

1. Regular interactions have been held with the local villagers and the village Sarpanch of Kanasar and Rawra seeking suggestions from the community for developing a robust CSR plan. WSAPPL had conducted most of the discussions in an informal set up in order to offer a platform where the villagers are able to share their views without trepidation. Based on the interactions, the CSR personnel have rolled out various CSR initiatives addressing the needs of the local communities.

2. Prior to undertaking the various CSR initiatives, meetings have been held with the local authorities to obtain permission for going ahead with respective activities/projects. Minutes of meetings with Sarpanch of Rawara and the permission letters obtained from different Government departments are enclosed in Appendix 8.

3. As part of the community welfare measures WSAPPL has taken initiative in community development activities in Kanasar and Rawra villages that include: construction/enhancement of community facilities, organizing of health camps, competition events, provision of labour during construction phase etc. Details of some of the activities taken up so far are summarised as follows:

School at Kanasar village: assistance given for developing a Library-Recreation-Information Centre in the

School (Refer Appendix 9 for details of the initiative taken by WSAPPL). Apart from this, the School received

assistance from Developer to renovate the Kitchen room.

School at Rawra village: in addition to plantations in the school compound, enhancements have been made to

the school room.

Community hall in Rawra village: a community hall constructed in Rawra is being utilized by the local

population for the purpose of cooking for social functions, social gatherings, meetings of women, etc.

Construction of toilets: as the plant location caused loss of access to open area previously used for open

defecation, WSAPPL had in discussion with the two villages agreed for construction of toilets for 13

households – 6 in Kanasar and 7 in Rawra. Construction contracts have been issued to a local firm1 and the

construction is scheduled to begin in the last week of June, with a targeted completion by October 30th 2013.

Competition, events and health camps: Events such as “Come, See and Learn” including competitions have

been organized. Accordingly, Welspun has organised a competition for students of 4 schools at Rajasthan

Middle School in Rawra village (Refer Appendix 10 for details) and Medical Camp at School level in Kanasar

village (Refer Appendix 11 for details).

Distribution of sweaters to children: Two hundred sweaters were distributed to school going children of 4

schools namely Govt Primary School No. 1 & 2, Ganesh Nagar, Govt Middle Primary School, Mistri Ki Dani &

Chokhani Ki Dani, Kanasar.

Cattle health check up camp: A Veterinary Camp was held in Rawra in the month of May 2012. The cattle

health and vaccination camp was organized at Rajkiy Primary School, Raware, in which a total of 3200 small

(Goat & Sheep) and big cattle (Cow & Camel) were treated and vaccinated. A similar camp was conducted in

Kanasar village in the month of November 2012 with the support of Government Veterinary Department, Bap,

Kanasar Panchayat.

Training on cattle rearing and management: To educate the villagers on the various government schemes

and the ways in which the farmers can avail from the veterinary department, a training program was organized

at the Govt. Primary School, Takhat Ki Dani, Raware, in which 54 villagers participated.

Job fair at Jodhpur: A Job fair was organized on 25th June 2012, at Shri Ummed Rajkiya stadium in Jodhpur.

The Welspun CSR team together with the Collectorate of Jodhpur, the District employment officer & ITI

Jodhpur, planned & coordinated the event. Various employment opportunities ranging from Fitters, Electricians,

Wiremen, Turner etc were available at Welspun India Limited, Anjar, Gujarat & personnel in the age group of

18-28 years were recruited for these posts at the Job fair.

Construction of approach road: An approach road of 1.5 km was constructed in view of constant demand

from villagers and village panchayat. The road was constructed from Rawra Ki Dani to Naion Ki Dani of Rawra

village.

Installation of solar light: 2 solar lights have been installed in the Govt. Primary School, Rawra in order to

educate school children about the functioning of a solar panel.

Construction of bus-shelter with drinking water facility: WSAPPL has constructed 2 bus-shelters with

drinking water facility (PYAVU), one at Bap to Rawra road and another near Kanasar road.

4. WSAPPL has invested INR 2,952,146 on various CSR projects / activities as on date. Proposed budget and expenditure details of CSR activities at Jodhpur site of WSAPPL for the year 2012-13 is given in Appendix 12. Additionally, as per the government order issued on 14th August 2012 by the Government of Rajasthan Planning Department, WSAPPL is required to adopt at least one school and one Primary Health Centre (PHC) in the project villages. WSAPPL is required to spend approximately INR 300,000 to INR 600,000 annually for a minimum period of three years. WSAPPL spend at about INR 300,000 per year as part of the activities taken up so far.

1 M/s Babulal & Company, C202, Murlidhar Vyas Nagar, Bikaner.

Library-Recreation-Information Center developed with

assistance from Developer Renovated Kitchen room of the School

Appendix 11a & b: Contract between WSAPPL & Karnimata Construction Company

Appendix 12: Quarterly Compliance Report to RPCB

1

Annexure # 1

Plantation Plan/Details

The species selection is based on local soil condition and resource availability. The site surface mainly rock type, gravel rich. Keep this in view; the site surface is not having the features like soil, nutrient & others required to support vegetation. Therefore, it is recommended to dig holes of 1.5 m dia with 1.0 m depth and filled with soil (having nutrients) for at site plantation. Consider the ground condition at site It is recommended not to restrict plantation at site, but take up it as a site area development (include plantation at Road side) program. Some of suggested plants are as given below. It is strictly recommended not to plant any tree / herb / shrubs which not occur in the area, because it may disrupt the local environmental settings. Acacia catechu Azadiricta indica Tecomella undulate Acacia jaquemontii Prosopis cineraria Salvadora oleoides Acacia leucophloea

The saplings shall be taken from local RFO office. The Range officer has been approached in regard to with regard to the supply of saplings and sought advice on plan of action. Three villages have been identified with probable locations. The sarpanch is engaged for allocating the area in the respective villages where we will take up plantations. The sarpanch is also collaborating for allocating man power for carrying out plantation. We have connected with the local organization, which has done quite a bit of water harvesting and ensured there is water around the area. We intend to work with the same party and see if we can ensure the availability of water for the same.

In regard to biodiversity park, land need to be allotted by district administration, we awaiting such allocation. It is suggested that forest department may take up this activity and we shall along with other solar power & wind power developers will contribute proportionately. The detail of plantation plan is tabulated below.

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Sr. No. Name of Plant Species Area Covered in Acre

No. of Plant Location Expenditure

Village – Rawra (Outside the Plants Boundary )

1 Neem, Babbol , Khejdi , Pipal & Bargad

6 Acres 2550 Road Side (5 kms. stretch ‐ Raware village triraha to the end of Raware village)

Government Primary School, Takhat ki Dani, Rawra

Burial Place

Rs.931353/‐

Within the Plant Boundary

2 Gulmohar, Ashok, Neem, Kadamb, Peltaphorum, Tebulia Rosea, Plumeria Alba, Palm (Royal palm), Hibiscus (White, pink, red), kaner & Chinese Palm

1 Acre 500 R‐1 1012458/‐

3 Gulmohar, Ashok, Neem, Kadamb, Peltaphorum, Tebulia Rosea, Plumeria Alba, Palm (Royal palm), Hibiscus (White, pink, red), kaner & Chinese Palm

1 Acre 550 R‐2 1096487/‐

4 Neem, Babbol , Khejdi , Bogenvilliya, Kaner & Gulmohar

4 Acres 3500 Gap filling & R ‐3 Rs.500000/‐

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