Initial Environmental Examination

February 2013

THA: Central Solar Power Project

Prepared by Solarco Solar Co., Ltd. for the Asian Development Bank.

Initial Environmental Examination Report Solarco Solar Power Project

Prepared by

Solarco Solar Co., Ltd.

November 2012

The initial environmental examination is a document of the borrower. Initial Environmental Examination Report Solarco Solar Co., Ltd.

Table of Content

Page A. Introduction 1 B. Policy Legal and Administrative Framework 1 C. Project Description 1 D. Description of Environment 8 E. Anticipated Impacts and Mitigation Measures 13 F. Analysis of Alternative 16 G. Information Disclosure, Consultation and Participation 16 H. Grievance Redress Mechanism 16 I. Project Personnel 17 J. Environmental Management Plan 17 K. Conclusion and Recommendation 18

Initial Environmental Examination Report Solarco Solar Co., Ltd.

INITIAL ENVIRONMENTAL EXAMINATION

A. Introduction 1. Solarco Solar Co., Ltd. is the developer of a solar energy project, which is comprised of six sites in three locations. Five out of six sites, Sai Yai 1&2 and Sai Phet 1&2&3, are located in province, while the other site, Sai Kyo 1, is in province. Both provinces are situated next to one another in the central region of Thailand. The Solarco Solar project has total production capacity of 9.5 x 6 = 57 MW-AC, which will be sold to Provincial Electricity Authority or PEA under a very small power producer (VSPP) contract. 2. Solarco Solar Co., Ltd. (Solarco) was formed as a joint venture company between two parties – Yanhee Solar Power Company Limited (YSP) and Electricity Generating Public Company Limited (EGCO). The former is holding a larger stake of 51 percent, while the latter is holding the rest of 49 percent equity stake in the newly established company. The Project has an investment cost of approximately seven billion THB. Sources of funds are expected to be in various forms. A portion of about 75 percent will be financed from banks, especially a low-interest loan available from the Asian Development Bank (ADB). This leaves the rest of 25 percent to be self-invested by Solarco. 3. Being classified as Category B under the ADB classification criteria, the Project is required for an initial environmental examination (IEE) to meet the environmental assessment requirements regarding ADB’s Safeguard Policy Statement (SPS; March 2010). Moreover, the preparation of IEE also pursues the Thai environmental regulations on development of an industrial project not listed under the requirement for preparing an environmental impact assessment (EIA) report. PEA will be responsible for the construction of the new transmission line to be connected to the existing 115 kV. Such construction is not required for conducting an IEE by the environment authority.

4. The initial environment examination (IEE) report is prepared to initially assess potential impacts likely to occur from the Project’s entire life cycle on the local environmental quality and communities. The assessment came up with a set of impact mitigation measures as well as monitoring programs for the Project to pursue in order to ensure minimized adverse impacts on the environment and communities nearby.

B. Policy Legal and Administrative Framework 5. Environmental impact assessment is not required for solar power projects in Thailand. However, environmental aspect was reviewed in the project feasibility study report and Solarco held public consultation meetings to communities dwelling within the study area of its every location site. This activity was conducted to be in compliance with the requirement listed in the Thai constitution.

6. As Solarco has developed an IEE report for its solar farm project to comply with the lending and financing consideration processes of Asian Development Bank (ADB), it is necessary that the IEE conform to ADB policies and guidelines. Please see Attachment 1 for the Asian Development Bank Policies and Guidelines.

C. Project Description a. Project Sponsors 7. Yanhee Solar Power Co., Ltd. has been experienced in solar farm business in Thailand for more than two years. So far, YSP has been involved in the development of 8 solar power plants across the country, accumulating a total electricity generation capacity of 34 MW-AC from this renewable energy model.

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8. EGCO Group is Thailand’s first independent power producer. As of June 2012, it has a total generation capacity of more than 5,045 MW from its both wholly and partially owned power plants. EGCO is also involved in developing solar farms, for example, the 55 MW Solar Power Plant currently supplying electricity to Electricity Generating Authority of Thailand or EGAT. The group has strategies to expand its business towards renewable energy which is targeted to reach 300 MW by 2015.1 b. Project Location 9. The three project locations in Nakhon Pathom and Suphan Buri are as presented in Figure C-1. Each of the six sites in these three locations has its coordinates as the table below.

Sai Kyo1

Suphan Buri

Nakhon Pathom Suphan Buri

Sai Yai 1&2 Nakhon Pathom

Tha Chin river

Bang Len District

Sai Phet 1&2&3

1 Mile 2 Km Figure C-1 Locations of 6 Project Sites in Nakhon Pathom and Suphan Buri

Site Coordinates (Latitude/longitude) Address

Sai Phet 1 14⁰ 06’ 17” N / 100⁰ 10’ 19” E Hinmoon sub-district, ,

Sai Phet 2 14⁰ 06’ 29” N / 100⁰ 10’ 29” E Hinmoon sub-district, Bang Len district, Nakhon Pathom province

Sai Phet 3 14⁰ 06’ 45” N / 100⁰ 10’ 35” E Hinmoon sub-district, Bang Len district, Nakhon Pathom province

1 http://www.egco.com/en/corperate_com_press_detail.asp?press_id=174&iYear=2012 Initial Environmental Examination Report Solarco Solar Co., Ltd.

Sai Yai 1 14⁰ 08’ 06” N / 100⁰ 08’ 15” E Bang Luang sub-district, Bang Len district, Nakhon Pathom province

Sai Yai 2 14⁰ 08’ 09” N / 100⁰ 08’ 33” E Bang Luang sub-district, Bang Len district, Nakhon Pathom province

Sai Kyo 1 14⁰ 09’ 18” N / 100⁰ 08’ 15” E Bang Ta Then sub-district, Song Phi Nong district,

Sai Kyo Site 10. The Sai Kyo site is located in Bang Ta Then sub-district, Song Phi Nong district, Suphan Buri province. The site is approximately 87 km away to the northwest of City, and can be reached by using National Highway No.9, 340 and 3422, respectively. A representative grid reference of the Sai Kyo site is 14⁰ 09’ 18” N / 100⁰ 08’ 15” E. The altitude of the site, obtained from AEC’s site survey result, varies from 0.8 to 2.8 meters above mean sea level (MSL), with an average of 1.15 meters MSL. The site has an area of 175-1-44 rais, or 280,576 square meters. Aerial photograph of Sai Kyo site location is as depicted in Figure C-2.

Figure C-2 Aerial photograph of Sai Kyo site Sai Yai sites 11. The Sai Yai area comprises 2 project sites, both of which are located in Bang Luang sub-district, Bang Len district, Nakhon Pathom province. The sites are approximately 90 km away to the northwest of Bangkok City. Its location is approximately 2.6 kilometers southward of Sai Kyo’s. Site references of the Sai Yai 1&2 are 14⁰ 08’ 06” N 100⁰ 08’ 15” E and 14⁰ 08’ 09” N 100⁰ 08’ 33” E, respectively. The altitude of the sites, obtained from AEC’s site survey result, varies from 0.14 to 3.31meters MSL, with an average of 1.36 meters MSL. The Sai Yai sites 1&2 have land area sizes of 214–0–55 and 203–0–53 rais (342,620 and 325,012 square meters). There is a buffer zone between the two plots with an area size of 29-0-25 rais (46,500 square meters). Aerial photograph of Sai Yai sites location is as depicted in Figure C-3.

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Sai Phet sites 12. The Sai Phet area comprises 3 project sites, all of which are located next to one another in Hinmoon sub-district, Bang Len district, Nakhon Pathom province. The sites are approximately 97 km away to the northwest of Bangkok City. Its location is approximately 9.6 kilometers southward of Sai Kyo’s. Site references of the Sai Yai 1&2&3 are 14⁰ 06’ 17” N / 100⁰ 10’ 19” E, 14⁰ 06’ 29” N / 100⁰ 10’ 29” E and 14⁰ 06’ 45” N / 100⁰ 10’ 35” E, respectively. The altitude of the sites, obtained from AEC’s site survey result, varies from 0.45 to 3.25 meters MSL, with an average of 1.39 meters MSL. The Sai Yai sites 1&2&3 have land area sizes of 164-3-75, 205-3-50 and 213-1-89 rais (263,900, 329,400 and 341,556 square meters). There are two buffer zones located in between each two plots. The one between Sai Phet 1 and 2 has an area size of 18-2-99 rais (29,996 square meters), and the other between Sai Phet 2 and 3 is 16-3-97 rais (27,118 square meters) in size. Sai Phet sites location is as depicted in Figure C-4.

Figure C-3 Aerial photograph of Sai Yai sites 1&2

On the East side of Sai Yai site 2, there will be Solarta Solar Power Project. This project is not relevant to Solarco and it has commercially operated since the middle of 2012.

Figure C-4 Aerial photograph of Sai Phet sites 1&2&3 Initial Environmental Examination Report Solarco Solar Co., Ltd.

13. All the three project locations are located at some 200 meters away from the east bank of . This river basin is part of the Chao Phraya watershed in the central plain of Thailand. Land uses around all 6 project sites are similar; they are exploited as agricultural areas for both seasonal crops such as paddy rice and sugar cane, and livestock feedings and aquaculture. Some deserted areas are also visible. 14. Historically, the Tha Chin River basin where the project sites are to be built is usually at risk of flooding. Particularly, the worst flooding in decades occurring in 2011 indicated the flood water level of 3.2 meters MSL, comparable with average altitudes of Sai Kyo, Sai Yai and Sai Phet at 1.15, 1.36 and 1.39 meters MSL, respectively. Moreover, the flood water was retained in such basin as long as a few months. Realizing this, the project owner managed to have all the sites protected with a reliable flood protection system to safely protect all the equipment from the devastation.

c. Scope and Layout 15. The project has a total area, by summation from its six sites and buffer zones, of approximately 1,986,678 square meters. Each site occupies the same power production capacity of 9.5 MW-AC, totaling 57 MW-AC. Electricity generated from each project site will be connected to the PEA substations nearby. Layouts of all project sites in 3 locations are illustrated in Figures C-5, C-6 and C-7.

Figure C-5 Sai Kyo 1 Layout

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2

1

Figure C-6 Sai Yai 1&2 Layout

Initial Environmental Examination Report Solarco Solar Co., Ltd.

3

2

1

Figure C-7 Sai Phet 1&2&3 Layout

16. As mentioned earlier about the need to have a reliable flood protection system, the project owner decided to construct earth dike along the entire site boundary. The design concept of the flood protection system at all sites includes the implementation of the perimeter flood protection dike, water retention pond and the pumping station. The design height of the dike is referenced to the flood level at 100 year return period . Other design factors are also taken into consideration as follows:  flood level at 100 year return period +3.54 m MSL (Based on Team’s report)  Climate change factor on rainfall intensity and sea level rise base upon World Bank Study Report +0.24 m  Height of basic freeboard based upon the general design guideline +0.30 m  Height for dike settlement / land subsidence base upon World Bank Study Report +0.20 m  Additional freeboard allowance +0.12 m Total +4.40 m MSL

17. Therefore, the dike for all sites is designed to have the same height by the summary of the above design factors at +4.40 meters MSL which is higher than the maximum flood level in 2011 and flood 100 year return period 0.94 and 0.86 meters respectively. In addition, all solar PV modules will be mounted on the mounting structure at the elevation of +4.15 meters MSL, as well as all inverters and transformers which will be lifted to the same height. The conceptual design figure on flood protection system is depicted in Figure C-8.

d. Technical data and characteristics 18. Technical data and characteristics of the project’s six solar farms are summarized in Table C-1. After comparing pros and cons of different PV solar technologies, the project owner decided to employ polycrystalline silicon technology for the six solar power plants. The use of merely one solar PV model from a manufacture for the entire sites is advantageous to the project owner in terms of both technical Initial Environmental Examination Report Solarco Solar Co., Ltd.

and economic aspects. For example, the logistics of spare parts as well as operation and maintenance practices will be easily handled and managed, and the procurement will benefit from better price deal due to economy of scale. e. Construction 19. The project construction works are expected to take about 11 months. Major civil works include land clearance and leveling, construction of infrastructure including internal roads, drainages, retention ponds and flood protection dikes, PV structure installation, and building of switchyards. Besides, all electrical works are also to be finished within the construction period. The proposed construction plan of the project is illustrated in Figure C-9. 20. The power produced from each project site is to be transmitted via new 115 KV transmission lines. The route of the new transmission lines will follow the existing right-of-way of PEA along the local road connecting between the existing 115 KV on National Highway No. 3422 and the Sai Phet sites, approximately 9.4 kilometers in length. No additional land acquisition and no properties or crops will be damaged. PEA will handle the construction and installation of the new transmission line. Map of the newly established 115 KV transmission lines is presented in Figure C-10. 21. Referring to Figure C-6, Sai Yai sites are located some 300 meters away from the local road. A new road will be constructed as an access road between the sites and the local road. This construction is included within the project construction, and the land acquisition process with YPH for the road was completed. The new road is approximately 300 meters in length and 6.0 meters in width. Also, a transmission line will be installed along the right-of-way of the road.

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4.4

Figure C-8 Conceptual Design Plan for Flood Protection System of All Solarco Sites

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Table C-1 Descriptions of each project site

Item Sai Phet 1 Sai Phet 2 Sai Phet 3 Sai Yai 1 Sai Yai 2 Sai Kyo 1 Plant capacity 11.99 MW-DC 11.99 MW-DC 11.99 MW-DC 11.99 MW-DC 11.99 MW-DC 11.99 MW-DC (9.5MW-AC) (9.5MW-AC) (9.5MW-AC) (9.5MW-AC) (9.5MW-AC) (9.5MW-AC) PV Modules Cell technology Polycrystalline Polycrystalline Polycrystalline Polycrystalline Polycrystalline Polycrystalline Manufacturer/country REC/Singapore REC/Singapore REC/Singapore REC/Singapore REC/Singapore REC/Singapore Model REC250PE REC250PE REC250PE REC245PE REC245PE REC245PE No. of modules 48,384 48,384 48,384 48,975 48,975 48,975 Cell production capacity (Watt) 245 245 245 250 250 250 Inclination (degree) 12 12 12 12 12 12 Demension (mm) 1,665 x 991 x 38 1,665 x 991 x 38 1,665 x 991 x 38 1,665 x 991 x 38 1,665 x 991 x 38 1,665 x 991 x 38 Height of panel above ground 4.15 4.15 4.15 4.15 4.15 4.15 (cm)

Inverters Manufacturer/country SMA/Germany SMA/Germany SMA/Germany SMA/Germany SMA/Germany SMA/Germany Type Central inverter Central inverter Central inverter Central inverter Central inverter Central inverter Model Sunny Central Sunny Central Sunny Central Sunny Central Sunny Central Sunny Central 800CP 800CP 800CP 800CP 800CP 800CP Maximum power output (kW) 800 800 800 800 800 800 No. of inverters 12 12 12 12 12 12 Transformers Manufacturer/country Thirathai/Thailand Thirathai/Thailand Thirathai/Thailand Thirathai/Thailand Thirathai/Thailand Thirathai/Thailand Model 2,000kVA(0.36/22KV) 2,000kVA(0.36/22KV) 2,000kVA(0.36/22KV) 1,760kVA(0.36/22KV) 1,760kVA(0.36/22KV) 1,760kVA(0.36/22KV) and and and and and and 12MVA(22/115kV) 12MVA(22/115kV) 12MVA(22/115kV) 12MVA(22/115kV) 12MVA(22/115kV) 12MVA(22/115kV) No. of transformers 6 and 1 6 and 1 6 and 1 6 and 1 6 and 1 6 and 1 (LV/MV and MV/HV)

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No. Items M1 M2 M3 M4 M5 M6 M7 M8 M9 M10 M11

1 Site survey

2 Earthworks, leveling

3 Dike and road

4 Drainage, retention pond

5 Structure installation

6 Mounting PV modules

7 Inverter installation

8 Sub-station and electrical works

9 Water distribution, fire alarm, CCTV & perimeter lighting

10 COD and performance test

Figure C-9 Proposed Project’s Construction Plan

Figure C-10 Map of Newly Installed 115 KV Transmission Lines Connecting Project Sites

Initial Environmental Examination Report Solarco Solar Co., Ltd.

D. Description of Environment a. Physical Environment 22. Topography The land is located in the alluvial low-lying plain of the Tha Chin River. No high mountains or tall buildings are observed in the area. The altitude of the three sites, obtained from AEC’s site survey result, varies from 0.14 to 3.31meters MSL. The average elevations of Sai Kyo, Sai Yai and Sai Phet stand at 1.15, 1.36 and 1.39 meters MSL, respectively. Being flat and close to the river, the area is at risk of flooding during the rainy season. 23. Geology The site is underlain by clay layer. The consistency of clay layer varies from soft to be stiff clay at deeper depth. To mitigate the risk of flooding, all the project sites will be backfilled by soft clay to +2.30 m MSL. 24. Seismic data The Department of Public Works and Town & Country Planning (DPT) has classified seven zones for the areas which located within and proximity to Bangkok (called as the “Basin of Bangkok”). All the project sites, except Sai Kyo, are located in Bang Len district, Nakorn Pathom province, and are therefore located in zone 1, according to the national standard DPT 1302-2552. The Sai Kyo site is located in Song Phi Nong district, Suphanburi province, outside the seven zones classified by DPT. All technical parameters/factors used in the structural design calculation have been selected in accordance with the requirements of national standard DPT 1032-2552 for zone 1. 25. Climate Nakhon Pathom and Suphan Buri are situated in the central region of Thailand which has 3 seasons – summer from March to May, rainy from June to October, and winter from November to February. According to the Thai Meteorological Department (TMD), the 30 years statistical data (1961 – 1990) of Suphan Buri shows that the mean maximum temperature in summer was 36.9 degree Celsius, and the mean minimum temperature in winter stood at 19.2 degree Celsius. Yearly average rainfall was 1,112.8 mm, and annual mean rainy day is 102 days. 26. Surface Water The Tha Chin River is the main source of surface water in the area. This river originates as a separated branch of the in , and then flows southward in parallel to the Chao Phraya river through many provinces and mouth the Gulf of Thailand at the river delta in , the adjacent southward province of Nakhon Pathom. The river plays a significant role for local communities where it passes by as various daily activities take place there. For example, it is the source of raw water for waterworks, irrigation and fisheries for those locals. Also, the river is used as a main transportation route for local produces. Other than the Tha Chin River, a number of man-made and natural ponds are visible in the area, and they are usually utilized for fisheries and irrigation. 27. Underground Water The water use within the project sites is predominantly from underground source, particularly for their PV panels cleaning process. 28. Land Use The Project’s neighboring lands, lying along the alluvial plain of the Tha Chin River and having fertile soil, are found widely used for growing seasonal crops, particularly paddy rice and sugar cane, and perennial trees, such as eucalyptus farming. Majority of project area are used for eucalyptus farming while the rest are unutilized. The Project sites have no record of being dwelled permanently like a community within. 29. Solar Potential Based upon the study of Department of Alternative Energy Development and Efficiency (DEDE) for the period of the year 1995 – 2010, the average global irradiance of Thailand is 4.9 kWh/m2-day. In particular, the project sites -- Sai Kyo, Sai Yai and Sai Phet – have annual radiance of 4.9 kWh/m2-day. b. Biological Environment 30. The project site and nearby area is not located in or near a sensitive ecosystem, for example national parks, wildlife sanctuaries, national forests, etc. Evidence of uses of land for agricultural and residential purposes is prevailing across the project’s surroundings. The project area is predominantly planted by eucalyptus trees. For the aquatic environment, common fishes (walking catfish, pangasius, silver barb) are found in the river and no endangered species will be affected by the project. Seasonal

- 12 - Initial Environmental Examination Report Solarco Solar Co., Ltd. birds such as egrets visit the area during winter only (about 3-4 months). The nearest bird observation station is at , Kamphaengsaen Campus, about 25 km. c. Socioeconomic Environment 31. Socioeconomic data of the 3 locations where the project sites are located in is as summarized in the table below. There are no indigenous people found within the project sites.

Site location Hinmoon sub-district1 Bang Luang Bang Ta Then sub-district2 sub-district3

Project site Sai Phet 1&2&3 Sai Yai 1&2 Sai Kyo 1

Type of local Administration Municipality Tambon Administration administration Office Office

No. of villages within 12 5 18

Population 5,969 (2,926 males and 2,330 (1,126 males and 15,418 (7,611 males and 3,043 females) 1,204 females) 7,807 females)

No. of households 1,540 650 4,815

Economy Agriculture 70% Commerce 70% Agriculture and others Self-employed 15% Agriculture 15%

Industries 3 factories/ 2 rice mills 3 rice mills n.a.

Average income/year 25,000 baht/capita Agri: 90,000 n.a. baht/household Business owner : 200,000 baht/household Employee : 70,000 baht/household

No. of schools 2 primary 2 primary & 1 secondary 10 primary & 2 secondary

Public health facilities 1 health center (3 beds) 1 hospital 2 hospitals

Source: 1 http://www.hinmool.go.th/ 2 http://www.bangluang.go.th/ 3 http://bangtathen.go.th

d. Historical and Cultural Value 32. The project site and the surrounding areas have no important historical and cultural sites. There has been no record of archeological findings.

E. Anticipated Impacts and Mitigation Measures a. Impacts During Pre-construction 33. Land preparation for project construction may result in land clearance. Approximately 800 rais (128 hectares) of eucalyptus plantation will be cleared for site preparation. All the trees that were cut will be purchased by a pulp mill as raw material under a contract farming agreement. In terms of disposal of trees that were cut, this will not pose any environmental impact. 34. As the project site elevation is relatively low, the sites are planned to be backfilled to an elevation of +2.30 m MSL before

- 13 - Initial Environmental Examination Report Solarco Solar Co., Ltd. construction. In addition, all the sites are designed to be surrounded with embankment. The backfilling and embankment activities which require a large volume of backfill materials may pose potential risks over road accident, damage of road surface, dust emissions from material spillage, etc. General data on backfill material transport is as below.

Project Site Distance from source Required volume of No. of trips per Status of Land to backfill site (km) backfill materials (m3) day Preparation*

Sai Kyo 6.0 450,000 400 Completed

Sai Yai 1&2 8.4 1,070,000 400 38%

Sai Phet 1, 2&3 3.2 1,780,000 400 11%

Remarks: Status of land preparation is as of November 30, 2012

35. Solarco has hired a contractor to do the site clearing and backfilling activities. The contractor is to take responsibility of minimizing environmental impact on the surroundings by following the project’s environmental and social management plan (ESMP). For example, the contractor must install wash bays at the entry/exit of the project sites, the trucks hauling backfill material must be covered properly before entering public roads, and traffic officers facilitating traffic of hauling trucks at the site entrance/exit must be provided. Since these activities are to be performed temporarily and the trucks will mostly traverse paved road, the impact is expected to be acceptable. b. Impacts During Construction 36. Construction period of the Project comprise two main works – civil and electrical works. It is clear that civil works such as construction of earth dike, road, reservoir, trenches, etc. are more likely to generate adverse environmental impacts than those of electrical works. Such civil works covers a duration of about 9 months out of the 11-month construction period of the project (refer to Figure C-9). 37. Potential environmental impacts from the project’s construction can be mostly visible in the forms of emissions of particulate matters and exhausted gases, noises, and road traffic. Major sources of air and noise pollution are from earth adjustment activities induced by earth moving machines, trucks and heavy construction equipment. The presence of hauling trucks conveying construction materials and PV equipment will extend potential risks over road accident, damage of road surface, dust emissions from material spillage, etc. from the pre-construction period. It is expected that there are as many as 13,000 trips of trucks hauling construction materials and PV equipment to the project sites. 38. In order to cope with these foreseen impacts, Solarco will have its construction contractors, as well as sub-contractors, to execute construction activities in accordance with its environmental and social management plan (ESMP). Furthermore, such impacts would be perceived during only construction period which is temporary (about 9-11 months). Having implemented the ESMP during the project construction and being supervised by Solarco personnel, it is expected that the environmental impacts during project construction would be minimal. c. Impacts During Operation 39. The operation of a solar power plant neither creates significant pollution emissions nor exploits consideration amount of natural resources. The solar power plant consumes only natural and renewable raw material – sunlight – to produce DC electricity using its PV equipment. There are no emissions of air pollution, noise, or odor generated from this process. 40. Clear water might be needed in a maintenance practice of the PV panels. The use of water for cleaning solar panel surfaces to be clear of dust and dirt is necessary in maintaining power production efficiency of the plant. This activity is expected to be exercised at a frequency of two or three times a

- 14 - Initial Environmental Examination Report Solarco Solar Co., Ltd. year at each site. The amount of water used each time of cleaning is estimated to be 100,000, 200,000 and 300,000 cubic meters at the sites of Sai Kyo, Sai Yai, and Sai Phet, or equivalent to 2 liters per panel. The source of water used for cleaning the PV panels is underground water, with daily allowable amount of underground water to be pumped from the source to be in accordance with the Department of Mineral Resources. Basically, it is planned to have 1 groundwater well at Sai Kyo, 1 well at Sai Yai, and 2 wells at Sai Phet, totaling 4 wells. For the domestic water use, drinking water will be purchased for the staff, and water for other purposes are taken from the groundwater well. As the source of water use by the Project is different from the local communities’. This will not affect the local water supply. 41. Wastewater from the cleaning practice of solar panels contains only suspended solids of earth dust without any toxic substances. It will be left to seep into the soil within the plant boundary. Run-off rainwater within the Project will be collected through the trenches to retention ponds which are provided within every project site. These ponds are designed to sufficient collect the run-off rainwater in every project site within 3 hours, before further drained by pipe culvert or pumped to the public drainage system. These ponds are designed to reduce the impact of rainwater run-off from the project sites to the surroundings that may cause flash flood. 42. Solid and liquid wastes do not prevail during normal operation period of a solar power plant. However, the preventive maintenance of the plant may deal with replacements of some equipment parts and lubricants, and results in creation of used spare parts and used lube oil. Such solid and liquid waste, either hazardous or not, shall be treated in accordance with the government rules. Provision for septic tank to treat wastewater is mandated. This practice will not pose any environmental impact in the local areas. d. Decommissioning 43. According to the PV panel supplier, all PV panels are scheduled to be replaced every 25 years, or longer operation time will result in efficiency reduction of the power generation to be lower than 80 percent. The decommissioned or expired panel sets, if without proper management, are expected to become waste and be discarded in landfills, resulting in significant environmental concern from its significant amount of silicon. Realizing this concern, the Project has contacted REC, the supplier of PV panels, to take all the PV panels after expiring to its recycling facilities. REC (Renewable Energy Corporation ASA) is a full member of PV Cycle Association – a solar industry alliance that is pooling resources to collect and recycle solar modules from customers of member companies when the products reach the end of their useful life (http://www.pvcycle.org/membership/member-info/?id=125). Thus, there is minimal impact from decommissioning practice of the Project. e. Social Impacts 44. The project will require a total of 198.67 hectares of land to establish the solar farm including buffer zones. At least 128 hectares of the total project area planted to eucalyptus trees will be cleared. There are occasional workers in the eucalyptus farm. These workers, however, own 20-30 rais of riceland which are not affected by the project and serves as main source of their income. These workers transferred to another eucalyptus farm which is also owned by YPC (the land owner of the project site) and if interested, they may opt to apply as laborer during project construction. Solarco entered into Lease Agreement with Yanhee Solar power Corp., Ltd. (YPC) for the land that will be used for the project for a period of 25 years. Negotiation was done on a willing lessor, willing lessee basis. There are no households or communities residing in the area. In addition, the project areas and surroundings have no record of settlements of ethnic groups or indigenous peoples (IPs). Accordingly, the emergence of the Project in these areas will not cause displacement of local communities nor impact on indigenous people. Under this condition, the Project is classified as category C both for involuntary resettlement and indigenous peoples.

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F. Analysis of Alternative 45. According to the Project’s Feasibility Study Report, the final stage for EPC contractor selection has come up with two contractors. However, both preferred contractors proposed PV modules from REC (Singapore) with its prevailing characteristics addressed. Therefore, REC’s polycrystalline PV panels will be employed for the Project’s all six solar power plants. No alternative site has been proposed aside from this area since the government has designated it as area for solar power development.

G. Information Disclosure, Public Consultation and Participation 46. Solarco Solar Co., Ltd. in association with local authorities – Bang Ta Then Tambon Administration Organization (TAO), Bang Luang TAO and Hinmoon TAO – organized public consultation meetings at the communities where the Project sites are to be established. The meeting at Bang Ta Then sub-district where the Sai Kyo site to be located was held on July 17, 2012 at the TAO office. In Bang Luang sub-district where the 2 sites, namely Sai Yai 1&2, are located, the Bang Luang TAO office held 2 public consultation meetings: the meeting No.1 was on May 10, 2012, and the meeting No.2 was on July 6, 2012. Both the meetings were held with the locals living around the Sai Yai sites, particularly in Moo 17, participating in. The Sai Phet sites are located in Hinmoon sub-district. A public consultation meeting was held by Hinmoon TAO. Community leaders and local people living around these three sites together with the eucalyptus workers/laborers were among the participants in the public consultation. There were some questions especially the available job positions for the local people and the future impact to them. However, there were no significant issues and the company emphasized that the first priority is the recruitment from local people as well as encourage female to work for the project. 47. The public consultation meetings at all project sites comprised the following activities: project information disclosure, presentation and discussion on pros and cons of a solar energy project, proposing Environmental Management Plan (EMP), Q&A, and public hearing. It is noted that most people quite understood the less impact from the project activities compared with that from thermal power plants. In addition, many requested that the Project provide job/employment opportunities to local people, offer communication channels to the locals, and support local communities in some occasions. The Project instantly replied to the participants that all the requests have been in the Project’s community plan. In conclusion, majority of participants in all areas were backing the establishment of the Project. 48. In addition, the Project is to pursuit the ERC (Energy Regulatory Commission)’s requirement on establishing a power fund to the local communities wherea power project is located. Under this requirement, a power fund will be collected from a power plant project in order to develop the local communities or to use for mitigating the negative impacts occurring from the power plant on the locals. The rate of collection depends on size and type of fuel use of a power plant. For example, during construction, the project has to transfer 50,000 THB/MW/year to the fund. And during operation, a renewable power plant like Solarco has to transfer 0.01 THB per unit of electricity produced in a year to the fund. The fund will be administered by a local commission created as per the ERC’s requirements.

H. Grievance Redress Mechanism 49. A Grievance Redress Mechanism (GRM) has been devised to provide a venue to discuss issues through conflict resolution and address issues adequately. During project construction and operation, a community relations (CR) officer who will be posted at the site office will be responsible in receiving and handling complaints or query regarding the project. 50. Four (4) channels for public communication and complaints will be made available: drop box, website, establishment of grievance hotline (telephone) and formal complaint though letter/mail. Out of the 4 channels, hotline can be the most effective way to contact the CR officer and discuss complaints as it is a two-way communication. The Operation Manager of ESCO as the project operator / General Manager of Solarco / Corporate Communications Manager of EGCO will be regularly updated by the

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CR officer to make sure that appropriate actions are undertaken based on complaints received. If the impact or issue is beyond the authority at the operations level, it will be elevated to the management for immediate and appropriate solution. Then, the CR officer will respond immediately to the complainant. 51. Management of Complaints or Query. A community member can approach or call the CR officer anytime for complaints or query. A formal complaint (letter) can also be sent (a complaints box will also be provided in the CR office) to the CR officer or the General Manager for timely appropriate action. Any complaint filed will be immediately handled and targeted to be settled by the CR officer within 3 working days. The CR officer will be maintaining a Record Book to keep track of the following: (a) date of the complaint, (b) details about the complainant (name and contact information), (c) description of grievance, (d) actions taken, (e) follow up requirements, and (f) the target date for the implementation of the mitigation measures, if there are any. The record book will include a narrative on the actual measures/process undertaken to handle or mitigate these concerns. I. Project Personnel 52. Despite operating its six project sites in Nakhon Pathom and Suphan Buri provinces, Solarco has its head office at EGCO’s Bangkok office where the management level and administration office are functioning. At sites, Solarco’s operational staff is based and functioning during operational phase. The Project’s construction will be carrying out by EPC contractors as well as their sub-contractors. Solarco will appoint an administrative officer for the 6 project sites. 53. During construction, it is expected that the maximum number of construction workers, including foremen and engineers, at any particular time at each project site will be 160 people. The command and control of those construction workers is under the EPC contractor’s supervision. During operation phase, the number of Solarco’s staff, including operators, maintenance team and security guards, at each site will be approximately 20 people. Most of Solarco’s staff will be recruited from qualified personnel from the Project’s vicinities. 54. For O&M, ESCO will handle all the operation and maintenance of the solar power farms. ESCO will also cover the Environment, Health and Safety (EHS) and Community relation aspects of the project. J. Environmental and Social Management Plan (EMP) 55. This chapter outlines the environmental and social management plan (ESMP) and defines the institutional arrangements required for the implementation of the plan. This ESMP also presents the environmental and social monitoring requirements for different phases of the project. ESMP during the construction and operation period is shown from Table J-1 to Table J-2. 56. Objectives of ESMP. This ESMP provides the delivery mechanism to address the adverse environmental and social impacts of the proposed project during its implementation, to enhance project benefits, and to introduce standards of good practices to be adopted during all project stages. The primary objectives of the ESMP are to:  Facilitate the implementation of the mitigation measures identified in this report;  Define the responsibilities of the project proponents, contractors, and environmental issues among them;  Define a monitoring mechanism and identify monitoring parameters in order to ensure complete implementation and effectiveness of identified mitigation measures; and  Provide a mechanism for taking timely action in the face of unanticipated environmental or social situations 57. This ESMP provides the delivery mechanism to address the adverse environmental and social impacts of the proposed project during its implementation, to enhance project benefits, and to introduce standards of good practices to be adopted during all project stages.

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58. Solarco will designate the Plant Manager as the EHS Officer. He will ensure that all personnel adhere to general environmental protection measures and specific mitigation measures as reflected in the ESMP are properly implemented. He will also be responsible for the EHS activities at the field level. The Field Technical Officer will support the EHS Officer during construction and operation of the project. The Contractor will be subject to certain liabilities under the environmental laws of the country and under its contract with Solarco. 59. During the operation phase of the proposed project, environmental and social management will become a routine function, as an integral part of the O&M activities. ESCO will provide support to Solarco within whole project life. a. Occupational Health and Safety (OHS) 60. Solarco is concerned on Occupational Health and Safety of its staff and contractors during both construction and operation periods. Therefore, an action plan on OHS is set up in order to mitigate the risk of injury and asset loss at work, and this action plan is included within the Project’s environmental management plan which is applied to its staff and contractors at all sites. The Project’s EMP is presented in Table J-1 and Table J-2. b. Environmental Management 61. Following the environmental assessment, despite environmental impacts from such a project operation not prevailing, some minor adverse impacts are addressed and expected. Thus, the Project has come up with a set of environmental mitigation measures to avoid or minimize adverse impacts throughout the Project’s life cycle. These measures are set as requirements for every activity of the Project, either implemented by its own staff of EPC contractors, to rely on. The EMP, comprising a set of environmental mitigation measures and a plan of monitoring and inspection, is as presented in Table J-1 and Table J-2. 62. The supervision, evaluation, and reporting of activities implemented as per the EMP will be carried out strictly and punctually to provide feedback to the ADB Project management team. c. Social Management 63. EGCO Group is renowned for having exercised its business taking into account social and environmental responsibilities in line with the company’s commitment “Energy for Life”. Solarco follows the same commitment of its parent company as the solar farm project takes into account public participations in its operation and contribution to sustainable development of the local communities. To name a few, the Project gives importance to local people to work in its plants, as well as encouraging the EPC contractors to hire local workers for the project construction. It also provides communication channels for the public to exchange messages, either complaints or information/suggestions, with the company. There is an annual budget provided for the Corporate Social Responsibility (CSR) and the Company is studying the proper activities to gain the most benefits to the community. 64. Solarco will also comply with the applicable labor laws in relation to the Project and will take specific measures in relation to internationally-recognized core labor standards in compliance with ADB’s Social Protection Strategy (Attachment A).

K. Conclusion and Recommendations 64. The nature of a solar power plant is known to have minimal adverse impacts on the environment throughout its operation stage. Potential negative impacts can be expected during project construction phase, and decommissioning of solar panel in the forms of noise and PM emissions, and discarding of expired PV panels, respectively. The Project has foreseen these concerns as it proposed a set of mitigation measures and a monitoring plan in the form of EMP for its contractors and staff to strictly pursue. Consequently, it is expected that adverse impacts from the Project’s life cycle will be minimal.

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65. The establishment of the Project in Tha Chin River basin of Nakhon Pathom and Suphan Buri provinces is supported by local communities and the sub-district municipality, resulting from the information disclosure and consultation programs implemented at both levels. The people expected that the emergence of such project will not pose significant negative impacts on the environment. Instead, it would contribute to local employment and increased income, and the renewable energy generated would stabilize local energy supply in sustainable way. In addition, the provision of communication channels between the communities and the Project will form better understanding between the two parties. The local’s expectation on the Project is in line with the Project’s commitment on environmental and social responsibility. 66. As the project operation mainly needs personnel with special technical skill, which is far beyond what the local people currently have, it is recommended that the Project put an effort on enhancing capacity of local people to be able to take part in the project operation.

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Table J-1 Environmental and Social Management Plan (ESMP)

Institutional Responsibility Impacts Proposed Mitigation Approximate Time Frame Budget Measures Location Implementation Supervision Construction phase Noise: Trucks and - Maintain construction machines in - At site Construction Included in EPC EPC contractor Solarco construction good conditions to avoid excessive period contractor’s budget machines noises generated. - Uses of heavy machineries are not - At site allowed during 18:00-06.00 hrs. - If necessary, instruct contractor to - At site install temporary noise barrier at the project area that is close to the communities before starting the construction Air quality: - Remove earth from trucks’ wheels - Site’s exit and Construction Included in EPC EPC contractor Solarco - Particulate before leaving the project site. public roads period contractor’s budget matters (PM) - Truck hauling construction nearby materials are required to cover its container unit to prevent spillage. - At site - Exhausted gases - Maintain construction machines in good condition to prevent incomplete combustion. Occupational - Construction workers shall be - At site Construction Included in EPC EPC contractor Solarco Health and Safety trained in relevant working area period contractor’s budget prior to execute work.

- Construction workers shall be provided and equipped with personal protection equipment (PPE) related to particular work - Particular works shall be strictly

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followed work permit scheme, i.e. hot work, confined space, etc. Transportation - Use of vehicles shall be strictly - Public roads Construction - EPC contractor Solarco conformed to traffic rules (loading, period speed, etc). - Designate officers to take care of safety and traffic at the entrance/exit of every project site. Socio-economic Creation of community relations - Within the Construction Included in Community Solarco Condition team to promote good relationship project site period Solarco’s budget Relations Office with the community, provide and (during

project information/status and look communities construction )

after and receive complaints and around the

query during project construction site and provide immediate and

appropriate action

Comply with core labor standards - At site Construction Included in Solarco (CLS) and national labor laws as period contractor’s Contractor part of ADB’s Social Protection budget Strategy

Table J-1 Environmental and Social Management Plan (ESMP continued)

Institutional Responsibility Impacts Proposed Mitigation Approximate Time Frame Budget Measures Location Implementation Supervision

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Operation phase

Water quality and - Provide a retention pond with a - At site During operation Included within the Solarco Local authority flood protection capacity enough to hold run-off project owner’s water 3 hrs within each project site. budget - Clear water may be discharged to natural water when necessary, but not to boost severity of flooding outside, if any.

Hazardous waste - Hazardous waste such as used lube - At site During operation Included within the Solarco Local authority oil and contaminated rags shall be project owner’s treated or discarded in accordance budget with related laws on mobilizing hazardous waste. Creation of community relations - Within the Community Solarco Socio-economic Construction Included in Relations Office Condition team to promote good relationship project site period Solarco’s budget with the community and look after and and ESCO

and receive complaints/queries and communities

provide immediate and appropriate around the action site

Operation period Included in Comply with core labor standards - At site Solarco’s budget (CLS) and national labor laws as Solarco part of ADB’s Social Protection Strategy

Decommissioning phase

Expired PV panels - Contact REC or a certified recycling - At site When PV panels Included within the Solarco Local authority agency to collect the expired PV get expired project owner’s panels for recycling. budget - Follow related laws on mobilizing industrial waste.

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Table J-2 Environmental and Social Monitoring Plan

Environmental Project stage Parameters Standard Location Frequency Institutional responsibility Component Implementation Supervision Occupational Construction As specified in As specified in At site Weekly Construction EPC contractor Health and EPC contractors’ contractors’ plan workers Safety OHS plan

Community Community Construction and Community One community At site or within One community Solarco Relations Officer Relations/Grievance Operation meetings meeting/updating nearby meeting/updating and ESCO Redress Mechanism conducted and during communities during information construction and construction and

materials prepared one during one during and disseminated project operation project operation to the community

Number of Depending on the Depending on the Community Solarco complaints/queries complaints filed complaints filed Relations Officer and ESCO received regarding the project

Employment Construction Data/Information on workers hired during construction generation Male Female Total Wage

Skilled

Unskilled Operation Data/information on workers hired during project operation Male Female Total Wage Skilled Unskilled

- 17 - Attachment A Asian Development Bank (ADB) Policies and Guidelines

1. ADB policies and standards to manage social and environmental risks and impacts are considered:

(i) ADB Safeguard Policy Statement (2009); (ii) Social Protection Strategy; (iii) Public Communication Policy; and (iv) Labor Standards.

The ADB’s Safeguard Policy Statement 2009 sets out the policy objectives scope and trigger, and principles for following three key safeguard areas:

(i) Environmental safeguard; (ii) Involuntary resettlement safeguard; and (iii) Indigenous people safeguards.

2. The objective and scope of above three key areas are briefly described as under. 3. Environment Policy. This policy element ensures the environmental soundness and sustainability of projects and supports the integration of environmental considerations into the project decision-making process. Environmental safeguards are triggered if a project is likely to have potential environmental risks and impacts.

4. During the design, construction, and operation of a project the borrower/client will apply pollution prevention and control technologies and practices consistent with international good practice, as reflected in internationally recognized standards such as the World Bank Group’s Environment, Health and Safety Guidelines.

5. Involuntary Resettlement Policy. This policy guideline encourages avoiding involuntary resettlement by exploring project and design alternatives; to enhance, or at least restore, the livelihoods of all displaced person in real terms relative to pre-project levels; and to improve the standards of living of the displaced poor and other vulnerable groups

6. The involuntary resettlement safeguards covers physical displacement (relocation loss of residential land or loss of shelter) and economic displacement (loss f land assets, access to assets, income sources, or means of livelihoods) as a result of (i) involuntary restrictions on land use or on access to legally designated parks and protected areas. It covers them whether such losses and involuntary restrictions are full or partial, permanent or temporary.

7. Indigenous People Policy. This guides the project proponent to design and implement projects in a way that fosters full respect for indigenous peoples’ identity, dignity, human rights, livelihood systems, and cultural uniqueness as defined by the indigenous peoples themselves so that they (i) receive culturally appropriate social and economic benefits, (ii) do not suffer adverse impacts as a result of projects, and (iii) can participate actively in projects that affect them.

8. The indigenous people’s safeguards are triggered if a project directly or indirectly affects the dignity, human rights, livelihood systems or culture of indigenous peoples or affects the territories or natural or cultural resources that indigenous peoples own, use, occupy, or claim as an ancestral domain or asset. The term indigenous peoples are used in a generic sense to refer to a distinct, vulnerable, social and cultural group possessing the following characteristics in varying degrees: (i) self-identification as members of a distinct indigenous cultural group and recognition of the identity by others; (ii) collective Initial Environmental Examination Report Solarco Solar Co., Ltd.

attachment to geographically distinct habits or ancestral territories in the project area and to the natural resources in these habits and territories; (iii) customary cultural, economic, social, or political institutions that are separate from those of the dominant society and culture; and (iv) a distinct language, often different form of the official language of the country or region. In considering these characteristics, national legislation, customary law, and any international conventions to which the country is a party will be taken into account. A group that has lost collective attachment to geographically distinct habits or ancestral territories in the project area because of forced severance remains eligible for coverage under this policy.

9. Policy on Gender and Development (1998). The Asian Development Bank (ADB) first adopted a Policy on the Role of Women in Development (WID) in 1985 and over the passage of time has progressed from a WID to a gender and development (GAD) approach that allows gender to be seen as a crosscutting issue influencing all social and economic processes. ADB‟s policy on GAD will adopt mainstreaming as a key strategy in promoting gender equity. The key elements of ADB‟s policy will include the following.

10. Gender sensitivity: to observe how ADB operations affect women and men, and to take into account women’s needs and perspectives in planning its operations

11. Gender analysis: to assess systematically the impact of a project on men and women, and on the economic and social relationship between them

12. Gender planning: to formulate specific strategies that aim to bring about equal opportunities for men and women Mainstreaming: to consider gender issues in all aspects of ADB operations, accompanied by efforts to encourage women‟s participation in the decision-making process in development activities

13. Agenda setting: to assist developing member country (DMC) governments in formulating strategies to reduce gender disparities and in developing plans and targets for women‟s and girls‟ education, health, legal rights, employment, and income-earning opportunities

14. ADB will aim to operationalize its policy on GAD primarily by mainstreaming gender considerations in its macroeconomic and sector work, including policy dialogue, lending, and technical assistance (TA) operations. Increased attention will be given to addressing directly gender disparities, by designing a larger number of projects with GAD either as a primary or secondary objective in health, education, agriculture, natural resource management, and financial services, especially microcredit, while also ensuring that gender concerns are addressed in other ADB projects, including those in the infrastructure sector.

2001 Social Protection Strategy

15. ADB’s Social Protection Strategy 2001 requires the Borrower to comply with applicable labor laws in relation to the Project, and take the following measures to comply with the core labor standards2 for the ADB financed portion of the Project;

(a) carry out its activities consistent with the intent of ensuring legally permissible equal opportunity, fair treatment and non discrimination in relation to recruitment and hiring, compensation, working conditions and terms of employment for its workers (including prohibiting any form of discrimination against women during hiring and providing equal work for equal pay for men and women engaged by the Borrower);

1 the core labor standards are the elimination of all forms of forced or compulsory labor; the abolition of child labor; elimination of discrimination in respect of employment and occupation; and freedom of association and the effective recognition of the right to collective bargaining, as per the relevant conventions of the International Labor Organization;

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(b) not restrict its workers from developing a legally permissible means of expressing their grievances and protecting their rights regarding working conditions and terms of employment;

(c) engage contractors and other providers of goods and services:

(i) who do not employ child labor3 or forced labor;4

(ii) who have appropriate management systems that will allow them to operate in a manner which is consistent with the intent of (A) ensuring legally permissible equal opportunity and fair treatment and non discrimination for their workers, and (B) not restricting their workers from developing a legally permissible means of expressing their grievances and protecting their rights regarding working conditions and terms of employment; and

(iii) whose subcontracts contain provisions which are consistent with paragraphs (i) and (ii) above.

The above measures should be incorporated in the environmental (and/or social) management plan (EMP).

The monitoring and reporting requirements in the EMP should also state that the Borrower will provide ADB with an annual report on its compliance with the measures identified above (which may be included in any report (e.g. Environmental and Social Monitoring Report) required to be provided by the Borrower to ADB).

For additional guidance please refer to the 2001 Social Protection Strategy (SPS) and the Core Labor Standards Handbook:

 http://www.adb.org/Documents/Policies/Social_Protection/social-protection.pdf  http://www.adb.org/documents/handbooks/Core-Labor-Standards/CLS-Handbook.pdf

2011 Public Communications Policy

16. The Public Communications Policy of ADB guides the institutional efforts to be transparent and accountable to the people it serves. The Policy recognizes that transparency and accountability are essential to development effectiveness. The objective of the policy is to enhance stakeholders’ trust in and ability to engage with ADB. The policy recognizes the right of people to seek, receives, and imparts information about ADB operations. It supports knowledge sharing and enables participatory development or two-way communications with affected people. The policy is based on a presumption in favor of disclosure unless there is a compelling reason for nondisclosure. It commits ADB to disclose institutional, financial, and project-related information proactively on its website, following strictly time limits, and provides mechanisms to handle responses and complaints.

Core Labor Standards

17. ADB adopted a commitment to core labor standards (CLS) as part of its Social Protection Strategy in 2001. Since then, ADB ensures that CLS are duly considered in the design and implementation of its investment projects. In this regards a handbook for CLS has been developed by ADB with cooperation of International Labor Organization (ILO). The objective is to convince decision makers that the introduction of CLS and labor standards in general will not impede development. The labor standards are simple the rules that govern how people are treated in a working environment. Labor standards cover a very wide variety of subjects, mainly concerning basic human rights at work, respect for safety and health and ensuring that people are paid for their work. CLS are a set of four internationally recognized basic rights and principles at work:

(i) Freedom of association and the effective recognition of the right to collective bargaining;

3 child labor means the employment of children whose age is below the statutory minimum age of employment in the relevant country, or employment of children in contravention of International Labor Organization Convention No. 138 ‘Minimum Age Convention” (www.ioo.org) 4 forced labor means all work or services not voluntarily performed, that is, extracted from individuals under threat of force or penalty

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(ii) Elimination of all forms of forced or compulsory labor; (iii) Effective abolition of child labor; and (iv) Elimination of discrimination in respect of employment and occupation.

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