Final Initial Environmental Examination IND: Gujarat Solar Power Project

Final Initial Environmental Examination

Project Number: 54035-001 July 2020

IND: Gujarat Solar Power Project

Prepared by AECOM India Private Limited for Electro Solaire Private Limited and the Asian Development Bank.

This initial environmental examination is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “Terms of Use” section of this website.

In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

Environment and Social Impact Assessment

200 MW Solar Power Project in Radhanesda Solar Power Park, Gujarat, India

Electro Solaire Private Limited

FINAL REPORT

29 July 2020

February 27, 2020 Rev 09: June 01, 2020

ESIA of 200 MW Solar Power Project

Quality information

Prepared by Checked by Verified by Approved by

Manish Pandya, Senior Poonam Singh, Senior Poonam Singh, Senior Chetan Zaveri, Executive Environment Consultant Environment Consultant Environment Consultant Director, Environment

Nishu Goel, Environment Consultant

Anil Ota, Senior Social Consultant

Barbara Lama, Social Consultant

Deepti Bapat, Senior Ecological Consultant

Revision History

Revision Revision date Details Authorized Name Position

09 1 June 2020 Addressal of Comments Yes Chetan Zaveri Executive Director, Environment

Distribution List

# Hard Copies PDF Required Association / Company Name

No Yes ESPL, ADB and SocGen

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ESIA of 200 MW Solar Power Project

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This document has been prepared by AECOM India Private Limited (“AECOM”) for sole use of our client (the “Client”) in accordance with generally accepted consultancy principles, the budget for fees and the terms of reference agreed between AECOM and the Client. Any information provided by third parties and referred to herein has not been checked or verified by AECOM, unless otherwise expressly stated in the document. No third party may rely upon this document without the prior and express written agreement of AECOM.

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ESIA of 200 MW Solar Power Project

Table of Contents

Executive Summary ...... 12 List of Abbreviations ...... 17 1. Introduction ...... 1-19 1.1 Project Background ...... 1-20 1.2 Purpose and Scope of Work ...... 1-20 1.3 Approach and Methodology ...... 1-21 1.3.1 Delineation of the Study Area/Area of Influence ...... 1-21 1.3.2 Desktop Review ...... 1-22 1.3.3 Screening and Scoping ...... 1-23 1.3.4 Stakeholder Identification and Analysis ...... 1-24 1.3.5 Site Survey ...... 1-24 1.3.6 Socio-Environment Baseline Data collection ...... 1-24 1.3.7 Stakeholder Consultation ...... 1-25 1.3.8 Impact Assessment ...... 1-25 1.3.9 Environment and Social Management Plan ...... 1-25 1.3.10 Agencies contacted ...... 1-25 1.4 Limitations ...... 1-25 1.5 Layout of Report ...... 1-25 2. Project Description ...... 2-27 2.1 Project Location ...... 2-27 2.2 Site Settings ...... 2-27 2.3 Project Overview ...... 30 2.3.1 Project Components ...... 30 2.3.1.1 DC Components ...... 31 2.3.1.2 AC Components ...... 32 2.3.1.3 Civil Structures ...... 32 2.3.1.4 Earthing ...... 33 2.3.1.5 Lighting and Over Voltage Protection ...... 33 2.3.1.6 Supervisory Control and Data Acquisition (SCADA) System ...... 33 2.3.2 Power Evacuation—Substation and Transmission Line ...... 33 2.3.3 Access Roads ...... 34 2.4 Status of the Project ...... 34 2.5 Resource Requirement and Procurement ...... 37 2.5.1 Land requirement and Procurement process ...... 37 2.5.1.1 Project-related land procurement and existing land procurement status ...... 37 2.5.1.2 Key Issues in Land Procurement ...... 38 2.5.2 Land procurement process ...... 38 2.5.3 Manpower requirement ...... 40 2.5.4 Water Requirement ...... 40 2.6 Waste Generation ...... 41 2.6.1 Waste Water ...... 41 2.6.2 Hazardous Waste ...... 41 2.6.3 Solid Waste ...... 41 2.7 Implementation Schedule ...... 41 2.7.1 Construction Activities ...... 41 2.7.2 Operation and Maintenance ...... 42 3. Environment and Social Regulatory Framework ...... 43 3.1 Terms of Reference ...... 43

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ESIA of 200 MW Solar Power Project

3.2 National and Regional Enforcement Authorities ...... 48 3.3 Applicable Environment and Social Laws and Regulations ...... 50 3.4 Policy Framework in India ...... 57 3.5 Applicable International Standards and Guidelines ...... 57 3.5.1 FMO Social Sustainability Policy ...... 57 3.5.2 IFC Performance Standards ...... 58 3.5.3 IFC EHS Guidelines ...... 60 3.5.4 Equator Principles, 2020 ...... 61 3.5.5 Applicability of ADB SPS ...... 63 3.5.6 Applicable International Conventions ...... 64 3.6 Categorisation of Project ...... 66 3.6.1 Classification as per MoEF&CC, India ...... 66 3.6.2 Classification as per IFC Performance Standards ...... 66 3.6.3 Project categorisation as per ADB SPS ...... 67 3.7 Applicable Environmental Standards ...... 68 3.7.1 Ambient Air Quality ...... 68 3.7.2 Ambient Noise Standards ...... 69 3.7.3 Noise Standards for Occupational Exposure ...... 69 3.7.4 Water Quality Standards ...... 70 4. Environmental and Socio-Economic Baseline ...... 71 4.1 Environmental Baseline ...... 71 4.1.1 Physiography ...... 73 4.1.2 Geology ...... 74 4.1.3 Drainage ...... 74 4.1.4 Land use and Land Cover ...... 77 4.1.5 Soil Types ...... 80 4.1.6 Hydrogeology ...... 80 4.1.7 Climate and Meteorology ...... 82 4.1.7.1 Rainfall ...... 83 4.1.7.2 Wind Speed ...... 83 4.1.8 Natural Hazards ...... 83 4.1.8.1 Wind Hazard ...... 83 4.1.8.2 Seismicity ...... 84 4.2 Air, Water, Noise and Soil Baseline ...... 85 4.2.1 Ambient Air Quality ...... 85 4.2.2 Ambient Noise Quality ...... 86 4.2.3 Water Quality ...... 87 4.2.4 Soil Environment ...... 88 4.2.5 Traffic ...... 91 4.3 Biodiversity profile ...... 93 4.3.1 Delineation of the Study Area ...... 93 4.3.2 Methodology ...... 93 4.3.2.1 Primary Data ...... 94 4.3.2.2 Secondary Data ...... 94 4.3.3 Species Profile of the Study Area ...... 94 4.3.3.1 Floristic Species ...... 95 4.3.3.2 Faunal Species ...... 99 4.3.3.3 Invasive Alien Species ...... 101 4.3.4 Habitat Profile of the Study Area ...... 101 4.3.4.1 Natural Habitats ...... 104

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ESIA of 200 MW Solar Power Project

4.3.4.2 Modified Habitats ...... 104 4.3.4.3 Critical Habitats ...... 105 4.3.5 Designated Areas ...... 109 4.3.5.1 Legally Protected Areas ...... 111 4.3.5.2 Internationally Recognized Areas ...... 111 4.3.6 Ecosystem Services ...... 111 4.4 Socio-economic Profile ...... 113 4.4.1 Socio-Economic Environment...... 113 4.4.2 Approach and Methodology ...... 113 4.4.3 Administrative Profile ...... 113 4.4.3.1 State profile: Gujarat ...... 113 4.4.3.2 District profile: Banaskantha ...... 114 4.4.3.3 Project Area ...... 114 4.4.3.4 Study Area ...... 114 4.4.4 Demographic profile of the Study Area ...... 115 4.4.4.1 Population level ...... 115 4.4.4.2 Social stratification: Vulnerable groups, SCs and STs ...... 115 4.4.4.3 Gender Profile ...... 116 4.4.5 Education level ...... 117 4.4.6 Occupation and Livelihood ...... 118 4.4.6.1 Land use pattern ...... 120 4.4.6.2 Irrigation ...... 120 4.4.6.3 Workforce Participation Rate ...... 121 4.4.7 Physical Infrastructure and Civic Amenities ...... 121 4.4.7.1 Health Profile and Infrastructure ...... 121 4.4.7.2 Drinking Water ...... 122 4.4.7.3 Sanitation ...... 122 4.4.7.4 Banks, Roads and Post Offices ...... 122 4.4.7.5 Electricity supply ...... 122 4.4.7.6 Cooking Fuel ...... 122 4.4.7.7 Religious Sites ...... 122 5. Stakeholder Engagement and Consultation ...... 124 5.1 Introduction ...... 124 5.2 Stakeholder Consultation and Disclosure Requirement for the project ...... 124 5.3 Stakeholder Categorisation ...... 125 5.4 Approach and Methodology of Stakeholder Analysis ...... 125 5.5 Stakeholder Analysis ...... 125 5.6 Stakeholder Consultations and Engagement ...... 134 5.6.1 Consultations with Mamlatdar (Magistrate Executive), Department of Revenue, Vav Tehsil. . 134 5.6.2 Consultations with Sarpanch (Village Head) of Radhanesda Village Panchayat ...... 135 5.6.3 Consultations with Sarpanch (Village Head) Kundaliya Village Panchayat ...... 138 5.6.4 Consultations with Opinion Leader of Kundaliya village ...... 141 5.6.5 Consultations with Principal/Teacher, Government Middle School, Radhanesda village, Vav Tehsil ...... 141 5.6.6 Consultations with Anganwadi Worker, Kundaliya Village, Vav Tehsil ...... 143 5.6.7 Consultations with Veterinary Officer, Vav Tehsil ...... 144 5.6.8 Focus Group Discussions with Rabari Community Members ...... 145 5.6.9 Consultations with the Gujarat Power Corporation Limited (GPCL) ...... 147 6. Analysis of Alternatives ...... 149 6.1 No Project Scenario ...... 149

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ESIA of 200 MW Solar Power Project

6.2 Alternate Location for Project ...... 150 6.3 Alternate Source of Power Generation ...... 150 6.4 Alternate Project Technology ...... 151 6.5 Alternate Transmission Line Route ...... 153 7. Impact Assessment ...... 154 7.1 Impact Assessment Criteria ...... 154 7.2 Impact Identification ...... 155 7.3 Environmental Impacts and Mitigation Measures ...... 157 7.3.1 Impacts during the Pre-construction and Construction Phase ...... 157 7.3.1.1 Ambient Air Quality ...... 157 7.3.1.2 Soil Quality ...... 158 7.3.1.3 Impact on Surface and Ground Water Quality ...... 158 7.3.1.4 Impact on Water Availability ...... 160 7.3.1.5 Ambient Noise Quality ...... 160 7.3.1.6 Solid and Hazardous Waste Management ...... 161 7.3.1.7 Traffic and Transport ...... 162 7.3.1.8 Occupational Health and Safety ...... 163 7.3.2 Impacts during Operation Phase ...... 165 7.3.2.1 Visual Impacts and Aesthetics ...... 165 7.3.2.2 Impact on Soil and Water Quality ...... 166 7.3.2.3 Impact on Water Availability ...... 167 7.3.2.4 Occupational Health and Safety of Workers ...... 168 7.3.3 Impacts during Decommissioning Phase ...... 169 7.3.3.1 Environment and Occupational Health & Safety ...... 169 7.3.3.2 Impact on Land Due to Improper Waste Disposal ...... 170 7.4 Ecological Impacts and Mitigation Measures ...... 171 7.4.1 Impacts during the Construction Phase ...... 172 7.4.2 Impacts during the Operation and Maintenance Phase ...... 174 7.4.3 Impacts during the Decommissioning Phase ...... 177 7.5 Socio- Economic Impacts and Mitigation Measures ...... 180 7.5.1 Impacts during the pre-construction phase ...... 180 7.5.1.1 Impact on animal grazing ...... 180 7.5.2 Impacts during the construction and operation phases ...... 180 7.5.2.1 Impacts on Local Economy ...... 180 7.5.2.2 Employment opportunities ...... 181 7.5.2.3 Labour Rights and Welfare ...... 181 7.5.2.4 Labour Influx ...... 181 7.5.3 Impacts during the decommissioning phase ...... 182 7.5.3.1 Loss of employment opportunities ...... 182 7.6 Impact of Climate Change on Solar PV Power Plant ...... 183 7.6.1 Anticipated Impacts ...... 183 7.6.1.1 Construction Phase ...... 183 7.6.1.2 Operational Phase ...... 185 7.6.1.3 Climate Transition Risk...... 186 7.7 Cumulative Impact Assessment ...... 188 7.7.1 Environmental Impacts ...... 188 7.7.2 Impacts on Biodiversity and Ecosystem Services ...... 189 7.7.2.1 Impact on Biodiversity ...... 189 7.7.2.2 Impact on Ecosystem Services ...... 189 7.7.3 Socio-economic Impacts ...... 189

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ESIA of 200 MW Solar Power Project

7.7.3.1 Impact on land ...... 189 7.7.3.2 Migrant Workers ...... 190 7.7.3.3 Impact on Infrastructure ...... 190 7.7.4 Conclusion ...... 190 8. Environment and Social Management Plan ...... 191 8.1 Introduction ...... 191 8.2 Organizational Structure (Environment, Social, Health and Safety) ...... 191 8.3 Roles and Responsibilities ...... 192 8.4 Inspection, Monitoring and Audit ...... 196 8.5 Documentation and Record Keeping ...... 196 8.6 Training ...... 197 8.7 Environment and Social Management Plan and Procedures ...... 198 8.7.1 Environment and Social Management Plan ...... 198 8.7.1.1 ESMP during Construction Phase ...... 198 8.7.1.2 ESMP during Operation Phase ...... 198 8.7.1.3 ESMP during Decommissioning Phase ...... 198 8.7.2 Waste Management Plan ...... 217 8.7.2.1 Waste Type and Quantity Generated ...... 217 8.7.2.2 Waste Management, Handling and Disposal ...... 218 8.7.3 Storm Water Management Plan ...... 218 8.7.4 Occupational Health and Safety Plan ...... 218 8.7.4.1 Risk Assessment ...... 219 8.7.4.2 Control Measures ...... 219 8.7.4.3 Training Requirements ...... 219 8.7.4.4 Documentation and Record Keeping ...... 220 8.7.5 Contract Worker Accommodation Plan ...... 220 8.7.5.1 Designed/ Construction standard ...... 221 8.7.5.2 Drinking water ...... 221 8.7.5.3 Toilet/ Washing/ Showering Facilities ...... 221 8.7.5.4 Hygiene and housekeeping ...... 222 8.7.5.5 First aid/ Medical facilities ...... 222 8.7.5.6 Audit and Inspection ...... 222 8.7.6 Traffic Management Plan ...... 222 8.7.6.1 Management Measures ...... 222 8.7.7 Grievance Redressal Mechanism ...... 223 8.7.7.1 Importance of Grievance Redressal Mechanism ...... 223 8.7.7.2 Stages of Grievance Redressal Mechanism ...... 223 8.7.7.3 Proposed Grievance Redressal Mechanism for ESIPL ...... 224 8.7.7.4 Functions of the Grievance Redressal Committee ...... 224 8.7.7.5 Stages of Grievance Redressal ...... 224 8.7.7.6 Engagement of Third Party ...... 225 8.7.7.7 Monitoring and Reporting ...... 226 8.7.8 Environment and Social Monitoring Plan ...... 226 8.7.8.1 Environmental Monitoring Plan ...... 226 8.7.8.2 Social and Health and Safety Monitoring Plan...... 227 8.7.8.3 Monitoring Plan during Decommissioning Phase ...... 227 8.7.9 Emergency Preparedness and Response Plan ...... 228 8.7.9.1 Responsibilities ...... 228 8.7.9.2 Identification of Emergencies...... 228 8.7.9.3 Declaration of Emergencies...... 229

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ESIA of 200 MW Solar Power Project

8.7.9.4 Emergency Equipment ...... 229 8.7.9.5 Coordination with External Agencies ...... 231 8.7.9.6 Emergency Response Team ...... 231 8.7.9.7 Emergency Response Procedure ...... 231 8.7.9.8 Reporting and Documentation ...... 232 9. Conclusions and Recommendations ...... 233 Appendix A Participant list of Stakeholder Consultations ...... 235 Appendix B Mammals of the Study Area ...... 236 Appendix C Resident Birds of the Study Area ...... 238 Appendix D Migratory Birds of the Study Area ...... 242 Appendix E Reptiles of the Study Area ...... 245 Appendix F Amphibians of the Study Area ...... 247 Appendix G Fishes of the Study Area...... 248 Appendix H Performance with respect to Equator Principles IV ...... 250 Compliance Assessment against Equator Principles IV: ...... 250 Environment and Social Action Plan (ESAP): ...... 256 Appendix I Environment and Social Action Plan (ESAP) prepared for ADB: ...... 258

Figures

Figure 1-1: Map showing physical features of the site and the area of influence ...... 1-22 Figure 2-1: Indicative location of Project site in Gujarat, India ...... 2-27 Figure 2-2: Map showing Project Location in Radhanesda Solar Park ...... 29 Figure 2-3: Overview of Solar PV Plant ...... 30 Figure 2-4: View of the project site ...... 35 Figure 2-5: Ground water at a depth of 1-2 m below ground at site ...... 35 Figure 2-6: View of the existing paved access road running parallel to site ...... 35 Figure 2-7: Limda Mata Ki Mandir under renovation at a distance of 1km from site ...... 35 Figure 2-8: Map showing the project location and external transmission line ...... 36 Figure 2-9. Land procurement/ allotment process ...... 39 Figure 4-1: Map showing Environment and Traffic Monitoring Locations ...... 72 Figure 4-2: Geological Map of Gujarat State ...... 74 Figure 4-3: Map representing Drainage within 5 km radius of site ...... 76 Figure 4-4: Map showing Landuse within 5 km radius of the Proposed Project site ...... 78 Figure 4-5: Map showing Land use of the Proposed Project site ...... 79 Figure 4-6: Soil Map of Gujarat State ...... 80 Figure 4-7: Hydrogeological map of Banaskantha district ...... 82 Figure 4-8: Wind Hazard map of Gujarat state ...... 84 Figure 4-9: Earthquake Hazard Map of Gujarat state ...... 85 Figure 4-10: Soil Texture Diagram ...... 90 Figure 4-11: Hourly Traffic Volumes at TM1 ...... 92 Figure 4-12: Biodiversity Sampling Sites in the Study Area ...... 94 Figure 4-13: Some Floristic Species recorded in the Study Area ...... 98 Figure 4-14: Habitat Profile of the Project Site ...... 102 Figure 4-15: Habitat Profile of the external Transmission Line Corridor ...... 103 Figure 4-16: The Central Asian Flyway ...... 107 Figure 4-17: Designated Areas around the Study Area ...... 110 Figure 7-1: Flood Scenario in Gujarat State ...... 184 Figure 8-1: Project organization structure ...... 192

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ESIA of 200 MW Solar Power Project

Tables

Table 2-1: Components of Solar PV Plant ...... 30 Table 2-2: Technical Details of PV Power Plant ...... 31 Table 3-1: Terms of Reference for the ESIA ...... 44 Table 3-2 Enforcement agencies relevant to the project ...... 48 Table 3-3: Applicable Environment and Social Laws and Regulations ...... 51 Table 3-4 National and State Level Policies Applicable to the Project ...... 57 Table 3-5 Applicability of IFC Performance Standards ...... 59 Table 3-6: Broad Overview ADB SPS and their applicability to the Project ...... 63 Table 4-1: Environmental Parameters Monitored for Baseline Data Collection ...... 71 Table 4-2: Environmental Monitoring Locations...... 73 Table 4-3: Landuse classification of Banaskantha district ...... 77 Table 4-4: Land use specific to Project Area and Site ...... 77 Table 4-5: Average Annual Rainfall (in mm) for Banaskantha District ...... 83 Table 4-6: Results of Ambient Air Monitoring ...... 86 Table 4-7: Results of Ambient Noise level Monitoring ...... 86 Table 4-8: Results of Ground Water and Surface Water Quality Analysis ...... 87 Table 4-9: Standard Soil Classification ...... 89 Table 4-10: Results of Soil quality analysis ...... 89 Table 4-11: PCU Factors adopted for Traffic Volume Survey ...... 91 Table 4-12: Hourly Traffic Volumes ...... 91 Table 4-13: Floristic Species recorded in the Study Area ...... 96 Table 4-14: Invasive Alien Species of Study Area ...... 101 Table 4-15: Critically Endangered and Endangered Species of the Study Area ...... 105 Table 4-16 Demographic Profile of State of Gujarat ...... 114 Table 4-17 Villages falling within five (05) kilometre radii...... 115 Table 4-18 Population Level ...... 115 Table 4-19 Presence of Vulnerable Sections of Community within the study area ...... 116 Table 4-20 Gender Profile of the Study Area ...... 117 Table 4-21 Literacy profile of Study Area ...... 117 Table 4-22 Occupational pattern in the Study Area ...... 119 Table 4-23 Land Use Pattern of Study Area ...... 120 Table 4-24 Irrigation Pattern in Study Area ...... 120 Table 4-25 Workforce Population in the Study Area ...... 121 Table 5-1 Overview of Disclosure and stakeholder consultation requirement ...... 124 Table 5-2 Stakeholder Group Categorisation ...... 125 Table 5-3: Stakeholder Significance and Engagement Requirement ...... 125 Table 5-4: Stakeholder Analysis ...... 127 Table 5-5 Summary of overall stakeholder influence ...... 134 Table 6-1: Anticipated Power Supply position of Gujarat in 2018-2019 ...... 149 Table 6-2: The levels of irradiance at the proposed Project Site (Month wise) ...... 149 Table 6-3 Comparative analysis of Various Power Generation Options ...... 151 Table 6-4: Characteristics of some PV Technology Classes ...... 152 Table 7-1: Impact Assessment Criteria ...... 154 Table 7-2: Impact Significance Matrix ...... 155 Table 7-3: Activity- Impact Interaction Matrix – Pre-Construction, Construction, Operation & Decommissioning Phase ...... 155 Table 7-4: Impact Significance – Ambient Air Quality ...... 158 Table 7-5: Impact Significance – Soil Quality ...... 158 Table 7-6 Impact Significance – Impact on Surface and Ground Water Quality ...... 159 Table 7-7: Impact Significance – Impact on Water Availability ...... 160 Table 7-8: Impact Significance – Ambient Noise Quality ...... 161 Table 7-9: Impact Significance – Waste Storage and Disposal ...... 162 Table 7-10 Impact Significance – Impact on Traffic and Transport ...... 163 Table 7-11: Impact Significance – Impact to Occupational Health and Safety of Workers...... 165 Table 7-12: Impact Significance – Aesthetic and Visual Impacts ...... 166 Table 7-13: Impact Significance – Impacts on Soil Quality ...... 167

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ESIA of 200 MW Solar Power Project

Table 7-14 Impact Significance – Surface Water Quality ...... 167 Table 7-15: Impact Significance – Impact on Water Availability ...... 167 Table 7-16: Impact Significance – Occupational Health and Safety of Workers ...... 169 Table 7-17: Impact Significance – Environment Occupational Health and Safety Hazards ...... 170 Table 7-18 Impact Significance – Impact on Land due to Improper Disposal of Waste ...... 171 Table 7-19: Impact Significance – Animal Grazing ...... 180 Table 7-20: Impact Significance – Local Economy ...... 180 Table 7-21: Impact Significance – Employment Opportunities ...... 181 Table 7-22: Impact Significance – Labour Rights and Welfare ...... 181 Table 7-23: Impact Significance – Employment opportunities ...... 182 Table 7-24: Impact Significance – Climate Change ...... 187 Table 7-25: Details of proposed solar projects near project site ...... 188 Table 8-1: ESMP during Pre-Construction Phase ...... 200 Table 8-2: ESMP during Construction Phase ...... 202 Table 8-3: ESMP during Operation Phase...... 209 Table 8-4: ESMP during Decommissioning Phase ...... 213 Table 8-5 Environmental Monitoring Plan ...... 226 Table 8-6 Social and Health and Safety Monitoring Plan ...... 227 Table 8-7 Codification of Siren ...... 230 Table 1: Gap Assessment for the Project against EP IV: ...... 251 Table 2: Environment and Social Action Plan (ESAP) ...... 256

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ESIA of 200 MW Solar Power Project

Executive Summary

Electro Solaire Private Limited (ESPL) has been selected for developing 200 MW solar power project after bidding by Gujarat Urja Vikas Nigam Limited for 700 MW grid connected Solar Photovoltaic Power Projects to be set up at Radhanesda Solar Park in Radhanesda village, Vav Taluka, Banaskantha district in the state of Gujarat (Phase III – R). Gujarat Power Corporation Limited (GPCL) has been appointed as a nodal agency for development of the 700 MW Ultra Mega Solar Power Park under the National Solar Mission by Ministry of New and Renewable Energy (MNRE).

Solairedirect Energy India Private Limited, the Indian subsidiary of Engie Solar India Private Limited has incorporated a Special Purpose Vehicle (SPV) namely M/s Electro Solaire Private Limited (hereinafter referred as ‘Client’/ESPL) for the development of the 200 MW project. The 200 MW solar power plant is proposed to be set up on 380 hectares (~938.06 acres) of land (two [02] land parcels of 190 hectares each) that has been leased by GUVNL for a period of 25 years to ESPL.

The ESIA has been undertaken as per requirements of International Finance Corporation (IFC) Sustainability Framework (Policy and Performance Standards on Environmental and Social Sustainability) 2012 and the associated World Bank Group Environmental Health and Safety Guidelines, ADB’s 2009 Safeguard Policy Statement (SPS), FMO's Social Sustainability Policy and Equator Principles IV (2020).

The overall area covered by the assessment includes the following constituent areas:

 The footprint of the project, hereafter referred to as the ‘Project Site’;  The area extending 5 km outward from the Project Site boundary (estimated to contain the potential receptors of any project-related environment, social and ecological impacts), hereafter referred to as the ‘Area of Influence’ or ‘AOI’; and  The alignment of the external transmission line, along with the area extending 500 m on either side of the alignment, hereafter collectively referred to as the ‘Transmission Corridor’.  The ‘Project Site’, the ‘AOI’ and the ‘Transmission Corridor’ are hereafter collectively referred to as the ‘Study Area’.

Project Description

The proposed project site is spread over an area of ~938.06 acres of land in the Radhanesda village of the state of Gujarat in India. The site can be accessed through State Highway (SH) 127 which passes through the village Kundaliya and connects to Radhanesda village at a distance of 8 km from the site. The road further connects to Limbidya village (Limbiya- Baet road) which is an existing government paved road (~3.5 m wide) and runs parallel towards north of the site.

ESPL is in the process of appointing a lump sum Turnkey contract with an Engineering, procurement and construction (Sub-contractor or EPC) contractor for development of this proposed project.

Power Evacuation

Power generated through PV modules will be stepped up to 33kV and will be pooled to main HT panel using breaker feeder. As per information provided by ESPL, a 33kV/220 kV internal common pooling substation (PSS) which will be constructed by GUVNL near the Project Site for all the Solar Power Developers in the Solar Park and the power will be further evacuated through a 400-kV transmission line of length ~35 km. The transmission line will be connected to the 400/200kV Banaskantha substation in Khimanavas village (Inter-Connection Point/Delivery Point), which is situated at a distance of 35 km from the project site. As per the information available, the transmission line corridor is currently under construction and is expected to be commissioned by March 2020.

Access road

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ESIA of 200 MW Solar Power Project

The site can be accessed through State Highway (SH) 127 which passes through village Kundaliya and connects Radhanesda village at a distance of 8 km from the site. The road further connects Limbidya village (Limbiya- Baet road) which is an existing government paved road (~3.5 m wide) and runs parallel towards the north of the site. The road leading to the site is an existing paved village road, and thus, no new road will be required to be developed for the project.

Land Requirement

The project land (380 hectares) allotted on lease basis for a period of 25 years to ESPL, is owned by the Gujarat Power Corporation Limited (GPCL). The said land does not include any private or forest land.

Project Activities

Construction Phase

Construction Labour: As informed, during the peak construction phase, 600-700 workers will be employed for a duration of 2-3 months. While most of the workers in the unskil led and semi-skilled categories will be hired from the neighbouring villages and from within the Banaskantha district, the manpower requirement in the skilled and highly skilled categories will be sourced from outside the state. Approximately 30% of the construction manpower will be migrant workers who will be provided accommodation in a labour camp proposed to be built at a distance of 1 km from the project site during the construction phase. Water requirement: it is estimated that water requirement for the construction phase will be 100 KL (Kilo litres) which includes water requirements for curing works, sprinkling and batching plant). The water will be sourced through a branch of the Sardar Sarovar Narmada Water canal located at a distance of 40 km from the Project Sit e. Reverse Osmosis (RO) treated packaged drinking water will be provided to the workers at site (~5000L/day) for peak construction period. One labour camp will be constructed, as reported.

Operation and Maintenance Phase

Water Requirement: During the operation phase, Reverse Osmosis (RO) treated packaged drinking water will be provided to the workers at site (~250L/day). Water for domestic requirement at the site will be ~1 KL and will be sourced through Narmada Canal.

As per the information provided by the Client, GPCL will construct a tank of 10 lakh litres capacity inside the solar park for meeting the water requirement for module cleaning for the entire solar park. Water for module cleaning will be sourced by GPCL through a branch of Narmada canal and will be stored in the tank to be constructed by GPCL for the entire solar park. Assuming a minimum of 2.5 litres of water per module, the water requirement for cleaning the whole plant (i.e. ~10 lakh modules) will be approximately 1,666 kilo litres, at one time. With a cleaning schedule of twice a month, it is estimated that approximately 3,332 kilo litres of water will be required for cleaning purpose on a monthly basis.

Analysis of Alternatives

The proposed project is an opportunity to utilize the solar potential of the state for power generation. A “No Project Scenario” will not address the issue of power shortage. An alternative without the project is undesirable, as it would worsen the power supply-demand scenario, which is expected to be a constraint on economic growth.

There are no fuel requirements or large quantities of water required for the operation of the plant. GHG emissions and other environmental pollution (stack emissions, ash management etc.) issues are also limited. Furthermore, there are minimal social issues associated with solar power projects.

The following additional criteria have been considered for site selection:

 The site is located away from major settlements;

 The site does not fall under any reserved or protected forests;  The land procured for the site mainly comprises of fallow land which is barren in nature and practically unusable for any other purpose; and  No environmentally sensitive features such as water bodies, forests, archaeological sites are located in the immediate site surroundings.

Environmental Baseline

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ESIA of 200 MW Solar Power Project

A study area of 5 km from the proposed project area was considered for the evaluation of environmental and social existing status and potential impacts.

Ambient Air Quality: All of the parameters measured for ambient air quality were noted to be well within the permissible limits of the National Ambient Air Quality Standards (NAQQS, 2009) for rural area, as defined by MoEF&CC at the sampled locations.

Ground Water quality: The results of ground water sample were compared with acceptable and permissible limits as specified in the drinking water standards - IS 10500:2012.The pH value of the sample was observed to be within the prescribed range, indicating neutral balance. The hardness and total dissolved solids (TDS) value in the groundwater sample exceeds the permissible limit. Chemical parameters such as chloride and magnesium were noted to be exceeding the permissible limit. Calcium was noted to be exceeding the acceptable limit but is within the permissible limit. Other heavy metal parameters such as Selenium, barium, Fluoride, boron were detected in the groundwater sample but were noted to be within acceptable limit. The groundwater sample does not show the presence of faecal coliforms implying that there is no faecal contamination in the groundwater. All other parameters were observed to be within the acceptable limits as specified in the drinking water standard of IS 10500:2012. It can be inferred from the water quality that groundwater contains high number of dissolved solids and has high hardness and thus is not completely fit for human consumption prior to conventional treatment.

Ambient Noise quality: The ambient noise level at location NQ 1 (near the site boundary) was noted to be exceeding the permissible standards of noise levels prescribed by CPCB for day time and night time i.e., National Ambient Air Quality Standards (NAAQS) in respect of noise limits for day time and night time for residential area. The high noise level can be attributed to vehicular movements, ground levelling work being undertaken nearby the site and high wind movement on the day of monitoring. Ambient noise level at NQ 2 (Radhanesda village road) was noted to be within permissible limits for the day time. However, noise levels were noted to be exceeding slightly above the permissible limits for night time. The ambient noise level at location NQ 3 (empty land parcels near the site) was noted to be exceeding the permissible standards for day time whereas the night time levels were within the permissible limits for noise level. The high noise levels at NQ 2 and NQ 3 can be attributed mainly to the high wind velocity on the day of monitoring and some construction activities being undertaken in the area in and around the Project Site (construction of the boundary wall, shops in the near vicinity, etc.).

Soil Quality: The pH values of the soil samples at the project site (SQ1) and around the site (SQ2) indicate normal to slightly saline soil conditions. Electrical conductivity of soil samples indicate that soil at the project site (SQ1) is injurious to most crops and thus indicates high salinity of soil and the soil around the project site falls under Normal category. The relatively high Sodium concentration in Soil sample at the project site indicates highly sodic soil and indicates that the soil has poor soil structure with low infiltration rate and aeration and thus the soil is not suitable for cultivation of many crops. Iron content in the soil samples were noted to be high. Heavy metals such as chromium, cadmium, Mercury were not detected in the soil samples. Whereas other heavy metals such as lead, nickel and arsenic were observed in the soil samples. The texture of soil sample SQ 1, i.e. the soil at the Project site is “Sandy Loam”, and the texture of soil sample SQ 2 (around the Project site) is “Sandy”.

Traffic Analysis: Out of the total traffic at the Village road, maximum influx and outflux was observed for light vehicles (four wheelers) such as cars, vans (48%), followed by two wheelers (26%). This is followed by Six Wheelers/Heavy Vehicles such as Light Commercial vehicles, Trucks and Buses etc. (24%). Further, cycles amounted for less than 1% of the traffic at the road.

Socio-Economic Baseline

The project area is in Radhanesda village, Vav Tehsil in District of Banas kantha. The project area is spread over 938.06 acres in Radhanesda Village. Radhanesda village falls under the jurisdiction of Radhanesda Village Panchayat. The study area has been further divided into direct impact area (the area where the project will be located) and indirect impact area (within 05 km of the project area). Kundaliya village falls within the 5-kilometre radii of the project.

Biodiversity Baseline:

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ESIA of 200 MW Solar Power Project

The Study Area, which includes the estimated areas of influence of both, the Project and its shared facilities, represents a part of the north-eastern fringe of the Little Rann of Kutch. The natural vegetation of the Study Area represents desert thorn scrub forest-type typical to semi-arid tracts of north-western India, including unique edaphic forms, such as Rann Saline Thorn Scrub and Salvadora Scrub. The habitat profile of the Study Area consists of a mosaic of near-natural to slightly modified habitats, with the Project Site containing mainly near- natural habitats, such as saline flats, grassland and scrub, while the Transmission Line Corridor contains mainly modified habitats, such as cultivated or fallow farmland, but also a few natural wetlands. The floristic and faunal profiles of the Study Area are characterized by habitat-specialist species of thorny scrub and wetlands. There is considerable presence of the invasive alien species Prosopis juliflora, throughout the Study Area. At least three (3) designated areas are situated in the vicinity of the Study Area, at distances of 1.5 km to 17 km from the corresponding nearest point on the boundary of the Study Area. The Study Area is situated within the Central Asian Flyway and in proximity to the East Asia – East Africa Flyway. A critical habitat assessment, involving focused monitoring of the Study Area for identified critical habitat trigger species, has concluded that it is improbable that the Project Site represents critical habitat with respect to the concerned species. The Study Area provides priority provisioning ecosystem services to the local pastoral community in terms of fodder for livestock.

Stakeholder Engagement

 Interaction with relevant government stakeholders GPCL, GUVNL, GEDA officials, Revenue officer of Vav Tehsil, Veterinary Officer of Vav Tehsil as well as Village Panchayat (Local Government) heads of Kundaliya and Radhanesda villages were undertaken;  Consultations with opinion leaders (leader, principal/teacher of Government School, Radhanesda village) was undertaken;  Focus Group Discussions with the community members of Radhanesda and Kundaliya villages were undertaken; and  Consultations with members of Rabari Community (OBC) a pastoral nomadic community was also undertaken.

Environmental and Social Impacts

The Project is a renewable energy project which uses solar energy for power generation. Renewable energy projects are considered to be cleaner compared to fossil fuel-based energy projects. The anticipated impacts during the construction, operation and decommissioning phases and after mitigation have been summarized in the Table below:

Impact Description Significant of Overall Impact Impact Nature Impact after mitigation

Pre-construction and Construction Phase

Ambient Air Quality Negative Moderate Minor

Soil Quality Negative Moderate Minor

Ambient Noise Quality Negative Moderate Minor

Water resources Quality Negative Moderate Minor

Solid and Hazardous Waste Management Negative Moderate Minor

Impact on Traffic and Transport Negative Moderate Minor

Impact to Occupational Health and Safety of Workers Negative Moderate Minor

Biodiversity and Ecosystem Services (Project) Negative Moderate Minor

Biodiversity and Ecosystem Services (Transmission Line) Negative Moderate Minor

Operational Phase

Aesthetic and Visual Impacts Negative Minor Minor

Soil Quality Negative Moderate Insignificant

Water Availability Negative Major Moderate

Occupational Health and Safety Hazards Impact Negative Moderate Minor

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ESIA of 200 MW Solar Power Project

Impact Description Significant of Overall Impact Impact Nature Impact after mitigation

Biodiversity and Ecosystem Services (Project) Negative Moderate Minor

Biodiversity and Ecosystem Services (Transmission Line) Negative Major Moderate

Employment Opportunities Negative Minor Moderate

Impact on local economy Positive Minor Moderate

Labour Rights and Welfare Positive Moderate Minor

Decommissioning Phase

Environment and Occupational Health and Safety Impact Negative Moderate Minor

Impact on Land Due to Improper Waste Disposal Negative Major Moderate

Biodiversity and Ecosystem Services (Project) Negative Moderate Minor

Biodiversity and Ecosystem Services (Transmission Line) Negative Moderate Minor

Employment Opportunities Negative Moderate Minor

Based on the above impact assessment matrix, impacts due to Project and transmission line has been identified and all the impacts identified can be managed through mitigation measures. Mitigation measures for each identified impact have been provided, along with the overall significance of the impact, before and after application of the mitigation measures.

An Environmental and Social Management and Monitoring Plan (ESMMP) has been developed to ensure that social and environmental impacts, risks and liabilities identified during the ESIA process are effectively managed during the operation and closure of the proposed project. The ESMP delineates the monitoring and management measures to avoid and/or minimize the identified impacts by allocating management responsibility and suggesting skill requirement for implementation of these measures.

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ESIA of 200 MW Solar Power Project

List of Abbreviations

SNo. Abbreviation Extension

1. AECOM AECOM India Private Limited

2. AC Alternate Current

3. AAQ Ambient Air Quality

4. AoI Area of Influence

5. CGWA Central Ground Water Authority

6. CPCB Central Pollution Control Board

7. CPR Common Property Resource

8. CTE Consent to Establish

9. CTO Consent to Operate

10. CSR Corporate Social Responsibility

11. CR Critically Endangered

12. DPR Detailed Project Report

13. DG Diesel Generator

14. DC Direct Current

15. ESPL Electro Solaire Private Limited

16. ERT Emergency Response Team

17. EN Endangered

18. EPC Engineering, Procurement and Construction

19. EPA Environment (Protection) Act, 1986

20. EAP Environment Action Plan

21. ESIA Environment and Social Impact Assessment

22. ESMP Environment and Social Management Plan

23. ESMS Environment and Social Management System

24. EMS Environment Management System

25. EHS Environment, Health and Safety

26. FGD Focus Group Discussions

27. GoG Government of Gujarat

28. GP Gram Panchayat

29. GHG Green House Gases

30. GSS Grid Sub -Station

31. GRM Grievance Redress Mechanism

32. GPCB Gujarat Pollution Control Board

33. GPCL Gujarat Power Corporation Limited

34. GUVNL Gujarat Urja Vikas Nigam Limited

35. HSE Health, Safety and Environment

36. ISA Implementation and Support Agreement

37. IMD Indian Meteorological Department

38. IP Indigenous People

39. IFC International Finance Corporation

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40. IUCN International Union for Nature and Natural Resources

41. MW Mega Watt

42. MoEF&CC Ministry of Environment, Forest and Climate Change

43. MNRE Ministry of New and Renewable Energy

44. NOC No Objection Certificate

45. O&M Operations and Maintenance

46. PRI Panchayati Raj Institution

47. PPE Personal Protective Equipment

48. PV Photo Voltaic

49. PUC Pollution Under Control

50. PSS Pooling Sub-station

51. PPA Power Purchase Agreement

52. PIC Prior Informed Consent

53. SC Scheduled Caste

54. ST Scheduled Tribe

55. SPPD Solar Power Park Developer

56. SPV Special Purpose Vehicle

57. TL Transmission Line

58. VU Vulnerable

59. WMP Waste Management Plan

60. WPA Wildlife Protection Act

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ESIA of 200 MW Solar Power Project

1. Introduction

Government of Gujarat vide resolution (G.R. No. SLR – 11-2015-2442 B) dated 13 August 2015, has notified the Gujarat Solar Power Policy 2015 which shall remain operational for the period up to 31 March 2021. The Gujarat Solar Power Policy 2015 stipulates that the obligated entities may purchase solar power to fulfil their renewable purchase obligation (RPO) at the tariff determined through competitive bidding. Subsequently, the Ministry of Power, vide Resolution (No. 23/27/2017 – R&R) dated 03 August 2017 notified the Guidelines for Tariff Based Competitive Bidding Process for Procurement of Power from grid connected Solar Photo Voltaic (PV) Power Projects.

Based on the above, Gujarat Urja Vikas Nigam Limited (GUVNL), vide request for selection (RFS) [No. GUVNL/700 MW/Solar (Phase III-R)] dated 06 March 2019, had floated tender for purchase of power through Competitive Bidding Process (followed by reverse e-auction) from 700 MW grid connected Solar Photovoltaic Power Projects to be set up at Radhanesda Solar Park in Gujarat (Phase III – R). The Radhanesda Solar Park/Radhanesda Ultra Mega Solar Park is located at Radhnesada village, Taluka Vav, Banaskantha district in the state of Gujarat. After successful bidders were announced for development of Solar Power Projects in the Radhanesda Solar Park, Government of Gujarat (GoG) appointed as a nodal agency for development of the 700 MW Ultra Mega Solar Power Project in the Radhanesda Solar Park under the National Solar Mission by Ministry of New and Renewable Energy (MNRE) vide its guidelines for Development of Solar Parks issued in June 2015 and its amendments thereon. GPCL has thus been designated as Solar Power Park Developer (SPPD)/ Solar Park Implementing Agency (SPIA) by Government of Gujarat. The entire solar park has been divided into seven (07) number of plots of 190 hectares each which has been allotted to different power producers by GPCL.

Engie is one of the largest solar power producing companies in France and Belgium. As of April 2018, the company has commissioned 1,849 MW of solar power across India, China and Thailand in Asia; Italy, Czech Republic, Netherlands, United Kingdom, Belgium, France and Spain in Europe; Brazil, Chile, Peru and Panama in South America; the United States of America and Canada in North America; South Africa in Africa and New Caledonia, Wallis and Futuna and Vanuatu in Oceania.

In 2015, Engie acquired 95% stake in Solaire Direct (now, Engie Solar SAS, France), a Europe based company which develops, installs and operates a broad array of solar photovoltaic (“PV”) power plants ranging from 1.5 kWp to tens of MWp in capacity. The Indian arm of Engie Solar SAS, France named as Solairedirect Energy India Private Limited was incorporated in 2010 with the primary objective to tap the solar power potential in the Indian market. Solairedirect Energy India Private Limited is amongst the leading solar power developers in India with platform of about 462 MWp under operation and construction.1

For the purpose of executing the 200 MW Radhanesda Solar Power Project, Solairedirect Energy India Private Limited incorporated a Special Purpose Vehicle (SPV) namely M/s Electro Solaire Private Limited (hereinafter referred as ‘Client’/ESPL). ESPL has been declared as one of the successful bidders, pursuant to Letter of Award (LoA) dated 28 May 2019 for development of Solar Power Project of 200 MW capacity (100 MW X 2 plots) and sale of entire of electrical energy, so produced, for commercial purposes from such power plant to GUVNL. The Power Purchase Agreement (PPA) was signed between ESPL and GUVNL on 26 August 2019 for a period of twenty-five (25) years. ESPL has been allotted Plot D (100 MW) and Plot E (100 MW) for development of solar plants within the Radhanesda Solar Park at Radhanesda village, Taluka Vav, Banaskantha district in the state of Gujarat (hereafter referred to as the “Site” or “Project Site”).

The 200 MW solar power plant (also referred to as the solar power project) in Gujarat is proposed to be set up on 380 hectares (~938.06 acres) of land (two [2] land parcels of 190 hectares each) that has been leased by GUVNL for a period of 25 years to ESPL through a competitive bidding in March 2019.

As per the Implementation and Support Agreement (ISA) for Grid Connected Solar Photo Voltaic Projects in Radhanesda Ultra Mega Solar Park (700 MW) signed between GPCL and ESPL dated 22 October 2019, GPCL will identify and acquire the land required for setting the power plant, obtain necessary permits and clearances

1 Detailed Project Report (DPR) for Development of 200 MW Solar Power Project at Radhanseda Ultra Solar Park, Banaskantha Gujarat (December 2019).

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ESIA of 200 MW Solar Power Project

required for development and will develop various infrastructure like internal transmission system, water supply, road connectivity, drainage system etc. for the solar power project.

AECOM India Private Limited (hereinafter referred to as ‘AECOM’) has been appointed by ESPL to undertake the ESIA study to evaluate environment and social risks and impacts associated with the Project. The ESIA study comprised of a reconnaissance survey, baseline environmental monitoring, primary ecological survey, data analysis and consultations and discussions with relevant stakeholders. 1.1 Project Background ESPL intends to develop a 200 MW capacity solar power project in Radhanesda village, Vav Taluka, Banaskantha district in the state of Gujarat, India (hereinafter referred as ‘Project’).

The project will be based on Solar Photo Voltaic technology using Multi/Poly Crystalline Silicon PV modules for power generation. The 200 MW solar power plant in Gujarat is proposed to be set up on 380 hectares (~938.06 acres) of land (two land parcels of 190 hectares each) that has been leased by GUVNL for a period of 25 years to ESPL.

A solar power plant is a cleaner option for power generation in comparison to non-renewable fossil fuels. Ministry of Environment, Forest and Climate Change (MoEF&CC) in its Office Memorandum No. J-11013/41/2006-IA-II (I) dated 13 May 2011 (as provided in Appendix A) stated that the solar power projects are not covered under the ambit of Environmental Impact Assessment (EIA) Notification, 2006 and therefore does not require prior environmental clearance (EC).

ESPL is in the process of signing a lump sum Turnkey contract with an engineering, procurement and construction (hereafter referred as EPC or ‘Sub-contractor’) contractor for development of the proposed project. The Sub-contractor will be responsible for installation of solar panels, construction of transformers in existing pooling substation and laying of transmission line. Post construction, an operation and maintenance (O&M) contractor for the project will be appointed by ESPL.

The power generated through the project will be fed to the common internal Pooling Substation (PSS), to be set up for all power developers (who would be operating in the Radhanesda Solar Park), which will be constructed by GUVNL near the Project Site and power will be further evacuated through a 400-kV transmission line of ~35 km length. As per the information available, the transmission line corridor is currently under-construction. The transmission line will be connected to the 400/200kV Banaskantha substation in Khimanavas village, which is currently under-construction and is expected to be commissioned by March 2020. 1.2 Purpose and Scope of Work The main purpose of the ESIA study is to identify, evaluate and manage environmental and social impacts that may arise during the development and operation of the project. This study is being undertaken as per the requirements of the IFC Performance Standards (PS) 2012, ADB Safeguard Policy Statement 2009 (SPS) and other lenders (as shared in the Terms of Reference – ToR), to understand the environmental and social compliance of the Project vis-à-vis the reference framework. The objectives of the ESIA study have been detailed below:

 Reconnaissance survey and primary site assessment to collect and review baseline environmental and social conditions;  Collection of additional secondary environmental, social and demographic information;

 Identification and review of the applicable environment and social standards and identification of key issues;  Assessment of potential environment and social impacts of the project and its components;

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ESIA of 200 MW Solar Power Project

 Undertaking cumulative environmental and social impacts assessment from other existing, planned or reasonably defined developments;  Identifying key stakeholders and undertaking stakeholder consultations to assess the influence and impact of the proposed project on them;  Suggesting mitigation measures and plans to maximize project benefits in consultation with affected communities;  Preparing an ESIA Report encompassing all components of the baseline study, impacts assessed, documented consultations undertaken and management plans to mitigate the impacts assessed; and  Developing an Environmental and Social Management Plan (ESMP) based on the impacts identified including monitoring aspects of the mitigation measures suggested. 1.3 Approach and Methodology The approach and methodology applied for the execution of the impact assessment study is as provided:

 The relevant project documents and detailed project report were reviewed to understand the project requirements;  Regulatory review was undertaken to understand the applicable, local and national legislation and regulatory frameworks;  A detailed social and environmental assessment of the site and surrounding areas was undertaken through the following: ─ Reconnaissance surveys to understand site specific issues; ─ Discussions with the local community and identification of key issues; ─ Collation of secondary information on social aspects of the site, supplemented by consultations with the local communities to understand community perception with regard to the project and its activities; ─ Stakeholder mapping and Identification;

─ Focused group consultations with selected land losers and other impacted groups; ─ Field surveys and data compilation; ─ Group/Community Consultations: Group meetings and consultations with local and community representatives; and  Assessment of impacts based on understanding of the project activities and existing baseline status;  Preparation of an Environment and Social Management Plan (ESMP).

1.3.1 Delineation of the Study Area/Area of Influence A case study approach was adopted to understand the various criteria for delineation of the study area or area of influence. IFC categorises the project primarily according to the significance and nature of its impacts. IFC defines the project's area of influence as the primary project site(s) and related facilities that the client (including its contractors) develops or controls; shared facilities that are not funded as part of the project (funding may be provided separately by a client or a third party including the government), and whose viability and existence depend exclusively on the project and whose goods or services are essential for the successful operation of the project; areas potentially impacted by cumulative impacts from further planned development of the project and areas potentially affected by impacts from unplanned but predictable developments caused by the project that may occur later or at a different location. The area of influence does not include potential impacts that would occur without the project or independent of the project.

IFC Sustainability Framework and Performance Standards (PS), World Bank EHS Guidelines and sector-specific (as applicable) environmental, health and safety guidelines as well as national regulatory requirements suggest that primary baseline data is to be collected so that it reflects the pollutants of concern associated with project processes. Since the proposed project is a renewable energy project and is located in the barren region of Radhanesda village, Banaskantha district in Gujarat and is devoid of much habitation, industrial activity or other

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ESIA of 200 MW Solar Power Project

pollution sources, hence, primary impacts from the proposed solar power project have been assessed in and around a radius of 2 kilometres (km) around the Project Site and secondary impacts have been assessed in and around a radius of 5 km around the Project Site.

Therefore, for the purpose of the ESIA study, an area of 5 km (aerial distance) radius has been considered as the Area of Influence (AoI) for identification and assessment of potential environmental and social impacts around the proposed project.

 Direct Impact Zone (Core Components): The area covering the Project Site, internal transmission line corridor and direct access road to the project is designated as the area under the direct influence of the project for environmental, ecological and social impacts.

 Indirect Impact Zone (Shared Facilities): Area outside the direct impact zone of the project, up to a radius of 5 km, is considered as the indirect influence zone for the project for environmental, ecological and social impacts. All the baseline environmental profiling, including environmental monitoring, socio-economic studies and public consultations, have been carried out within the AoI of 5 km.

In order to include the farthest anticipated direct receptors of biodiversity-related impacts, AoI for the biodiversity studies was delineated as the proposed Project Site, along with the area extending outward up to a radius of 5 km from the Project Site boundary. The map showing the physical features of the Project Site is provided below in Figure 1-1.

Figure 1-1: Map showing physical features of the site and the area of influence

1.3.2 Desktop Review AECOM carried out a desk-based review of the information shared by the client prior to mobilizing for the site visit for undertaking the Impact assessment. As part of the review, the proposed project area was screened using Google Earth. Based on the review of satellite imagery, the environmental and social sensitivities to be covered as part of the site visit were assessed and subsequently scoped in.

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ESIA of 200 MW Solar Power Project

The desk-based review was primarily focussed on but was not limited to the following documents:

 Detailed project report (DPR);

 Site layout plan;  Evacuation Approval;  Power purchase agreement (PPA);  Solar radiation report;

 Various land related documents;  Organizational chart; and  Other Project related documents.

1.3.3 Screening and Scoping At the initial stage of the impact assessment, a preliminary level screening and scoping assessment of the project and its components, including an appraisal of the higher-level environment and social (E&S) risks, screening of the project site and shared facilities (including the access roads, transmission lines, substation, sources of raw material etc.) was undertaken. The screening and scoping study was conducted to identify the likely impacts that the development of the project will have on environment, biodiversity and social conditions in the AoI, to establish an understanding of the various linkages between the lifecycle phases of the project and the associated environmental, social and ecological aspects and development of the activity-impact matrix for the project, to identify the various stakeholders to be consulted for the ESIA study and develop a forward-going approach and methodology to be adopted including E&S baseline development, stakeholder engagement, impact assessment and development of the Environment and Social Management Plan (ESMP).

The screening and scoping assessment was undertaken based on the understanding of the objective and scope of work and AECOM’s experience of working on renewable energy projects, especially the solar energy sector.

The AECOM team, comprising of one (1) EHS expert, one (1) Social expert and one (1) bio-diversity expert undertook a site visit to the project location between 30 - 31 October 2019 and 04-07 November 2019. As part of the site visit, the following key activities were undertaken:

 Meeting with the on-site project representative;  Site walk through the two land parcels (measuring 190 hectares each) purchased/ earmarked for the project;  Site walk through the proposed site for the Pooling Substation (PSS) of the solar power park;  Visit to the under-construction 400/220 kV Banaskantha Grid Substation (GSS) to which power from the project as well as other players operating in the power plant would be evacuated. The proposed GSS is located at a distance of 35 kms from the power park in Khimanavas village;  Consultations with members of local communities from the Radhanesda village;  Consultations with the local Sarpanch;

 Consultations with the Gujarat Power Development Corporation;  Preliminary biodiversity screening for the presence of critical habitats (CH); and  Photo documentation of the existing land use, structures close to the site, access roads, village structures etc. The critical habitat screening (undertaken as part of the E&S Scoping) indicated that the Study Area (including the Project Site) is part of the reported ranges of certain potential CH trigger species, as defined by IFC PS 6. Thereafter, a Critical Habitat Assessment (CHA) to assess the area coinciding with the proposed Project Site, as well as, the areas coinciding with the shared facilities of the Project, namely the pooling sub-station, the external transmission line corridor and the main sub-station, for the presence of Critical Habitat (hereafter referred to as ‘CH’), as defined by the applicable reference frameworks, namely the IFC Performance Standard 6 (PS6), 2012 and the ADB Safeguard Policy Statement (SPS), 2009 was undertaken.

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ESIA of 200 MW Solar Power Project

The relevant preliminary findings of the CHA study are reported as part of the biodiversity baseline of the ESIA report.

1.3.4 Stakeholder Identification and Analysis On the basis of the understanding developed in the initial stages, the potential stakeholders for the project were identified and the individual concerns, expectations and influences of the stakeholders on the project were identified. The purpose of such an understanding was to allow for a proper assessment and mitigation of the impacts. On the basis of this understanding, an exercise of stakeholder mapping was undertaking, the purpose of which was to:

 Identify each stakeholder group;  Study their profile and nature of stakes;  Understand each groups’ specific issues, concerns and expectations from projects in the area; and

 Gauge their influence on the project.

1.3.5 Site Survey AECOM team conducted a site survey in two phases i.e. from the 1-3 January and 7-10 January 2020. The following activities were undertaken during this visit:

 Undertake environmental assessments to gain an understanding of the following and consultations with site representatives: ─ Site setting assessment of 5 km study area for the project site; ─ Site setting assessment of transmission line corridor; ─ Study of key environmental receptors such as large water bodies, forest area, man-made sensitivities such as schools, colleges, hospitals etc.  Undertake environmental monitoring and collection of baseline environmental data;  Undertake social assessments and consultations in the form of individual interviews and focussed group discussions (FGDs) with the following key stakeholder groups: ─ Local stakeholders; and

─ Institutional stakeholders/government departments.  Undertake biodiversity assessment including collection of biodiversity baseline data and key stakeholder consultations (Forest department, local community, etc.).

1.3.6 Socio-Environment Baseline Data collection Environmental baseline data was collected through primary monitoring and reconnaissance surveys of the study area (5 km distance around the project site). Secondary information through literature surveys was also collected for the study area. The baseline study included the following:

 Primary environmental baseline data collection within the study area. The primary environmental and social baseline data was collected with respect to ground water, ambient air quality (AAQ), ambient noise level, soil quality, traffic survey and socio-economics profile. The ecology and biodiversity data were also collected as part of the primary data collection;  The GIS mapping of the study area was done to present details on land use pattern, forest/ vegetation cover, settlements, water bodies, drainage pattern, spot heights and contours; and  Information on geology, meteorological conditions, water and ecological resources, socio-economic status etc. was collected from secondary sources.

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ESIA of 200 MW Solar Power Project

1.3.7 Stakeholder Consultation During the site visit for ESIA, following groups of stakeholders were consulted with the objective of collecting baseline data/information and to understand concerned issues:

 Institutional Stakeholders: Representative of GPCL, Mamlatdar (Magistrate Executive) of Vav tehsil, Veterinary officer of Vav tehsil were consulted;

 Local communities: Consultations with village heads (Sarpanch) of Kundaliya and Radhanesda village, Opinion leaders of the Kundaliya and Radhanesda village and Anganwadi worker of Kundaliya village were consulted; and

 ESPL site representative: Consultations were undertaken with the ESPL site team during visit.

1.3.8 Impact Assessment Impact identification and prediction are undertaken on the basis of environmental and social baseline data collected. The major processes involved are:

 Identification – to define the impacts associated with different phases of the project and the activities undertaken;  Prediction – to forecast the nature, magnitude, type, duration, extent, scale, frequency likelihood and sensitivity of the major impacts identified; and  Evaluation – to determine the significance of residual impacts i.e. taking into account how mitigation will reduce a predicted impact. Professional judgement, experience and knowledge of similar projects were used for impact analysis. The extent and potential consequences of the impacts have been compared against applicable reference framework. Mitigation measures have been suggested for each of the identified adverse impacts.

1.3.9 Environment and Social Management Plan This section delineates the roles and responsibility and timeline for implementing mitigation measures to prevent the significant impacts arising from activities during different phases of the project.

1.3.10 Agencies contacted The agencies consulted by AECOM team during the ESIA study include the following:

 Tehsil Revenue Department, Vav;

 GPCL, Gandhinagar;  Animal Husbandry department, Vav;  Office of the Deputy Conservator of Forest (DCF), Wild Ass Sanctuary, Dhrangadhra  Range Forest Office, Tharad; and

 Divisional Forest Office, Palanpur. 1.4 Limitations The ESIA study of the project is limited to project information made available by the client, discussion with ESPL representative, primary monitoring, secondary data collected, consultation with local community and observations made during site survey. Professional judgement and interpretation of facts has been applied for presenting inference from the collected information. 1.5 Layout of Report The current ESIA Report has been arranged under the following chapters:

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ESIA of 200 MW Solar Power Project

1. Chapter One: Introduction (This chapter provides a background of the project and the current Report, the objectives with which the study has been undertaken, the scope of work, etc.)

2. Chapter Two: Project description (This chapter provides details of the project location, key project components and utilities, land requirements, power purchase agreement, current project status, etc.)

3. Chapter Three: Environment and Social Regulatory framework (This chapter encompasses the national administrative requirements, applicable permits, licences, approvals and consents and project categorisation as per Reference Framework)

4. Chapter Four: Environmental and socio-economic baseline (This chapter illustrates the environmental baseline, socio-economic baseline and Ecology baseline)

5. Chapter Five: Analysis of alternatives (This section presents the analysis of alternatives for the proposed solar project)

6. Chapter Six: Impact Assessment (This chapter highlights the impact assessment criteria, key environmental risks and key social risks)

7. Chapter Seven: Environment and Social Management Plan (This chapter highlights the organization structure, training, Inspection monitoring and audit and Documents and record keeping)

8. Chapter Eight: Conclusion and Recommendations

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ESIA of 200 MW Solar Power Project

2. Project Description 2.1 Project Location The proposed Project Site is located in Radhanesda Ultra-Mega Solar Park (700 MW) situated in Radhanesda village, Vav Taluka, Banskantha district in the state of Gujarat, India. The site can be accessed through State Highway (SH) 127 which passes through the village Kundaliya and connects to Radhanesda village at a distance of 8 km from the site. The road further connects to Limbidya village (Limbiya- Baet road) which is an existing government paved road (~3.5 m wide) and runs parallel towards north of the site. The Site is situated at a level of ~3 m below the access road. Ahmedabad airport is the nearest airport to the site at a distance of 271 km towards northwest of the site. Radhanesda village is the nearest habitation to the site at a distance of ~4 km. International border with Pakistan is at a distance of about 28 km from the site. There is no solar power plant or any industry within 5 km radius of the project site.

The Indicative proposed project site location has been depicted in the Figure 2-1 below.

Figure 2-1: Indicative location of Project site in Gujarat, India

2.2 Site Settings The Project Site comprises of two (2) adjoining plots i.e. Plot D and Plot E, each measuring 190 hectares (~469.03 acres) and is located in the south western portion of the Radhanesda Solar Park. Towards north west of the Site is the land parcel measuring 68 hectares (167.96 acres), which has been designated for grazing purposes by the Government of Gujarat and the proposed Pooling Substation (PSS), to be constructed by GUVNL. The Southern boundary of the Site is also the boundary of the solar park towards that side. The Project

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ESIA of 200 MW Solar Power Project

Site is surrounded by other solar power developers towards the east and west side. The PSS, to be constructed in the northern portion of the solar park, will cater to all the power developers operating within the Radhanesda solar power park. The site is generally flat and is situated at an elevation of 6 m above mean sea level. The entire land parcel comprising the Radhanesda Solar Power Park (including the Project Site) is owned by the Government of Gujarat (GoG) and does not involve any private or forest land.

A major proportion (approximately 80%) of the site constitutes natural or near-natural habitats represented by saline mudflats, thorn scrub and thorn forest and the remaining site constitutes modified habitats represented by farmland, salt-pans and embankments. No physical structures were noted at the site during the site visit.

It was noted that the soil at the project site has high salinity and accumulation of salt was noted throughout the land parcels. Also, the soil needs to be compacted prior to commencing any work on the site.

Ground water was noted to be at a depth of 1-2 m below ground level (bgl) at the site and the same was confirmed by the village Sarpanch. However, the ground water was reported to be extremely saline and thus unsuitable for drinking or domestic purposes. It is proposed that underground cables will be laid at the site for evacuation of the power generated through the project. It was informed by the project proponent that rain water gets accumulated at the site during precipitation.

The access road running parallel to the site is an existing paved road (~3.5 m wide) and is well connected to nearby cities. Thus, no access road needs to be constructed for the project. The map representing the location of project in Radhanesda Solar Park has been shown in the Figure 2-2 below.

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ESIA of 200 MW Solar Power Project

Figure 2-2: Map showing Project Location in Radhanesda Solar Park

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ESIA of 200 MW Solar Power Project

2.3 Project Overview 2.3.1 Project Components The project components for a solar power plant include Solar PV array, transformer, inverter, substation, transmission line and shared infrastructures (office building, control room, guard room, etc.).

Solar power is trapped through the PV cells in the modules, which are connected to form an array to produce higher voltage. Since the power generated through the solar panels is a Direct Current (DC) and electrical appliances use the Alternating Current (AC), inverters are used to convert DC to AC generated in the solar farms. Transformers are then connected with the AC to step up the voltage to 33 kV for transmission to pooling substation and there it steps up 220 kV level to feed into the grid substation.

Details on components of PV solar plant are presented in Table 2-1 and schematic diagram of a functional solar power plant with project components is depicted in Figure 2-3 below.

Figure 2-3: Overview of Solar PV Plant

Source: Utility-Scale Solar Photovoltaic Power Plants by IFC (World Bank Group)

Table 2-1: Components of Solar PV Plant

S. No. Component Description

1. Solar PV modules These convert solar radiation directly into electricity through the photovoltaic effect in a silent and clean process that requires no moving parts. The PV effect is a semiconductor effect whereby solar radiation falling onto the semiconductor PV cells generates electron movement. The output from a solar PV cell is direct current (DC) electricity. A PV power plant contains many cells connected in modules and many modules connected in strings2 to produce the required DC power output.

2 Modules may be connected together in a series to produce a string of modules. When connected in a series the voltage increases. Strings of modules connected in parallel increase the current output.

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ESIA of 200 MW Solar Power Project

S. No. Component Description

2. Inverters These are required to convert the DC electricity to alternating current (AC) for connection to the utility grid. Many modules in series strings and parallel strings are connected to the inverters.

3. Module mounting (or These allow PV modules to be securely attached to the ground at a fixed tilt angle, or on tracking) systems sun-tracking frames.

4. Step-up The output from the inverters generally requires a further step-up in voltage to reach the transformers AC grid voltage level. The step-up transformer takes the output from the inverters to the required grid voltage (for example 33kV and 230 kV depending on the grid connection point and country standards).

5. Grid connection This is where the electricity is exported into the grid network. The substation will also have interface the required grid interface switchgear such as circuit breakers (CBs) and disconnects for protection and isolation of the PV power plant, as well as metering equipment. The substation and metering point are often external to the PV power plant boundary.

Apart from the above basic components, the project system will consist of a main control room (MCR) and a switch yard within the project boundary.

As per the information provided by the Client, the 250 MW (AC)/200 MW (DC) solar power project will be based on Multi-crystalline silicon (c-Si) Solar Photo Voltaic technology using 380Wp/435Wp) with with 72 cells each for power generation. The proposed power plant will have an AC/DC ratio of 1.50 / 1.40 (DC Overloading).

The salient features of the project components have been presented in Table 2-2 below and the details have been provided in subsequent sections.

Table 2-2: Technical Details of PV Power Plant

Parameter Make

Solar PV Modules 380/435 Wp (789473/666666) Module mounting structure Fixed type Tilt- 19 deg for 2P29/ Pitch 8.0 M for 435 Wp Tilt- 18 deg for 2P30/ Pitch 7.5 M for 380 Wp String Combiner Box (SCB) 16 Inputs / 1 Output- with 380 Wp design 24 inputs/ 1 output- with 435 Wp design Cables as per design DC 3.3KV XLPE Armored Cable Cables as per design AC XLPE with HDPE outer Sheath & water saleable tape Invertors Capacity 6.40 MW Block with String Inverter (160 kW, 185 KTL Huawei) 3125 kVA Number of Invertor 64 Invertor Transformer Make 6.40 MVA for String Inverter & 12.5 MVA (16 nos.) for Central Inverter option Outdoor HT Panel make and Rating 33KV VCB Indoor type at MCR Source: Detailed Project Report (DPR)

2.3.1.1 DC Components

PV Module

All solar PV modules mandatorily have to adhere to International Electrotechnical Commission (IEC) specifications given in IEC 61215 for Crystalline Silicon modules. The solar PV modules for the project must be tested and certified by an independent international testing laboratory. For optimum energy generation Crystalline Silicon 380 Wp and 435 Wp modules will be used for this project.

Module Mounting Structure

Fixed tilt ground mounted structures with uniform loading will be used for this project. PV modules are directly mounted on the module support members. The aluminum frame of each solar module is galvanically isolated

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ESIA of 200 MW Solar Power Project

from the steel supporting beam to prevent localized corrosion and high-quality stainless-steel fixings are used throughout.

The mounting structure is designed for holding the designated number of modules in series. The frames and leg assemblies of the array structures are made of structural steel sections. The composition of steel conforms to IS 2062, suitable for welding purposes.

The structure will be designed to allow easy replacement of any module to support solar PV modules at a given orientation, absorb and transfer the mechanical loads to the ground properly. The legs of the structures with appropriate strength are fixed in the foundation columns as per design based on site soil condition.

Inverters

Inverters/ Power Conditioning Units (PCU) act as the interface between the PV array and the Grid. As the PV array output varies with the solar radiation, the inverter has to effectively interface with the grid to remain synchronized. Main functions of Inverters are:

 Convert the incoming DC received from PV modules into AC with suitable power quality.  The inverter also has to act as a protective device of the system. It needs to trip if the voltage, current or frequency goes outside acceptable ranges

For the project, 160 kW (185 KTL) of Huawei make will be used for 6.40 MW block and for 12.5 MW Block with Central Inverter (3.125 MW outdoor Inverter) will be selected. 2.3.1.2 AC Components

The AC subsystem commences from the output of the inverters and comprises of the transformers, the associated switchgear, metering and protection circuits and terminates at the two-pole structure from where the transmission lines would start.

Transformer

Outdoor oil-type 6.40 MVA for String Inverter & 12.5 MVA for Central Inverter option with Voltage 33KV (as per design) with three (03) winding for String Inverter and five (05) winding for Central Inverter option will be used for the project.

HT Panel

The HT panel is an interface between the transformers and grid providing the protection required for the system. The switchgear contains all equipment viz. Circuit breakers, CTs, PTs, relays and associated equipment. 33 kV Switchgear with16 ITS station and 2 number for MCR will be used.

Metering

The metering arrangement is compatible with the Availability-Based-Tariff (ABT) mechanism along with a check meter with Modbus arrangement and facility to provide remote monitoring. The meter has web communication facility and is visible at the State Load Dispatch Centre (SLDC).

AC Auxiliary System

The AC auxiliary supply of single/three phase is required for periphery lighting, security cabin and control room lighting etc. 2.3.1.3 Civil Structures

Inverter room and Control Room The inverter rooms are pre-fabricated FRP structures and control room is the standard RCC framed structures.

Boundary Wall

The complete plant boundary covering module yard, control room, switchgear room and switch-yard, security cabin, etc. is provided with a compound wall made of pre-cast slabs.

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ESIA of 200 MW Solar Power Project

Security Cabin

The security cabin made of FRP (Fiber-reinforced plastic) is provided near the site entry gate.

Transformer Foundation

The power transformer has been placed on gravel filled foundation and placed on the ground/ raised foundation.

Pile Foundation

Pile foundation design has depended upon soil conditions, geographical condition, regional wind speed, bearing capacity, slope stability, etc.

Internal Roads

Internal roads T3 traffic category with 3.5 m width will be constructed 250 mm above floor level. Peripheral roads around the boundary will be constructed as per IRC 37 with at least 3 m width. 2.3.1.4 Earthing

There will be dedicated earthing stations for transformer, MV switch boards and high voltage panels. Maintenance free earthing stations are considered preferable for the design due to long-term trouble-free performance in comparison to conventional pipe earthing. All the modules will be appropriately earthed in accordance to the NEC (National Electrical Code). Grounding of the modules will be done as recommended by the manufacturer. 2.3.1.5 Lighting and Over Voltage Protection

The MV stations comprising of transformers, inverters, etc. will be provided with adequate lightning protection. Similarly, the entire main control room building, and four pole structure arrangement will be protected as per IS standards. Necessary concrete foundation for holding the lightning conductor in position will be made after giving due consideration to the maximum wind speed (47 m/sec) and maintenance requirement at site in future. Each lightning conductor will be fitted with individual separate earth pit as per required Standards including accessories and provided with iron cover plate having a lock arrangement, watering pipe using charcoal or coke and salt as per required provisions of Indian Standards (IS). 2.3.1.6 Supervisory Control and Data Acquisition (SCADA) System

The entire solar PV power plant will be integrated with Supervisory Control and Data Acquisition (SCADA) system which communicates with all the inverters and monitoring boxes (SMB) for displaying parameters mentioned below. The integrated SCADA has the feature to be used either locally via a local computer or also remotely via the Web using either a standard modem or a GSM / WIFI modem and broadband. SCADA have provision of tracking the status of breakers and relays. Following parameters will be shown in the SCADA system:  Data from weather station;  PV module back surface temp;  Line and phase currents;

 Cumulative energy exported;  Power at 220 kV terminal;  AC and DC side power of each inverter;  Voltage of the HT Side; and

 Current and voltage of each sub-array/string.

2.3.2 Power Evacuation—Substation and Transmission Line Power generated through PV modules will be stepped up to 33kV and will be pooled to main HT panel using breaker feeder. As per information provided by ESPL, a 33kV/220 kV internal common pooling substation (PSS)

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ESIA of 200 MW Solar Power Project

which will be constructed by GUVNL near the Project Site for all the Solar Power Developers in the Solar Park and the power will be further evacuated through a 400-kV transmission line of length ~35 km.

As per the information available, the transmission line corridor is currently under construction and is expected to be commissioned by March 2020. The transmission line will be connected to the 400/200kV Banaskantha substation in Khimanava village (Inter-Connection Point/Delivery Point), which is situated at a distance of 35 km from the project site.

As per the DPR, SPPD has secured connectivity from Central Transmission Utility (CTU) for the Solar Park. ESPL after being selected in the bidding, entered into Implementation and Support Agreement (ISA) for connecting their project with grid through internal Pooling Sub-station. ESPL shall connect their project to Internal PSS by laying 33 kV cable up to low voltage bus bar of Pooling Sub-station at its own cost. All the line losses up to Inter-connection point will be on account of the Solar Power Developer.

Metering point shall be at 220 kV side of 400/220 kV Banaskantha substation of Power Grid Corporation of India Limited (PGCIL), i.e. the CTU. However, one more metering system shall be installed at 33 kV side of Internal Pooling Sub-station where power from the Solar Power Project is injected for measuring export / import from each project.

It is to be noted that the transmission line component of the project is a shared facility common to all the solar power producers operating/ proposed to operate within the Power Park. Consequently, ESPL does not have any control over the procedure being employed towards obtaining RoW, payment of compensation to owners of private land parcels towards loss of land located between the foot legs of the transmission and restricted land use along the RoW corridor. However, consultations with communities inhabiting within proximity of the proposed transmission line route indicated that the proponent will pay one-time compensation to land owners for loss of standing crops and trees.

2.3.3 Access Roads The main entrance to the site is proposed to be from the eastern side. The site can be accessed through State Highway (SH) 127 which passes through the village Kundaliya and connects to Radhanesda village at a distance of 8 km from the site. The road further connects to Limbidya village (Limbiya- Baet road) which is an existing government bitumen road (~3.5 m wide) and runs parallel to the site.

Since, the road is paved thus, no new road will be required to be developed for the project. Consultations with the project proponent suggested that project-related construction material, equipment and machinery are envisaged to be transported through the access road connecting the site. 2.4 Status of the Project For the purpose of the environmental and social impact assessment, a site visit was undertaken in January 2020. As on the day of site visit, the project was noted to be in pre-construction phase, and it was noticed that fencing work to demarcate the site boundary was being undertaken at the proposed project site. As per the information provided, land procurement is under the purview of GPCL. A Power Purchase Agreement (PPA) was signed between GUVNL and ESPL on 26 August 2019 for purchase of power generated from the proposed project for a period of 25 years. As per the information shared by the client, the Engineering, Procurement and Construction (EPC) Contractor for the project is in the process of being finalised. A hydrological study for understanding the flooding and drainage aspects of the entire solar power park was undertaken by IIT, Roorkee in August 2016. The Right of Way (RoW) for the transmission line will be obtained by the GPCL. Evacuation Approval for the entire solar park of capacity 700 MW to be set up in Radhanesda village was obtained by GPCL from Power Grid Corporation of India Limited (PGCIL) through letter dated 13 October 2019.

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ESIA of 200 MW Solar Power Project

Figure 2-5: Ground water at a depth of 1-2 m below Figure 2-4: View of the project site ground at site

Figure 2-7: Limda Mata Ki Mandir under renovation at a Figure 2-6: View of the existing paved access road running distance of 1km from site parallel to site

The Figure 2-8 represents the project site along with the PSS and external transmission line.

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ESIA of 200 MW Solar Power Project

Figure 2-8: Map showing the project location and external transmission line

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ESIA of 200 MW Solar Power Project

2.5 Resource Requirement and Procurement 2.5.1 Land requirement and Procurement process The following project components were identified for which land was required during the construction and/ or operation phase;

 Installation of Solar Modules;  Site office;  Invertor room;  Stock yard; and

 Transmission line The above information on the project components has been drawn based on discussions with the site representatives of ESPL, consultations with institutional stakeholders such as the Gujarat Urja Vikas Nigam Limited (GUVNL), Gujarat Power Development Corporation (GPDC) and Gujarat Energy Development Agency (GEDA) and review of land-related documents shared by ESPL. 2.5.1.1 Project-related land procurement and existing land procurement status

The land required to be used for solar modules is approximately 4 acres/ MW and total 200 MW will be installed in this project. Hence, the total land requirement for installing the 200 MW solar power plant with site office, inverter room, transmission line and other associated structures is approximately 380 hectares (~ 938.06 acres). The Project Site comprises of two (2) adjoining plots i.e. Plot D and Plot E, each measuring 190 hectares (~469.03 acres) and is located in the south western portion of the Radhanesda Solar Park. The land parcel of 68 hectares (167.96 acres), earmarked for grazing purposes, and the proposed PSS, that will be common for all solar power operators which will be operating within the solar power park, are located towards north west of the Project Site.

Details and existing land procurement status for the project is as follows:

 Extent of land: As per the site representatives, the concerned land parcels are mostly saline, sandy and uncultivable land measures and fall within the Radhanesda Solar Power Park located in the Radhanesda village under Vav tehsil in Banaskantha district. ESPL has also undertaken a title search for the project land through representatives from the head office in Pune.

 Mode of procurement: The entire land measuring ~ 938.06 acres has been allotted on lease basis by the GPCL to Electro Solaire Private Limited (ESPL) for a period of 25 years.

 Current procurement status: The lease deed has already been executed between GPCL and ESPL. However, ESPL was yet to take physical possession of the land at the time of the ESIA study.

 Farming and irrigation: The entire project land was observed to be sandy and unfit for farming. Moreover, poor fertility and lack of irrigation facilities for cultivation of the concerned land parcels were reported during community consultations. Consequently, no farming activities were observed or reported during the site visit.

 Access road: The site can be accessed through State Highway (SH) 127 which passes through village Kundaliya and connects Radhanesda village at a distance of 8 km from the site. The road further connects Limbidya village (Limbiya- Baet road) which is an existing government paved road (~3.5 m wide) and runs parallel towards the north of the site. The site is situated at a level of ~3 m below the access road. Consultations with the site representative revealed that at least 2-3 meters of land on either side of the existing road is there (owned by the Government) that can be used to widen the road. Hence, no land is required for widening of the access road.

 Transmission line: Power generated from the project will be fed to the common Pooling Substation (PSS), which will be constructed by GUVNL adjacent to north western portion of the Project Site and power will be further evacuated through a 400-kV transmission line measuring ~35 km. As per the information available, the transmission line corridor is currently under construction. The transmission line will be connected to the 400/200kV Banaskantha substation in Khimanivas village, which is currently

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ESIA of 200 MW Solar Power Project

under construction and is expected to be commissioned by March 2020. The transmission line corridor is mostly passing through agricultural land parcels, however, the right of way (RoW) of the transmission line is yet to be finalised.

 Grazing within and around the project site: Grazing activities were observed in a land parcel measuring approximately 68 hectares (167.96 acres) situated adjacent to the north western portion of the Project Site. The land parcel, originally owned by the government, has been handed over to the Radhanesda Gram Panchayat (GP) as a goodwill gesture to the local communities for animal grazing purpose. Consequently, the said land parcel measuring 68 hectares has been excluded from the solar power park. Though the same is located within the boundary of the solar power park, however, it has been excluded from allotment to any developer and is connected by an access road measuring approximately 5-6 meters.

 No appropriation through the tools of acquisition: It is to be noted that no appropriation of land using the tools of acquisition have been involved for the project. Consequently, the project does not have any impacts that are involuntary in nature. 2.5.1.2 Key Issues in Land Procurement

As indicated earlier, land for the concerned solar power park, including the two (2) plots that have been allotted to ESPL for setting up their power project, is owned by the Government of Gujarat. Hence, no procurement of land from private parties has been done for the project. The land in question has been allotted by the Government of Gujarat through the GPCL to individual solar power producers on a lease basis for a period of 25 years. The position of the project/ land procurement vis-à-vis key socio-economic issues are as follows:

 Schedule V Area and Tribal Land: The Project area does not fall under Schedule V areas as defined in the Indian Constitution under Article 342. The land identified for the project does not comprise of any tribal land/ land parcels owned by members belonging to the Indigenous Peoples (IP). Moreover, the project does not have any impacts on IPs. It is to be noted that according to the 2011 Census, Banaskantha has 9.1 % tribal population residing within the district.

 Forest land: The project will be developed on Government-owned sandy, saline, barren and uncultivable waste land. As reported, no forest land will be used for the project.

 Common Property Resources (CPR): No CPRs were reported on the allotted land parcels. As indicated earlier, within the boundary of the solar park, one land parcel measuring 68 hectares (167.96acres) has been allotted by the Government as a goodwill gesture to local communities for grazing purposes.

 No Objection Certificate (NOC) from Panchayat: The State of Gujarat does not require solar power projects to take a NOC from the Gram Panchayat of the impacted villages prior to initiation of construction activities. However, the project proponent reported that prior to commencement of construction activities at site, a NOC will be obtained from the Radhanesda Gram Panchayat.

 Landlessness: As the entire project land is owned by GPCL and the same has been leased to ESPL for a period of 25 years, there is no possibility for landlessness caused by the project.

 Encumbrance on Land/ Economic Impact: No encumbrance or encroachment on the project land could be observed at site or reported during stakeholder consultations. Similarly, no agricultural activities were observed at site. Hence, based on the general site conditions – sandy/ uncultivable nature of land, lack of rains and the limited farming being undertaken around the proposed project land, no significant economic impacts of the project are envisaged.

 Cultural Heritage sites: ‘Limda Mata Ki Mandir’ – a temple was observed at approximately 1 km from the project. The existing temple was being renovated during the site visit. The project will have no bearing/ impact on the temple. Consultations with the local communities and the Sarpanch, Radhanesda indicated that the temple has been existing in the same location since generations and that its origin/ circumstances surrounding its origin is not known.

2.5.2 Land procurement process As indicated earlier, the project land allotted on lease basis for a period of 25 years to ESPL, is owned by the Gujarat Power Corporation Limited (GPCL). The said land does not include any private or forest land. The

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ESIA of 200 MW Solar Power Project

procedure used for procurement/ allotment of the said land by the GPCL on lease basis to ESPL has been highlighted in Figure 2-9.

Figure 2-9. Land procurement/ allotment process

The key aspects of the lease of the concerned land parcels between GPCL and ESPL that were reviewed in the lease document include the following:

 The Land is located in the old survey no- 121 and has two (2) new blocks – Survey no-125 and Survey no-128;  The nature of land use is non-agricultural;  The extent of land in the old survey no. i.e. 121 is 1407.06.98 acres and the same was confirmed through a remeasurement applied by the Talati cum Mantri of Kundaliya Village;  The lease period is for 25 years;

 The lease rate is to be Rs. 10,000 per hectare per year with a provision for increase in the lease rate by 15 % every three years; and  Review of the land allotment genesis suggests that the concerned parcels were allotted as per the officer’s order on 24/4/1965 (name of the allotted person is not clearly mentioned) and again on 9/4/1966. Therefore, there is change in allotment and the government has allotted the same land at Radhanesda to a new person (name of the allotted person is not clearly mentioned). Based on review of the lease deed shared by ESPL, consultations with the revenue department officials, the ESPL representatives and the local Sarpanch, it can be confirmed that the land procurement for the project is being done through the land lease process.

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ESIA of 200 MW Solar Power Project

2.5.3 Manpower requirement Procurement of land for the project was already completed at the time of the site visit. However, no project- related construction activities had started. The EPC contractor for the project was yet to be appointed at the time of site visit. However, it was reported that during the peak construction phase, approximately 600-700 workers will be employed for a duration of 2-3 months. Some of the key activities to be undertaken at site during the construction phase includes foundation work, civil construction work, electrical and structural work etc. While most of the workers in the unskilled and semi-skilled categories will be hired from the neighbouring villages and from within the Banaskantha district, the manpower requirement in the skilled and highly skilled categories will be sourced from outside the state. It was revealed by the site representative of ESPL that approximately 30 % of the construction manpower will be migrant workers who will be provided accommodation in a labour camp that will be constructed approximately 1 kms from the project site during the construction phase. The manpower requirement during the operations phase was reportedly between 6 – 8 people who will be engaged through contractors mostly for housekeeping, security, gardening etc. The ESPL manpower to be engaged during the construction and operations phases was reported to be between 10 – 15 (during construction) and 4 (during operations) respectively.

2.5.4 Water Requirement Construction Phase

In the proposed plant almost all the buildings and structures will be prefabricated type and all the equipment will be packed and shifted in completely assembled or partially assembled form. The installation of the equipment will not require water in any form, as reported. As per the information shared by the Client, water requirement for the construction phase will be 100 KL (Kilo litres) that will be required for piling, foundation works and other construction activities. The water will be sourced through a branch of the Sardar Sarovar Narmada Water canal located at a distance of 40 km from the Project Site. Reverse Osmosis (RO) treated packaged drinking water will be provided to the workers at site (~5000L/day) for peak construction period. One labour camp will be constructed, as reported.

Operation Phase

Conventionally, the water requirements for the plant in operation phase are predominantly for washing of solar PV modules periodically to remove bird droppings, dust and other dirt and for domestic use.

During the operation phase, Reverse Osmosis (RO) treated packaged drinking water will be provided to the workers at site (~250L/day). Water for domestic requirement at the site will be ~1 KL and will be sourced through Narmada Canal as informed by the Client.

As per the information provided by the Client, responsibility of the water supply belongs to Gujarat Government who have a control of Narmada Water Allocation in entire Gujarat State. Based on the secondary information available in public domain, it was understood that ~1.5 MLD of water has already been allocated to Radhanesda Solar Park. GPCL will construct a tank of 10 lakh litres capacity inside the solar park for meeting the water requirement for module cleaning for the entire solar park. Water for module cleaning will be sourced by GPCL through a branch of Narmada canal and will be stored in the tank to be constructed by GPCL for the entire solar park. Assuming a minimum of 2.5 litres of water per module3, the water requirement for cleaning the whole plant (i.e. ~10 lakh modules) will be approximately 1,666 kilo litres, at one time.

As on the day of site visit, GPCL has already started construction of Water Pipeline and elevated Water Tank within Solar Park. Design of the Water Infrastructures are designed based on 1.5 MLD water requirement. However, the total water requirement during construction stage will be 100 KL and that during operation stage will be 5000 KL per month. Hence considering that a total of 7 solar power developers will be operating within the solar park, the dedicated water supply of 1.5 MLD will be sufficient.

3 As per the details shared by Client, ~2.5 liters of water will be required for cleaning of one module.

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ESIA of 200 MW Solar Power Project

2.6 Waste Generation 2.6.1 Waste Water During construction phase, adequate number of portable toilets will be provided by the EPC contractor at site and a septic tank with soak pit will be provided for disposal of domestic wastewater generated. Wastewater from construction activity will be limited to cleaning and washing activities.

During the operation phase, domestic wastewater will be limited to domestic wastewater discharged from the site office. Toilets with a septic tank and soak pit will be provided for disposal of domestic wastewater generated at the site office.

2.6.2 Hazardous Waste During construction phase, hazardous waste such as used oil from diesel generator (DG) sets, oil-soaked cotton, oil lined containers, paints etc. will be generated at the site. The hazardous waste will be disposed through a Gujarat Pollution Control Board (GPCB) authorized hazardous waste recycler within 90 days of generation.

During operation phase, no DG set is proposed to be installed at the site and thus the hazardous waste generation will be limited to used oil from transformer. The oil will be reused after filtration and the waste oil will be disposed through a GPCB approved hazardous waste recycler.

2.6.3 Solid Waste Solid waste generation during the construction phase will consist primarily of scrapped building materials, excess concrete and cement, rejected components and materials, packing and shipping materials (pallets, crates, Styrofoam, plastics etc.). The waste will be disposed by the EPC contractor by following designated solid waste management practices.

During operation phase, the waste generated will be limited to paper, plastic waste and food waste from the site office. The waste shall be collected in designated bins at site and disposed at a regular interval by the O&M contractor. 2.7 Implementation Schedule ESPL has undertaken site assessment based on solar radiation data available, identification of land and land procurement for the proposed project. The entire project land has been allotted to ESPL by the GPCL on lease basis for a period of 25 years.

ESPL will engage an EPC contractor on turnkey basis for undertaking construction works by the end of January 2020. The construction works will comprise of carrying out geotechnical investigations, foundation works, installation of switch yard, array yard installation, SCADA system, inverters modules and equipment installation.

Once construction of the project is over, the project will be handed over to an Operation and Maintenance Contractor (O&M) which is yet to be finalised by ESPL. However, the O&M contract will be for a period of twenty- five (25) years. As part of the O&M, the O&M contractor will be the in-charge of project management which includes financial and administrative control, overall project co-ordination, manpower selection for operation and maintenance etc.

As per the information shared by the Client, the construction of the solar power plant is expected to be initiated by January 2020 and the construction period is expected to last for eleven (11) months. The expected date of commissioning of the 200 MW power plant is November 2020. The construction of the internal PSS has been initiated by GUVNL. The PSS is located at a distance of ~200 m from the site and is expected to be commissioned by June 2020.

2.7.1 Construction Activities Site Development

The site development activities for the proposed project will entail the following:

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 soil investigations;  site clearing;

 site levelling;  construction of access roads;  fencing of site; and  laying of foundations.

All construction activities shall occur within the site boundary limits with the exception of those activities related to the interconnections between the site and the common infrastructures, which will be performed by the ESPL outside the boundary wall of the site. ESPL shall only be responsible for site clearing and grading of the site as required for construction, operation, and maintenance of the plant.

2.7.2 Operation and Maintenance The solar photovoltaic system requires least maintenance among all power generation facilities due to the absence of fuel, intense heat, rotating machinery, waste disposal, etc. However, keeping the photovoltaic panels in good condition, monitoring and correcting faults in the connected equipment and cabling are still required in order to get maximum energy from the plant. The maintenance functions of a typical solar PV power plant can be categorized as below.

1) Scheduled or preventative maintenance – Planned in advance and aimed at preventing faults from occurring, as well as keeping the plant operating at its optimum level. 2) Breakdown maintenance – carried out in response to failures. Maintenance Requirement

The main objective of the plant maintenance is to keep the plant running reliably and efficiently as long as possible. Efficient operation implies close control not only over the cost of production but also over the cost of maintenance. There are two components in maintenance cost: one is the direct cost of maintenance, (i.e. the material and labour), and the other is the cost of production loss.

Routine Maintenance

Several maintenance activities need to be completed at regular intervals during the lifetime of the system. The energy yield of the plant will be monitored using the remote data acquisition system connected to each inverter. Significant reduction in energy yield will trigger specific maintenance requirements, such as inverter servicing or module replacement. Typical activities required are described below:

1) General maintenance: Vegetation will need to be cut back if it starts to cause a fire risk or introduce shading; 2) Modules: Visual inspection and replacement of damaged modules will be required. Cleaning of the module glass surface during long dry periods may be considered. Module cleaning needs to be carried out periodically to remove dust, bird dropping etc.; 3) Wiring and junction box: Visual inspection for corrosion, damage such as chafing and damage by rodents and birds and for overheating of cables and connections; 4) Inverter Servicing: Inverter faults are the most common cause of system downtime in PV power plants and therefore, the scheduled maintenance of inverters should be treated as a centrally important part of the O&M strategy. The preventive maintenance of inverters includes visual inspection, cleaning/replacing cooling fan filters, removal of dust from electronic components, tightening of any loose connections etc.

Breakdown Maintenance

Breakdowns can occur due to lack of routine or preventive maintenance, bad climatic conditions, disturbance in utility grid etc. As breakdowns affect energy generation and hence revenue generation, these kind of faults needs to be immediately corrected. Breakdown can occur at any part of the system between solar PV modules to substation end.

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3. Environment and Social Regulatory Framework

This section highlights the environmental and social regulations applicable to the proposed solar power project. The section broadly focuses on the institutional framework, national administrative/ regulatory requirements, applicable environment, health and safety and social legislative requirements, ADB Policies, Strategies and Operations Manuals, FMO policies and IFC Performance Standards, relevant to the proposed project. 3.1 Terms of Reference Scoping exercise for the project was undertaken in November 2019. Based on the scoping, Terms of Reference (ToR) for the ESIA study are illustrated in Table 3-1.

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Table 3-1: Terms of Reference for the ESIA

S. N. Section Particulars Description of the Content

1. Executive Summary - The section will provide a brief summary of the project, ESIA process and methodology adopted, environment and social baseline conditions, significant project related aspects and identified impacts and mitigation.

2. Introduction  Project Background The section will provide description of project background with objectives, purpose and scope and approach &  Purpose and Scope of Work methodology adopted for the ESIA study.  Approach and Methodology  Agencies Contacted  Limitations  Report Layout

3. Project Description  Site Settings This section will present project details such as layout, land details, site settings, project components etc. This will  Project Layout also include the description of the infrastructural development as a part of project life cycle during construction and  Project Components operation phase and resources required.  Power Evacuation System  Land Requirement  Status of the Project as on date of Site visit  Resource requirement

4. Environmental and  Introduction This section will provide information on Policy, Legal and Administrative framework applicable to the proposed solar Social Regulatory  Enforcement Agencies farm project as well reference to the International conventions and Clients Guidance documents. The section will also Framework  Applicable Environment and Social Laws, define the applicability of IFC Performance Standards of the proposed project. Regulations and Policies  IFC Performance Standards  UN Guiding principles on Business and Human Rights  Applicable Environmental Standards  Applicable International Conventions

5. Environment and  Introduction This section will illustrate the baseline settings of the environmental aspects, ecological profile and socio-economic Socio-Economic  Physiography status of the project area. Baseline  Geology and Soil  Drainage Environmental Aspects: Results of the primary environmental monitoring conducted will also be analysed against the legal as well as  Ground Water Resources international standards and presented under this section. The following parameters will be assessed:  Water Quality

 Climate and Meteorology Micro-meteorology: Available information on meteorology for the area representative of the site will be collected  Natural hazards from Meteorology Department. Setting up an automatic micro-meteorological station with data logging facility at the  Ambient Air Quality site for continuous monitoring for micro-meteorological parameters like ambient temperature, wind direction, wind  Ambient Noise speed, relative humidity, cloud cover and rainfall for twelve (12) weeks.

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 Biodiversity  Socio-economic Environment Air Quality: Information on Air quality will be collected through monitoring of ambient air quality for one (01) weeks per location for parameters such as Particulate Matter (PM-10), PM-2.5, Oxides of Nitrogen (NOx), Sulphur Dioxide (SO2), etc. Surface and Ground Water: Surface and ground water samples will be collected for analyses of following parameters:

 Organoleptic and Physical Parameters: Colour, Odour, pH, Taste, Turbidity, Total Dissolved Solids  General Parameters: Biological Oxygen Demand (BOD), Chemical Oxygen Demand (COD), Aluminium (as Al), Ammonia (as total ammonia-N), Anionic detergents (as MBAS), Barium (as Ba), Boron (as B), Calcium (as Ca), Chloramines (as Cl2), Chloride (as Cl), Copper (as Cu), Fluoride (as F), Free residual chlorine, Iron (as Fe), Magnesium (as Mg), Manganese (as Mn), Nitrate (as NO3), Phosphorus (as P), Selenium (as Se), Silver (as Ag), Sulphate (as SO4), Sulphide (as H2S), Total alkalinity as calcium carbonate, Total hardness (as CaCO3), Zinc (as Zn), Cadmium (as Cd), Cyanide (as CN), Lead (as Pb), Mercury (as Hg), Molybdenum (as Mo), Nickel (as Ni), Pesticides, Polychlorinated biphenyls, Total arsenic (as As), Total chromium (as Cr).  Bacteriological Parameters: E. coli bacteria, Total coliform bacteria Soil Quality: Soil samples will be collected and analysed for the following parameters:

 Physical Parameters: Particle Size Distribution, Texture, pH, and Permeability, Porosity, Electrical Conductivity, etc.

 Chemical Parameters: Nitrites, Nitrates, Phosphates, TPH, Heavy Metals such as Fe, Pb, Mn, Ni, Ba, Zn, Cu, Cd, Cr, As and Hg, Total Hydrocarbons, Cation Exchange Capacity, Trace Metal, Organic Matter, etc.

Ambient noise quality will be monitored to determine hourly equivalent noise levels. The noise sampling will be done once during the study period continuously for 24 hours, selected on the basis of the site sensitivities within the study area. The results of the findings will be analysed to work out Leq hourly, Leq day and Leq night.

Biodiversity Aspects:

Methodology and duration of the biodiversity study would be provided. Further, specific details on the following biodiversity aspects would be provided:  Floristic Profile – based on reported Forest Types an/d recorded floristic species  Faunal Profile – based on reported and recorded species of mammals, birds (resident and migratory), reptiles, amphibians and fishes  Invasive Alien Species  Habitat Profile (Natural and Modified Habitats)  Potential Critical Habitats – based on PS6-stipulated criteria/thresholds  Designated Areas (Legally Protected Areas and Internationally Recognized Sites)  Ecosystem Services (Provisioning, Regulating, Supporting and Cultural)

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Social Aspects: The socio-economic and demographic details of the study area encompassing villages within a radius of 5 kms will be provided on the following parameters: -  Education and literacy;

 Occupation and livelihood;

 Rural infrastructure and civic amenities; and

 Road, communication and transport. The ESIA will also assess the land procurement status and process.

The performance of the state, district and block vis-à-vis key socio-economic and demographic indicators will also be sketched. Further, assessment of socio-economic impact associated with the right of way and land procurement of any shared or related facilities (for example access road, transmission line, etc.) will be undertaken. 6. Stakeholder  Introduction  This section will highlight the requirements of the IFC with respect to stakeholder consultations and disclosure. Engagement and  Objective and Scope Key stakeholder groups of the project will be identified and mapped in this section basis which engagement measures can be proposed. Consultation  Engagement Mapping and Analysis

7. Analysis of Alternatives  Introduction This section will present the analysis of alternatives for the proposed solar project considering no project scenario,  No Project Scenario alternate methods for power generation and technology and alternate routes for transmission line.  Alternative Site Location  Alternate Source of Power Generation  Alternate Routes of Transmission Line  Conclusion

8. Evaluation of Impacts  Introduction This section will describe the Environmental, Ecological and Social impacts associated with the pre-construction,  Summary of Project Activities construction and operation, and decommissioning phase of the project and suggests specific mitigation measures to  Impact Evaluation Criteria avoid/reduce the identified impacts.  Impact Significance Criteria The exercise will cover impacts on areas of high biodiversity, protected areas or threatened species, disturbance of ecological systems and local communities through alteration of ambient air quality, noise levels, soil, surface and  Impact Assessment underground water quality resulting from Project activities; efficiency of energy use and opportunities of technology improvement; increased risk of natural resource degradation and alteration from significant use by the Project; acceptability of labour and working conditions during the construction and operation of the project, impacts on erosion and sediment discharge to surface waters etc.

The ESIA will also assess cumulative impacts with respect to construction, water usage, biodiversity etc., in detail and assess if the impacts are in line with the reference framework.

The Impact assessment exercise will also include assessment of Climate Physical and Transition Risks, resulting from climate change, which involve event-drive (acute) or longer-term shifts (chronic) in climate patterns.

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9. Environmental and  Introduction This section will provide recommendation for environmental and social management plan aimed at minimizing the Social Management  Organizational Structure (Environment, Social, negative environmental and social impacts of the project. Environmental and social monitoring requirements for Plan (ESMP) Health and safety) effective implementation of mitigating measures during development as well as operation of the project will also be  Roles and responsibilities delineated along with requisite institutional arrangements for their implementation.  Monitoring and Audit  Documentation and record keeping  Training

Social Management Plans:  Stakeholder Engagement Plan (inclusive of Monitoring mechanism)  Grievance Redressal Mechanism (inclusive of Monitoring mechanism) Environment Monitoring and Management Plan  Waste Management Plan

10. Conclusion and - This section will conclude the outcomes of the study and categorise the proposed project based on IFC Categorization of the Categorization. The conclusions and recommendations of the proposed ESIA study will be based on site inspections, Project evaluation of impacts identified by specialists and the process of stakeholder consultation.

11. Gap Analysis against The section will present the gap analysis of the project against the equator principles and present an E&S Action Plan the Equator Principles to close the gaps identified.

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3.2 National and Regional Enforcement Authorities In India, Ministry of New and Renewable Energy (MNRE) is the nodal agency to manage the upcoming solar power projects and the environmental aspects are governed by Ministry of Environment, Forests and Climate Change (MoEF&CC), Central Pollution Control Board (CPCB), Central Electricity Authority (CEA) and Central Electricity Regulatory Commission (CERC). The social governance aspects at the micro level are addressed by institutions like panchayats and municipal bodies.

All the permissions and the approvals have to be taken from the concerned ministries, line departments and the local civic bodies for any upcoming project in India. The environmental and social governance approach in the country consists of:

1. Regulatory and implementing entities;

2. Legal framework including policies, acts and laws; and 3. Permitting system. A brief description of the relevant enforcement agencies with respect to the institutional framework is described in Table 3-2 below:

Table 3-2 Enforcement agencies relevant to the project

S. N. Name of the Agency Description

1. MoEF&CC MoEF&CC is the apex body in India which has been formulated to plan, promote, coordinate and oversee the implementation of India's environmental and forestry policies and programmes. Various acts like The Environment (Protection) Act 1986, as amended in April 2003, The Air (Prevention and Control of Pollution) Act, 1981, amended in 1987 and The Water (Prevention and Control of Pollution) Act, 1974, amended in 1988 have been developed. It is the responsibility of the apex body to ensure the compliance under the acts to maintain stipulated standards and environmental management through various supporting rules promulgated under the Acts. 2. Central Pollution Control The CPCB was established in September 1974, for the purpose of implementing provisions Board (CPCB) of the Water (Prevention and Control of Pollution) Act, 1974. The executive responsibilities for the industrial pollution prevention and control are primarily executed by the CPCB at the Central level, which is a statutory body, attached to the MoEF&CC. CPCB works towards control of water, air and noise pollution, land degradation and hazardous substances and waste management. CPCB will direct GPCB in case any violation is undertaken in complying with the conditions of Hazardous Waste Authorization. 3. Gujarat Pollution Control GPCB is a statutory authority, constituted as per the provisions under the Water (Prevention Board (GPCB) and Control of Pollution) Act, 1974, entrusted to implement environmental laws and rules within the jurisdiction of the State of Gujarat, India. The Board ensures proper implementation of the statutes, judicial and legislative pronouncements related to environmental protection within the State. Solar Farms fall under ‘White Category’ as per Final Document on Revised Classification of Industrial Sectors Under Red, Orange, Green and White Categories (February 29, 2016) issued by CPCB. There shall be no necessity of obtaining the Consent to Operate for White category of industries under the Water (Prevention and Control of Pollution) Act, 1974 and the Air (Prevention and control of pollution) Act, 1981. Intimation to concerned SPCB / PCC shall suffice. White Category Units do not require a Hazardous waste authorization from the Board, however, hazardous and other wastes generated by such industries shall be handed over to the authorised actual users, waste collectors or disposal facilities. 4. Petroleum and The PESO is under the Department of Industrial Policy & Promotion, Ministry of Commerce Explosives Safety and Industry, Government of India. The Chief Controller of explosives is responsible to deal Organisation (PESO) with provisions of: The Explosive Act, 1884 and Rules, 2008, The Petroleum Act, 1934 and the Rules 2002, The Static and Mobile pressure vessels (Unfired) Rules, 2016 and amended 2018, and Manufacture, Storage and Import of Hazardous Chemical Rules, 1989 and amendment 2000.

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S. N. Name of the Agency Description

The site will store a small quantity of fuel during construction phase. However, in case fuel storage exceeds the limit as stipulated in the Act, the project is required to obtain a license from PESO. 5. Director Industrial The main objective of the DISH is to ensure safety, health, welfare and working conditions Safety and Health of workers working in factories and in construction works by effectively enforcing the (DISH) provisions of the Factories Act, 1948 the Building & Other Construction Workers Act 1996 and other labour legislations. It is also to ensure the protection of rights of workers and to redress their grievances. Factory license is required as ‘factory’ means ‘any premises having ten or more workers involved in a manufacturing process’. Factory License from the State Government or Chief Inspectorate of Factories, Gujarat is required to be obtained for the project. Project proponent/ Construction contractor shall comply with all requirements of Gujarat Factories Rules 1963 and participate in periodic inspection. It is also to be ensured that no child labour is engaged during construction or operation phases of the project. 6. Ministry of New and The MNRE is the nodal ministry of Government of India for all matters related to new and Renewable Energy renewable energy. The broad aim is to develop and deploy new and renewable energy for (MNRE) supplementing the energy requirements of the country as stated on its website. The role of MNRE has been assuming importance in recent times with growing concerns of energy security. Energy self-sufficiency was identified as the major driver for new and renewable energy in the wake of the two oil shocks of 1970. 7. Gujarat Energy Gujarat Energy Development Agency (GEDA) is shouldering the responsibility of a state Development Agency nodal agency (SNA) for the Ministry of New and Renewable Energy Sources (MoNRE) and (GEDA) the state designated agency (SDA) for Bureau of Energy Efficiency (BEE). It aims to provide a platform to utilization of sustainable energy (renewable energy and energy efficient) technologies on mass scale to make them techno-economically and socio-culturally viable in the context of Gujarat’s energy scenario. 8. Central Electricity CEA is a Statutory Body constituted under the erstwhile Electricity (Supply) Act, 1948, Authority thereafter replaced by the Electricity Act, 2003, where similar provisions exist, the office of the CEA is an "Attached Office" of the Ministry of Power. The CEA is responsible for the technical coordination and supervision of programmes and is also entrusted with a number of statutory functions. 9. Central Electricity The Commission intends to promote competition, efficiency and economy in bulk power Regulatory Commission markets, improve the quality of supply, promote investments and advise government on the removal of institutional barriers to bridge the demand supply gap and thus foster the interests of consumers. 10. Central Ground Water CGWA was constituted under Sub-section (3) of Section 3 of the Environment (Protection) Authority (CGWA) Act, 1986 for the purposes of regulation and control of ground water development and management. As per CGWA's guidelines effective from 01 June 2019, NOC is required for ground water withdrawal for all infrastructure projects drawing/proposing to draw ground water through an energised means. (with effect from 16.11.2015). For the proposed project (falling in “Saline“ category) NOC is required for ground water, abstraction, NOC may be provided that the fresh water resources are not affected through such abstraction. No disposal of brine/contaminated ground water shall be allowed in the premise. In case there are any overlain/underlain by fresh water aquifers, NOC will only be granted after submission of a hydrogeological study, undertaken by a NABET accredited consultant. 11. Gram Panchayat Gram Sabha or the Panchayats are the local bodies which have been defined by the 73rd Constitutional Amendment Act, 1992. Panchayats have to be consulted before acquiring land in the Scheduled Areas for development projects and before re-settling or rehabilitating persons affected by such projects in the Scheduled Areas. The responsibilities that have been entrusted upon Panchayats comprises of the preparation of plans for economic development and social justice and the implementation of such schemes for economic development and social justice, as may be assigned to them. 12. Office of the Deputy If the project site is a part of the Protected Area or Eco sensitive Zone of the Wild Ass Conservator of Forest Sanctuary, which lies in close proximity to the project site, then an application for approval

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S. N. Name of the Agency Description

(DCF), Wild Ass from the National Board for Wildlife (NBWL) will have to be submitted to the DCF, Wild Ass Sanctuary, Dhrangadhra Sanctuary, Dhrangadhra 13. Office of the Range If any project infrastructure, activities or personnel are likely to occur in any area falling in Forest Officer, Tharad the jurisdiction of the Tharad forest range, application for approval will have to be submitted to the Range Forest Officer, Tharad.

3.3 Applicable Environment and Social Laws and Regulations Table 3-3 summarizes the key regulations that are relevant to the project across its lifecycle. This table should be used to update/develop a comprehensive legal register for the Project.

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Table 3-3: Applicable Environment and Social Laws and Regulations

S. Aspect Relevance Applicable Legislation Agency Applicable Permits and Requirements No. Responsible EHS Laws, Acts, Rules and Regulations

1. Environmental  Construction activities will generate air,  The Environment (Protection) GPCB As per Section 7 of Environment Protection Act, 1986 and Rule 3 of the Protection water and noise emissions; and Act 1986, as amended in April Environment Protection Rule, 1986, no person carrying on any industry,  Scattering of debris and construction 2003; and operation and process shall discharge or emit any environmental material can contaminate the soil,  EPA Rules 1986, as amended in pollutant in excess of prescribed standards. water and surroundings. 2002. Compliance under the rules to maintain stipulated standards and environmental management through various supporting rules promulgated under the Act.

ESPL and the EPC contractor are required to ensure that Project implementation adheres to the various clauses laid down in the Act

2. Prevention and Waste water generation during construction The Water (Prevention and Control of GPCB As per the section 24 of the Water (Prevention and Control of Pollution) Control of Water and operation of the Plant Pollution) Act, 1974, amended in 1988 Act, 1974, amended in 1988 no person shall knowingly cause or permit Pollution any poisonous, noxious or polluting matter into any stream or well or sewer or on land.

3. Prevention and Movement of vehicles, operation of diesel The Air (Prevention and Control of GPCB As per section 22 of The Air (Prevention and Control of Pollution) Act, Control of Air generators for power at campsite or other Pollution) Act, 1981, amended in 1981, amended in 1987, no person operating any industrial plant, in any Pollution construction activities. 1987. air pollution control area shall discharge or cause or permit to be discharged the emission of any air pollutant in excess of the standards laid down by the GPCB.

A solar power plant is clean option for power generation in comparison to non-renewable fossil fuels. Ministry of Environment, Forest and Climate Change (MoEF&CC) in its Office Memorandum No. J- 11013/41/2006-IA-II (I) dated 13th May 2011 stated that the solar power projects are not covered under the ambit of EIA Notification, 2006 and therefore does not require prior environmental clearance. In addition to this, CPCB issued notification regarding harmonization of classification of industrial sectors under Red/Orange/Green/White categories which states that ‘solar renewable power plants of all capacities’ is classified as a “White Industry” (Part-A, Serial Number 35) and does not require Consent to Establish and Consent to Operate. Only intimation to the concerned regional officer of State Pollution Control Board (SPCB) shall suffice 4

4 As per latest directions of Central Pollution Control Board, dated March 2016, Final report on revised categorization of industrial sectors under Red/ Orange/ Green/ White, solar power projects have been classified under White category of industries. As per the CPCB’s direction to SPCB/PPCs, “there shall be no necessity of obtaining Consent to Operate for White Category of industries and intimation to the concerned SPCB/PPC shall suffice.” And as per GPCB (https://www.gpcb.gov.in/Portal/News/129_1_GREEN_CATEGORY_EXEMPTED_FROM_CTE_CCA.pdf) “white category industries shall not be included in the Consent Mechanism. As per CPCB order dated 18th January 2017, the White category includes Solar Power Plants of all capacities. (http://kredlinfo.in/scrollfiles/exemption%20from%20pollution%20board.pdf)

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S. Aspect Relevance Applicable Legislation Agency Applicable Permits and Requirements No. Responsible

4. NOC And Batching plant operation would lead to The Water (Prevention and Control of GPCB Applicable. Consent to emission of fugitives. It also envisages Pollution) Act, 1974; Needs to be obtained before the construction work is commenced. Establish and waste water generation which could lead to The Air (Prevention and Control of Operate for contamination of land and water resources. Pollution) Act, 1981 & In addition, there would be generation of Batching Plant The Noise Pollution (Regulation and noise disturbance to the neighbouring Control) Rules, 2000 and subsequent villages. amendments.

5. License under Factory license is required as the project is Chapter I of The Factories Act, 1948 Directorate, As per the section 6 of The Factories Act, 194, ESPL would have to Factories Act, generating, transforming or transmitting Industrial Safety obtain registration of the power plant from the State Government or 1948 power. and Health, Chief Inspectorate of Factories, Gujarat if 10 or more workers are Government of engaged, triggering the applicability of the Factories Act. Gujarat

6. Noise Emissions Noise generated from operation of  The Noise (Regulation & Control) GPCB As per the Rules 3 and 4 of the Noise (Regulation & Control) Rules, construction machinery Rules, 2000 as amended in 2000 as amended in October 2002, noise emissions in the project area October 2002; and should not exceed standards specified in the Schedule.  As per the Environment (Protection) Act (EPA) 1986 the ambient noise levels are to be maintained as stipulated by CPCB for different categories of areas like, commercial, residential and silence zones etc. 7. Hazardous  The proposed project will generate Hazardous and Other Wastes GPCB As per the Hazardous Waste and Other Wastes (Management and Wastes waste oil from diesel generator during (Management and Trans boundary Trans boundary Movement) Rules 2016 and its amendment in 2019 the 5 Management construction phase and used Movement) Rules, 2016 as amended Rule 6 after sub-rule (1) states that: transformer oil during operation phase; in 2019 An occupier shall not be required obtain an authorisation under this  Solvents and chemicals used or rule, from the State Pollution Control Board, in case the consent to cleaning etc.; and Management of establish or consent to operate, is not required from the State Pollution damaged solar modules. Control Board or Pollution Control Committee under the Water (Prevention and Control of Pollution) Act, 1974 (25 of 1974) and Air (Prevention and Control of Pollution) Act, 1981 (21 of 1981); Provided that the hazardous and other wastes generated by the occupier shall be given to the actual user, waste collector or operator of the disposal facility, in accordance with the Central Pollution Control Board guidelines.

However, as per the Rules 4, 6, 8, 17, 18, 19 and 20 of the Hazardous and Other Wastes (Management and Transboundary Movement) rules following compliances are to be ensured by ESPL:

5 https://kspcb.gov.in/Hazardous%20and%20Other%20Wastes%20Amendment%20Rules,%202019_25-03-2019.pdf

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S. Aspect Relevance Applicable Legislation Agency Applicable Permits and Requirements No. Responsible

 Authorization for collection, reception, storage, transportation and disposal of hazardous wastes;  Liability of the occupier, transporter and operator of a facility: The occupier, transporter and operator of a facility shall be liable for damages caused to the environment resulting due to improper handling and disposal of hazardous waste listed in schedules to the Rules; and The occupier and operator of a facility shall also be liable to reinstate or restore damaged or destroyed elements of the environment.

8. Electricity Private sector projects to obtain distribution  The Electricity Act 2003; and Gujarat Electricity As per section 14 of The Electricity Act, 2003, ESPL shall obtain license Distribution Licenses from the State Electricity  The, Central Electricity Authority Regulatory under the act. License Regulation Committee and to have open (Measures relating to Safety and Commission Under rules 12 and 7, ESPL and the Contractors to ensure preventive access to the transmission lines Electricity Supply) Regulations, measures for health and safety of humans and plant. 2010 9. Storage of There will be storage of Diesel at site for  The Petroleum Act 1934, as PESO (Chief As per Section 3 of The Petroleum Act 1934 and Rule 116 of The Petroleum operation of generators during construction amended in August 1976 Controller of Petroleum Rules 1976, ESPL will be required to obtain a license from products phase.  The Petroleum Rules 1976, as Explosives) PESO, if the quantity of the fuel stored exceeds two thousand and five amended in March 2002. hundred litres and/ or is stored in a receptacle exceeding one thousand litres in capacity.

10. Surface Movement of construction vehicles and  The Motor Vehicles Act 1988, as State Transport ESPL to ensure compliance of the Section 39, Motor Vehicle Act, 1988 Transportation other vehicles for transportation of workers amended by Motor Vehicles Authority as amended in 2017 and Rule 47, Motor Vehicle Rule, 1989. (Amendment) Act 2000, dated 14th August 2000.  The Central Motor Vehicles Rules 1989, as amended through 20th October 2004 by the Central Motor Vehicles (Fourth Amendment) Rules 2004. Biodiversity related laws

11. Forest Protection Presence of legally protected forest areas in The Indian Forest Act, 1927 Gujarat State Approval of the Forest Department is required if project-related proximity to the project site Forest infrastructure, activities or personnel occur within a legally protected Department forest area.

12. Wildlife Presence of wildlife habitats, including those The Wildlife (Protection) Act, 1972 National Board for Approval of the National Board for Wildlife is required if project-related Conservation of Schedule I species, in and around the Wildlife infrastructure, activities or personnel occur within national parks and project site sanctuaries.

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S. Aspect Relevance Applicable Legislation Agency Applicable Permits and Requirements No. Responsible

13. Forest Presence of legally protected forest areas in The Forest (Conservation) Act, 1980 Gujarat State Approval of the Forest Department is required if the project uses legally Conservation proximity to the project site Forest protected forest land for any non-forest purpose. Department

Social and labour-related Laws, Regulations and Acts

14. Labour Engagement of workers for construction and The Factories Act, 1948 and Gujarat Department of ESPL / EPC Contractor shall comply with all requirements of Factories operation of the plant Factories Rules, 1963 Labour, Rules and participate in periodic inspection. Government of Gujarat

15. Contract Workers Engagement of contract workers The Contract Labour (Regulation and Department of As per Section 12 of the Contract Labour (Regulation and Abolition) Abolition) Act, 1970 as amended in Labour, Act, 1970 a contractor executing any contract work by engaging 20 or 2017 Government of more contract labourers has to obtain a licence under the Act. Gujarat

16. Child Labour Engagement of Child Labour at site The Child Labour (Prohibition and Department of Section 3 under the Child Labour (Prohibition and Regulation) Act, 1986 Regulation) Act, 1986 Labour, (CLA, 1986) including amendment in 2016. No child below the age of Government of 14 years shall be employed in any establishment mentioned in Gujarat Schedule Part A and Part B of the CLA, 1986.

17. Bonded Labour Engagement of Bonded Labour at site Bonded Labour (Abolition) Act 1976 Department of Rule 4 of the Bonded Labour System (Abolition) Act, 1976 specifies Labour, "After the commencement of this Act, no person shall-

Government of  make any advance under, or in pursuance of, the bonded labour

Gujarat system, or compel any person to render any bonded labour or other form of forced labour."

18. Payment of Provision of wages to labour engaged at the Minimum Wages Act, 1948 Department of Section 12 of the Minimum Wages Act, 1948: The employer shall pay to Wages site Labour, every employee engaged in a scheduled employment under him wages Government of at a rate not less than the minimum rate of wages fixed by the Gujarat appropriate Government Authority for that class of employees in that employment without any deductions except as may be authorized within such time and subject to such conditions as may be prescribed. Every employer shall be responsible for the payment to persons employed by him of all wages required to be paid under this Act.

19. Payment of Equal wages to male and female workers at Equal Remuneration Act 1976 Department of It is the duty of an employer to pay equal remuneration to men and Wages. site Labour, women workers for same work or work of a similar nature. Government of Gujarat

20. Payment of Engagement of Labour at site Workmen's Compensation Act, 1923 Department of Requires if personal injury is caused to a workman by accident arising Wages Labour, out of and in the course of his employment, his employer shall be liable Government of to pay compensation in accordance with the provisions of this Act. Gujarat

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S. Aspect Relevance Applicable Legislation Agency Applicable Permits and Requirements No. Responsible

21. Women at Engagement of Female Labour at site Maternity Benefit Act, 1961 Department of Section 4 of the Maternity Benefit Act, 1961 including amendment as in Workplace Labour, Maternity Benefit (Amendment) Act, 2017: - Government of  "No employer shall knowingly employ a woman in any Gujarat establishment during the six weeks immediately following the day of her delivery or her miscarriage;  No woman shall work in any establishment during the six weeks immediately following the day of her delivery or her miscarriage; and  Without prejudice to the provisions of section 6, no pregnant woman shall, on a request being made by her in this behalf, be required by her employer to do during the period specified in sub- section (4) any work which is of an arduous nature or which involves long hours of standing, or which in any way is likely to interfere with her pregnancy or the normal development of the foetus, or is likely to cause her miscarriage or otherwise to adversely affect her health." Section 5 of the Maternity Benefit Act, 1961 including as amended in 2017. "As per the amendment in 2017,  Subject to the provisions of this Act, every woman shall be entitled to, and her employer shall be liable for, the payment of maternity benefit at the rate of the average daily wage for the period of her actual absence, that is to say, the period immediately preceding the day of her delivery, the actual day of her delivery and any period immediately following that day;  No woman shall be entitled to maternity benefit unless she has actually worked in an establishment of the employer from whom she claims maternity benefit, for a period of not less than eighty days in the twelve months immediately preceding the date of her expected delivery;  The maximum period for which any woman shall be entitled to maternity benefit shall be twenty-six weeks of which not more than eight weeks shall precede the date of her expected delivery;  A woman who legally adopts a child below the age of three months or a commissioning mother shall be entitled to maternity benefit for a period of twelve weeks from the date the child is handed over to the adopting mother or the commissioning mother, as the case maybe; and In case where the nature of work assigned to a woman is of such nature that she may work from home, the employer may allow her to do so after availing of the maternity benefit for such periods and on such conditions as the employer and the woman may mutually agree."

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S. Aspect Relevance Applicable Legislation Agency Applicable Permits and Requirements No. Responsible

22. Contractor Labour Contractors or third parties to be involved in Building and Other Construction Department of Section 7 of the Act mandates the registration of establishments. ESPL License the construction works for the proposed Workers (Regulation of Employment Labour, should ensure that contractor/ sub-contractors have a valid registration project, if required, will also be engaged and Conditions of Service) Act, 1996 Government of only subject to availability of valid and Contract Labour (Regulation and Gujarat under the Building and Other Construction Works Act and Contract registration. Abolition) Act, 1970. Labour (Regulation and Abolition) Act, 1970.

23. Contract Labour Principal Employer registration for engaging The Contract Labour (Regulation and Department of Section 7 of the Act mandates the Principal Employer registration for contract labour through third party is Abolition) Act, 1970 Labour, engaging contract labour through third party. required. Government of Gujarat

24. Migrant Workmen Principal Employer registration for engaging The Inter-State Migrant Workmen Department of Section 4 of the Act mandates that the Principal Employer registration migrant labour is required for direct/indirect (Regulation of Employment and Labour, should be obtained for engaging migrant labour through third party. labour. conditions of service) Act, 1979 Government of Gujarat

25. Working Working conditions of contracted Labour Contract Labour (Regulations and Department of Section 16,17,18,19,20 and 21 of the said Act mandates the provision Conditions working at the site Abolition) Act, 1970 Labour, of the principal employer to ensure that all the contracted workers are Government of provided with condition of services, rate of wages, holidays, hours of Gujarat work as stipulated in the act and rules.

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3.4 Policy Framework in India Policies with respect to the renewable energy in India and Gujarat, focusing on the solar power, as released by the Government of India and Government of Gujarat from time to time and applicable to the project are discussed briefly in Table 3-4:

Table 3-4 National and State Level Policies Applicable to the Project

S. N. Name of the Policy Description 1. National Electricity The National Electricity Policy 2005 states that environmental concerns would be suitably Policy 2005 addressed through appropriate advance action by way of comprehensive Environmental Impact Assessment and implementation of Environment Action Plan (EAP). As per the policy, adequate safeguards for environmental protection with suitable mechanism for monitoring of implementation of Environmental Action Plan and R&R Schemes should be put in place. Open access in transmission has been introduced to promote competition amongst the generating companies who can now sell to different distribution licensees across the country. This should lead to availability of cheaper power. 2. National Solar Mission The objective of the Jawaharlal Nehru National Solar Mission (JNNSM) under the brand (JNNSM) 'Solar India' is to establish India as a global leader in solar energy, by creating the policy conditions for its diffusion across the country as quickly as possible. The Mission has set a target of 20,000 MW and stipulates implementation and achievement of the target in 3 phases (first phase up to 2012-13, second phase from 2013 to 2017 and the third phase from 2017 to 2022) for various components, including grid connected solar power. The successful implementation of the JNNSM requires the identification of resources to overcome the financial, investment, technology, institutional and other related barriers which confront solar power development in India. The penetration of solar power, therefore, requires substantial support. The policy framework of the Mission will facilitate the process of achieving grid parity by 2022. 3. National Environmental Government of India released the National Environment Policy in 2006. The policy aims at Policy, 2006 mainstreaming environmental concerns into all developmental activities. It emphasises conservation of resources, and points that the best way to aid conservation is to ensure that people dependent on resources obtain better livelihoods from conservation, than from degradation of the resources. 4. Gujarat Solar Power The Government of Gujarat vide G.R. No. SLR-11-2015-2442-B has formulated Gujarat Policy 2015 Solar Power Policy 2015 to promote the generation of power from solar energy. Objectives of the policy are: 1) To promote generation of green and clean power in the State using solar energy; 2) To create conditions conducive to the participation of private and public sector as well as PPP in the promotion and setting up of up Solar Energy based power projects in the State; 3) Productive use of wastelands / non – agricultural lands thereby leading to socioeconomic transformation and a reduction in regional disparities in development; 4) Employment generation and skill up gradation of the youth; 5) To put in place an appropriate investment climate that would leverage the benefits of Clean Development Mechanism (CDM) and result in lower Green House Gas (GHG) emissions; 6) Co-creation of Solar Centers of Excellence and pools of technical professionals which would work towards applied research and commercialization of indigenous and cutting edge technologies involving applications of solar energy generation and appliances; 7) Spreading of environmental consciousness among all citizens of the State especially the youth and school going children; and 8) Decentralization and diversification of the energy portfolio and to increase the share of renewable solar power.

3.5 Applicable International Standards and Guidelines 3.5.1 FMO Social Sustainability Policy FMO's Social Sustainability Policy intends to protect people and the environment impacted by its own operations and its investments and to help clients manage their environmental and social impact and improve their corporate governance. FMO requires, that all clients comply with applicable environmental, social and human rights laws in their home and host countries. In addition, with respect to the management of environmental and social impact, the primary standards that guide FMO’s relationship with clients are the IFC Environmental and Social Performance Standards and the associated World Bank Group Environmental Health and Safety Guidelines.

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3.5.2 IFC Performance Standards The performance standards stipulate that any proposed project shall meet the following requirements throughout the life of an investment by IFC or other relevant financial institution: -

 Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts;  Performance Standard 2: Labour and Working Conditions;  Performance Standard 3: Resource Efficiency and Pollution Prevention;

 Performance Standard 4: Community Health, Safety, and Security;  Performance Standard 5: Land Acquisition and Involuntary Resettlement;  Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources; s  Performance Standard 7: Indigenous Peoples; and

 Performance Standard 8: Cultural Heritage These Performance Standards and guidelines provide ways and means to identify impacts and affected stakeholders and lay down processes for management and mitigation of adverse impacts. The applicability of the Performance Standards is discussed in Table 3-5.

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Table 3-5 Applicability of IFC Performance Standards

S. Performance Description and Applicability No. Standard 1. PS1 – Assessment and APPLICABLE Management of Environmental and PS 1 establishes the importance of: Social Risks and Impacts  Integrated assessment to identify the environmental and social impacts, risks, and opportunities of projects;  Effective community engagement through disclosure of project-related information and consultation with local communities on matters that directly affect them; and  The project proponent’s management of environmental and social performance throughout the life of the project.

The PS 1 is applicable to projects with environment and/or social risks and/or impacts. The proposed project is a solar power project and will have environmental and social impacts such as stress on existing water resources, construction activities, direct or indirect impact on communities, etc. 2. PS2 – Labour and APPLICABLE Working Conditions PS-2 recognizes that the pursuit of economic growth through employment creation and income generation should be accompanied by protection of the fundamental rights of workers. 3. PS3 - Resource APPLICABLE Efficiency and Pollution Prevention PS3 recognizes that increased economic activity and urbanization often generate increased levels of pollution to air, water, and land, and consume finite resources in a manner that may threaten people and the environment at the local, regional, and global levels. The objectives of PS 3 are:  To avoid or minimize adverse impacts on human health and the environment by avoiding or minimizing pollution from project activities.  To promote more sustainable use of resources, including energy and water.  To reduce project-related GHG emissions.

The proposed project is a clean energy project and will not have major pollution sources associated with it. The construction works for the development of project will entail generation of wastes like air emissions, wastewater, used oil from DG sets and construction debris. The operation phase will result in generation of minor quantities of waste such as used transformer oil, broken and defunct solar panels and waste water from cleaning of solar panels. 4. PS4 – Community APPLICABLE Health, Safety and Security PS 4 recognizes that project activities, equipment, and infrastructure can increase community exposure to risks and impacts. Its main stress is to ensure that the safeguarding of personnel and property is carried out in accordance with relevant human rights principles and in a manner that avoids or minimizes risks to the Affected Communities.

Objectives of PS 4 thus are:  To anticipate and avoid any adverse impacts on the health and safety of the Affected Community during the project life from both routine and non-routine circumstances.  To ensure that the safeguarding of personnel and property is carried out in accordance with relevant human rights principles and in a manner that avoids or minimizes risks to the Affected Communities. The proposed project will involve transportation of construction material and movement of construction machinery which may pose safety risks to the affected communities. 5. PS5 – Land Acquisition NOT APPLICABLE and Involuntary PS 5 recognizes that project-related land acquisition and restrictions on land use can Resettlement have adverse impacts on communities and persons that use this land. Its main aim is to anticipate and avoid, or where avoidance is not possible, minimize adverse social and economic impacts from land acquisition or restrictions on land use by providing compensation for loss of assets at replacement cost and ensuring that resettlement activities are implemented with appropriate disclosure of Information, consultation, and the informed participation of those affected.

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S. Performance Description and Applicability No. Standard The PS is not applicable for the project as land for the solar park in question has neither been acquired by the government nor does it involve any privately-owned land. Stakeholder consultations at site also confirmed that there were no economic/ livelihood activities on the concerned land prior to its allotment to players for setting up their solar plant. This is primarily due to the saline and barren nature of the concerned land parcel (comprising the Site) because of which the land was not suitable for any agriculture activities. 6. PS6 – Biodiversity APPLICABLE Conservation and Sustainable PS 6 recognizes that protecting and conserving biodiversity, maintaining ecosystem Management of Living services, and sustainably managing living natural resources are fundamental to Natural Resources sustainable development.

The objectives of PS 6 are: . To protect and conserve biodiversity . To maintain the benefits from ecosystem services . To promote the sustainable management of living natural resources through the adoption of practices that integrate conservation needs and development priorities. The Project Site, as well as, the area of influence of the project contain natural and near- natural habitats, besides modified habitats, as also a potential critical habitat. The Project Site and the area of influence of the project provide important ecosystem services to the local community, including priority provisioning services in the form of water resources and pasture for livestock. The proposed project infrastructure and activities, such as removal of vegetation, levelling of land, laying of access roads, vehicular movement, artificial illumination and installation of solar panelling and power transmission cables, are expected to cause loss or degradation of habitats and ecosystem services, as well as, fragmentation of habitats, and possibly, promote further spread of already introduced invasive alien species. There is no designated area situated within the Project Site, but there are 3 designated areas within close proximity to the area of influence of the Project. Therefore, PS 6 is applicable to the Project. 7. PS7 – Indigenous NOT APPLICABLE People Performance Standard 7 recognizes that Indigenous Peoples, as social groups with identities that are distinct from mainstream groups in national societies, are often among the most marginalized and vulnerable segments of the population. In many cases, their economic, social, and legal status limits their capacity to defend their rights to, and interests in, lands and natural and cultural resources, and may restrict their ability to participate in and benefit from development.

The PS 7 is not applicable to the project as;  The project is not located in a schedule V area;  There is no presence of Scheduled Tribes in the block and district in which the project is located;  No tribal land has been procured for the project;  No livelihood dependence on the land has been reported of tribal or non-tribal; and  With regards to ethnic composition, only 3 (0.17 %) out of the total population of 1,732 in Radhanesda village are Scheduled Castes (SC), as per the Census of India Report 2011. No presence of Scheduled Tribes (ST) is recorded in the village. 8. PS8 – Cultural Heritage NOT APPLICABLE For the purposes of this Performance Standard, cultural heritage refers to tangible forms of cultural heritage, such as tangible moveable or immovable objects, property, sites, structures, or groups of structures, having archaeological (prehistoric), paleontological, historical, cultural, artistic, and religious values. The PS is not applicable to the project as;  The land on which the project is being setup does not contain any structures bearing cultural, historical, religious or spiritual significance; and No sites bearing cultural, historical, religious or spiritual significance has been impacted by the project

3.5.3 IFC EHS Guidelines IFC has released the following environmental, health and safety guidelines on 30th April 2007:

 Environmental, Health, and Safety General Guidelines

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 Environmental, Health, and Safety Guidelines for Electric Power Transmission and Distribution issued on 30th April 2007.

The key requirements stated in the EHS guidelines have been discussed in below.

ENVIRONMENTAL ATTRIBUTES

 Air Emissions and Ambient Air Quality,  Energy Conservation,

 Wastewater and Water Quality,  Water Conservation,  Hazardous Materials Management,  Waste Management,

 Noise and  Contaminated Land

OCCUPATIONAL HEALTH AND SAFETY

 General Facility Design and Operation,  Communication and Training,  Physical/Chemical/Biological Hazards,  Personal Protective Equipment (PPE) and

 Monitoring.

COMMUNITY HEALTH AND SAFETY

 Water Quality and Availability,  Structural Safety of Project Infrastructure,

 Life and Fire Safety (L&FS),  Traffic Safety,  Transport of Hazardous Materials,  Disease Prevention and

 Emergency Preparedness and Response.

CONSTRUCTION AND DECOMMISSIONING

 Environment Baseline environmental,

 Occupational Health and Safety and  Community Health and Safety.

3.5.4 Equator Principles, 2020 The Equator Principles Financial Institutions (EPFIs), have adopted the Equator Principles in order to ensure that the Projects financed by them are developed in a manner that is socially responsible and reflects sound environmental management practices. Equator Principles are a set of principles aiming towards promotion of responsible environmental stewardship and socially responsible development, including fulfilling responsibility to respect human rights by undertaking due diligence. The Principles are intended to serve as a common baseline and framework, globally for all sectors. All the Principles were noted applicable to the project. Additionally, a gap analysis for the project has been taken against the Equator Principles to assess the compliance.

Principle 1: Review and Categorisation

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Using categorisation, the EPFI’s environmental and social due diligence is commensurate with the nature, scale and stage of the Project, and with the level of environmental and social risks and impacts. The categories are:

Category A – Projects with potential significant adverse environmental and social risks and/or impacts those are diverse, irreversible or unprecedented;

Category B – Projects with potential limited adverse environmental and social risks and/or impacts that are few in number, generally site-specific, largely reversible and readily addressed through mitigation measures; and

Category C – Projects with minimal or no adverse environmental and social risks and/or impacts.

Principle 2: Environmental and Social Assessment

For all Category A and Category B Projects, the EPFI will require the client to conduct an Assessment process to address, the relevant environmental impacts of the proposed Project. The Assessment documentation should propose measures to minimise, mitigate, and offset adverse impacts in a manner relevant and appropriate to the nature and scale of the proposed Project. The client is expected to include assessments of potential adverse Human Rights impacts and climate change risks as part of the ESIA or other Assessment, with these included in the Assessment Documentation. The client should refer to the UNGPs when assessing Human Rights risks and impacts, and the Climate Change Risk Assessment should be aligned with Climate Physical Risk and Climate Transition Risk categories of the TCFD.

Principle 3: Applicable Environmental and Social Standards

The Assessment process should, in the first instance, address compliance with relevant host country laws, regulations and permits that pertain to environmental and social issues. India being a Non-Designated Country, the Assessment process evaluates compliance with the then applicable IFC Performance Standards on Environmental and Social Sustainability (Performance Standards) and the World Bank Group Environmental, Health and Safety Guidelines (EHS Guidelines).

Principle 4: Environmental and Social Management System and Equator Principles Action Plan

For all Category A and Category B Projects, the EPFI will require the client to develop or maintain an Environmental and Social Management System (ESMS). Further, an Environmental and Social Management Plan (ESMP) will be prepared by the client to address issues raised in the Assessment process and incorporate actions required to comply with the applicable standards.

Principle 5: Stakeholder Engagement

The EPFI will require the client to demonstrate effective Stakeholder Engagement as an on-going process in a structured and culturally appropriate manner for all Category A and Category B Projects. The client will conduct an Informed Consultation and Participation process. The consultation process will be tailored to the risks and impacts of the Project; the Project’s phase of development; the language preferences of the Affected Communities; their decision-making processes; and the needs of disadvantaged and vulnerable groups.

To facilitate Stakeholder Engagement, the client will, commensurate to the Project’s risks and impacts, make the appropriate Assessment Documentation readily available to the Affected Communities, and where relevant Other Stakeholders, in the local language and in a culturally appropriate manner.

Principle 6: Grievance Mechanism

For all Category A Projects, and as appropriate Category B projects the EPFI will require the client, as part of the ESMS, to establish a grievance mechanism designed to receive and facilitate resolution of concerns and grievances about the Project’s environmental and social performance.

Principle 7: Independent Review

For all Category A Projects and as appropriate Category B projects, an Independent Environmental and Social Consultant, not directly associated with the client, will carry out an Independent Review of the Assessment Documentation including the ESMPs, the ESMS, and the Stakeholder Engagement process documentation in order to assist the EPFI's due diligence, and assess Equator Principles compliance.

Principle 8: Covenants

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For all Projects, the client will covenant in the financing documentation to comply with all relevant host country environmental and social laws, regulations and permits in all material respects. For all Category A and Category B Projects, Equator Principles requires that the covenants cover the commitment of the client to comply with the ESMPs, EPAP during construction and operation phase and report on this compliance to the Lenders in an agreed format.

Principle 9: Independent Monitoring and Reporting

For Projects where an Independent Review is required under Principle 7, the EPFI will require the appointment of an Independent Environmental and Social Consultant after Financial Close or require that the client retain qualified and experienced external experts to verify its monitoring information which would be shared with the EPFI.

Principle 10: Reporting and Transparency

For all Category A Projects and as appropriate Category B projects:

 The client will ensure that, at a minimum, a summary of the ESIA is accessible and available online.

 The client will publicly report GHG emission levels during the operational phase for Projects emitting over 100,000 tonnes of CO2 equivalent annually.

 The EPFI will encourage the client to share commercially non-sensitive Project-specific biodiversity data with the Global Biodiversity Information Facility13 (GBIF) and relevant national and global data repositories, using formats and conditions to enable such data to be accessed and re-used in future decisions and research applications.

3.5.5 Applicability of ADB SPS An overview of ADB’s Safeguard Policy Statement (SPS) and their applicability to the project is provided in the table below.

Table 3-6: Broad Overview ADB SPS and their applicability to the Project

S. No. ADB’s Policy/SPS Overview Applicability to the Project

1. SPS 1: Environment The Environmental safeguards are triggered if a Applicable project is likely to have potential environmental risks and impacts. The projects are initially This SPS is applicable to screened to determine the level of assessment environmental aspects like but not that is required. ADB categorises the projects into limited to air emissions, water and three project categories based on the severity, wastewater management, noise sensitivity and the magnitude of its potential emissions, chemical management, environmental impacts: Category A (if the project hazardous material management. likely to have significant adverse environmental impacts that are irreversible, diverse, or unprecedented. An environmental impact assessment (EIA), including an environmental management plan (EMP), is required); Category B (if the project likely to have potential impacts are less adverse than category A and minor impacts expected can be mitigated. An initial environmental examination (IEE), including an EMP, is required); and Category C (if the projects likely to have minimal or no adverse environmental impacts. An EIA or IEE is not required).

2. SPS 2: Involuntary The policy is designed to avoid the risk of Not Applicable. Resettlement impoverishment among those displaced as a direct result of ADB investment. The policy The entire land on which the recognizes that restoring the incomes and living project is located is situated has standards of the affected people is complex, and been leased from the GPCL.

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requires a development strategy that Procurement of the said land was encompasses compensation, resettlement and done by the GPCL from the rehabilitation packages to improve, or at least government. During the restore, their social and economic base. consultations, it was reported that no habitations were present on the The ADB’s Policy on Involuntary Resettlement land and the land has been stipulates three important elements in involuntary historically owned only by resettlement: (i) compensation for lost assets and government. Thus, it can be loss of livelihood and income, (ii) assistance in concluded that project specific relocation including provision of relocation sites land procurement has not resulted with appropriate facilities and services, and (iii) in any involuntary resettlements. assistance with rehabilitation to achieve at least the same level of well-being with the project as before.

3. SPS 3: Indigenous The Policy on Indigenous Peoples is triggered if a Not applicable People project directly or indirectly affects the dignity, human rights, livelihood systems, or culture of The region where the project is indigenous peoples or affects the territories or located does not fall under the natural or cultural resources that indigenous Schedule V area and does not peoples own, use, occupy, or claim as an have any significant presence of ancestral domain or asset. The policy on states tribal communities. The same was that the borrower/ client will ensure (i) that confirmed through community affected indigenous peoples receive culturally consultations. Based on the above appropriate social and economic benefits; and (ii) inferences, it can be presumed that when potential adverse impacts on that no indigenous people would indigenous peoples are identified, these will be have been affected due to project avoided to the maximum extent possible. Where activities. this avoidance is not feasible, based on meaningful consultation with indigenous communities, the Indigenous Peoples Plan (IPP) will be prepared which outlines measures to minimize, mitigate, and compensate for the adverse impacts.

4. Policy on Gender and ADB’s Policy on Gender and Development (2006) Applicable Development is the guiding framework for gender and development activities. The policy adopts gender This policy is applicable to social mainstreaming as the key strategy for promoting aspects such as recruitment and gender equality and women’s empowerment selection, terms of employment, across the ADB funded projects. The Policy on equal opportunity and non- Gender and Development (GAD) is guiding discrimination, parity in salary/ document to ensure that their needs and wages etc. concerns are addressed and that gender issues in resettlement are mitigated. The policy adopts gender mainstreaming as a key strategy for promoting gender equity, and for ensuring that women participate and that their needs are explicitly addressed in the decision-making process.

3.5.6 Applicable International Conventions Environmental problems which migrate beyond the jurisdiction (Trans-boundary) require power to control such issues through international co-operation by either becoming a Contracting Party (CP) i.e. ratifying treaties or as a Signatory by officially signing the treaties and agreeing to carry out provisions of various treaties on environment and social safeguards. The relevant international conventions are as provided in Table 3-7.

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Table 3-7 Relevant International Conventions

S. N. International Conventions Salient Features 1. Montreal Protocol on Substances India signed the Montreal Protocol along with its London Amendment on 17- That Deplete the Ozone Layer (and 9-1992 and also ratified the Copenhagen, Montreal and Beijing Amendments subsequent Amendments) on 3rd March 2003. 2. Kyoto Protocol The Kyoto protocol was signed by India in August 2002 and ratified in February 2005. The convention pertains to the United Nations framework on Climate Change. The 3rd Conference of the Parties to the Framework Convention on Climate Change (FCCC) in Kyoto in December 1997 introduced the Clean Development Mechanism (CDM) as a new concept for voluntary greenhouse- gas emission reduction agreements between industrialized and developing countries on the project level. 3. International Labour Organization India has also ratified many of the International Labour Organization conventions conventions that are relevant to the Project including: 1. C1 Hours of Work (Industry) Convention, 1919 (14:07:1921, ratified); 2. C5 Minimum Age (Industry) Convention, 1919 (09:09:1955, ratified): 3. C11 Right of Association (Agriculture) Convention, 1921 (11:05:1923, ratified): 4. C14 Weekly Rest (Industry) Convention, 1921 (11:05:1923, ratified); 5. C29 Forced Labour Convention, 1930 (30:11:1954, ratified) & C105 Abolition of Forced Labour Convention, 1957 (18:05:2000, ratified); 6. C100 Equal Remuneration Convention, 1951 (25:09:1958, ratified); 7. C107 Indigenous and Tribal Populations Convention, 1957 8. C111 discrimination (Employment and Occupation) Convention, 1958 (03:06:1960, ratified) 4. UN Guiding principles on Business The United Nations (UN) Guiding Principles on Business and Human Rights and Human Right (GPs), which were endorsed by the Human Rights Council (HRC) in June 2011, are built on three pillars: states’ duty to protect human rights, corporate responsibility to respect human rights, and access to effective remedies. All three pillars of the GPs – especially Pillar 1 and Pillar 3 – require states to take a number of measures to ensure that business enterprises do not violate human rights and that effective remedies are available in cases of violation. The UN Working Group on the issue of human rights and transnational corporations and other business enterprises (UNWG) ‘strongly encourages all states to develop, enact and update’ a national action plan (NAP) on business and human rights (BHR) as part of states’ responsibility to disseminate and implement the GPs. In June 2014, the HRC passed a resolution calling upon states to develop NAPs. As of 29 February 2016, ten states have drawn up NAPs of which India was a party wherein it reaffirms India’s commitments towards realization of human rights and promotion of socially responsible businesses in the country. 5. Convention on Biological Diversity, India is a party to CBD since 1994. The objectives of the CBD are the 1992 (CBD or Rio Convention) conservation of biological diversity, the sustainable use of its components, and the fair and equitable sharing of the benefits arising from commercial and other utilization of genetic resources. The agreement covers all ecosystems, species, and genetic resources. 6. Convention on the Conservation of India is a Party to CMS since 1983. CMS is an intergovernmental treaty Migratory Species of Wild Animals, aimed at conservation and sustainable use of migratory animals and their 1983 (CMS or “Bonn Convention”) habitats. It brings together Range States through which migratory animals pass and lays the legal foundation for internationally coordinated conservation measures throughout a migratory range. Parties strive towards protecting migratory species, conserving or restoring the places where they live, mitigating obstacles to migration and controlling other factors that might endanger them. 7. Convention on Wetlands of India is a Contracting Party to the Ramsar Convention since 1982. It is an International Importance especially as intergovernmental treaty that provides a framework for the conservation and Waterfowl Habitat, 1971 (Ramsar wise use of wetlands and their resources. It includes all lakes and rivers, Convention) underground aquifers, swamps and marshes, wet grasslands, peatlands, oases, estuaries, deltas and tidal flats, mangroves and other coastal areas, coral reefs, and also human-made sites, such as fish ponds, rice paddies, reservoirs and salt pans. Contracting Parties commit to work towards the wise use of all their wetlands, designate suitable wetlands for the list of Wetlands of International Importance (the “Ramsar List”) and ensure their effective management, as well as, cooperate internationally on transboundary wetlands, shared wetland systems and shared species

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S. N. International Conventions Salient Features

8. Convention on International Trade in India is a Party to CITES since 1976. It is an international agreement Endangered Species of Wild Flora between governments aimed at ensuring that international trade in specimens and Fauna, 1975 (CITES) of wild animals and plants does not threaten the survival of such species. Each CITES Party is expected to adapt its domestic legislation to ensure that the CITES framework is implemented at the national level.

9. Convention Concerning the Protection India has been a State Party to the WHC since 1977. The WHC aims to of World Cultural and Natural identify and protect the world's natural and cultural heritage considered to be Heritage, 1972 (UNESCO World of outstanding universal value. State Parties to the WHC are expected Heritage Convention) (WHC). to identify and nominate properties on their national territory to be considered for inscription on the World Heritage List, giving details of how a property is protected and providing a management plan for its upkeep. States Parties are also expected to protect the World Heritage values of the properties inscribed.

10. The Rotterdam Convention on the The Rotterdam Convention on the Prior Informed Consent (PIC) Procedure Prior Informed Consent (PIC) for Certain Hazardous Chemicals & Pesticides in international Trade was Procedure adopted by India at the Conference of Plenipotentiaries at Rotterdam in 1998.

3.6 Categorisation of Project 3.6.1 Classification as per MoEF&CC, India MoEF&CC had brought out notifications in 1989, with the purpose of prohibition/ restriction of operations of certain industries to protect ecologically sensitive Doon Valley. The notification introduced the concept of categorization of industries as “Red”, “Orange “and “Green” with the purpose of facilitating decisions related to location of these industries. Subsequently, the application of this concept was extended in other parts of the country not only for the purpose of location of industries, but also for the purpose of Consent management and formulation of norms related to surveillance / inspection of industries.

According to the Final Document on Revised Classification of Industrial Sectors under Red, Orange, Green White Categories; February 29,2016; Central Pollution Control Board; Table G-5: Final List of White Category of Industries, Sl. No 79 Solar power generation through solar photovoltaic cell, wind power and mini hydel power has been classified under White Category.

 Newly introduced White category contains 36 industrial sectors which are practically non-polluting; and  There shall be no necessity of obtaining the Consent to Operate’’ for White category of industries. An intimation to concerned SPCB / PCC shall suffice6.

3.6.2 Classification as per IFC Performance Standards As part of its review of a project’s expected social and environmental impacts, IFC uses a system of social and environmental categorization. This categorization is used to reflect the size of impacts understood as a result of the client’s social and environmental assessment and to specify IFC’s institutional requirements. The categories used by the IFC are:

1. Category A Projects: Projects with potential significant adverse social or environmental risks or/and impacts that are diverse, irreversible or unprecedented; 2. Category B Projects: Projects with potential limited adverse social or environmental risks or/and impacts that are few in number, generally site-specific, largely reversible and readily addressed through mitigation measures; 3. Category C Projects: Projects with minimal or no adverse social or environmental risks or/and impacts, including certain financial intermediary (FI) projects with minimal or no adverse risks; and 4. Category FI Projects: All FI projects excluding those that are Category C projects.

IFC therefore categorizes the project primarily according to the significance and nature of its impacts. IFC defines the project's area of influence as the primary project site(s) and related facilities that the client (including its contractors) develops or controls; shared facilities that are not funded as part of the project (funding may be

6 Final Document on Revised Classification of Industrial Sectors under Red, Orange, Green White Categories; February 29,2016; Central Pollution Control Board;

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provided separately by a client or a third party including the government), and whose viability and existence depend exclusively on the project and whose goods or services are essential for the successful operation of the project; areas potentially impacted by cumulative impacts from further planned development of the project; and areas potentially affected by impacts from unplanned but predictable developments caused by the project that may occur later or at a different location. The area of influence does not include potential impacts that would occur without the project or independently of the project.

Applying the criteria stipulated by the IFC Policy on Environmental and Social Sustainability for environmental and social categorization of projects, ESPL's proposed 200 MW solar project may be assigned as ‘Category B’ with respect to environmental and social impacts. This is so basis the primary data available to date which indicates that the environmental and social risks and impacts of the proposed project activities are expected to be few in number, generally site-specific, largely reversible, and readily addressed through mitigation measures, which supports the ‘Category B’ classification. Additional rationale for the above categorization is as below:

3.6.3 Project categorisation as per ADB SPS Project Category and Requirements

The ADB SPS along with the ADB Environmental Safeguards, A Good Practice Sourcebook, 2012 clarifies the rationale, scope and content of an environmental assessment and supported by technical guidelines (e.g., Environmental Assessment Guidelines, 2003). Projects are initially screened to determine the level of assessment that is required according to the following three environmental categories (A, B, or C).

 Category A is assigned to projects that normally cause significant or major environmental impacts that are irreversible, diverse or unprecedented such as hydroelectric dams (an Environmental Impact Assessment is required).

 Category B projects have potential adverse impacts that are less adverse than those of category A, are site-specific, largely reversible, and for which mitigation measures can be designed more readily than for category A projects (an Initial Environmental Examination is required).

 Category C projects are likely to have minimal or no negative environmental impacts. An environmental assessment for Category C projects is not required but environmental implications need to be reviewed.

The project has been evaluated considering the environmental (SPS1) categorization of ADB. The adverse environmental and social impacts of the project are considered site-specific and reversible. Therefore, it has been classified as Category B in accordance with ADB’s SPS1 (2009). The rationale for categorisation is as follows:

On the backdrop of the understanding of the categorisation of ADB Projects and based on Involuntary Resettlement impacts and based on the following facts, the proposed Project can be classified as Category C with respect to SPS 2 – Involuntary Resettlement:

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 The proposed Project is being set up on land owned by the Government of Gujarat (GoG) and has been leased to the proponent for a period of 25 years;  The land has not been procured from any private land owners and has been in continuous possession of the GoG for at least a period of more than 60 years i.e. since 1960s;  No livelihood activities apart from some grazing was reported or observed on the proposed Project land parcel; and  No housing structures, habitations or settlements were reported or observed at site during the site visit. The same was confirmed through community consultations and discussions with institutional stakeholders. On the backdrop of the understanding of the categorisation of ADB Projects and based on impacts of IPs and based on the following facts, the proposed Project can be classified as Category C with respect to SPS 3 – IPs:

 The proposed Project will be set up on land owned by the GoG and no acquisition/ procurement of land from private land owners including land parcels owned by IPs is involved in the Project;  IPs do not have any livelihood dependence on the proposed Project land or any customary land rights on the concerned land parcels; and  There are no designated CPRs located within the proposed Project area that are being used by IPs. 3.7 Applicable Environmental Standards 3.7.1 Ambient Air Quality As per the IFC EHS guidelines (April 2007), “the ambient air quality standards are ambient air quality levels established and published through national legislative and regulatory processes and ambient quality guidelines refer to ambient quality levels primarily developed through clinical, toxicological, and epidemiological evidence (such as those published by the World Health Organization)”. National Ambient Air Quality Standards (NAAQS), as notified under Environment (Protection) Rules 1986 and revised through Environment (Protection) Seventh Amendment Rules, 2009 are given Table 3-8:

Table 3-8: National Ambient Air Quality Standards

Pollutant Time Weighted Concentration in Ambient Air Average Industrial, Residential, Ecologically Sensitive Rural and other Areas Area (notified by Central Government)

3 Sulphur Dioxide (SO2), µg/m Annual* 50 20

24 Hours** 80 80

3 Nitrogen Dioxide (NO2), µg/m Annual* 40 30

24 Hours** 80 80 Particulate Matter (size less than 10 Annual* 60 60 3 µm) or PM10, µg/m 24 Hours** 100 100

Particulate Matter (size less than 2.5 Annual* 40 40 3 µm) or PM 2.5, µg/m 24 Hours** 60 60

3 Ozone (O3), µg/m 8 Hours** 100 100

1 Hour** 180 180

Lead (Pb), µg/m3 Annual* 0.5 0.5

24 Hours** 1 1

Carbon Monoxide (CO), mg/m3 8 Hours** 2 2

1 Hour** 4 4

3 Ammonia (NH3), µg/m Annual* 100 100

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Pollutant Time Weighted Concentration in Ambient Air Average Industrial, Residential, Ecologically Sensitive Rural and other Areas Area (notified by Central Government)

24 Hours** 400 400

3 Benzene (C6H6), µg/m Annual* 5 5

Benzo (O) Pyrene (BaP), particulate Annual* 1 1 phase only, ng/m3

Arsenic (As), ng/m3 Annual* 6 6

Nickel (Ni), ng/m3 Annual* 20 20 *Annual arithmetic mean of minimum 104 measurements in a year taken twice a week, 24 hourly at uniform interval

**24 hourly or 8 hourly or 1 hourly value as applicable shall be complied with 98% of the time in a year. 2% of the time they may exceed, but not on 2 consecutive days. Note: Whenever and wherever monitoring results on two consecutive days of monitoring exceed the limits specified above for the respective category, it shall be considered adequate reason to institute regular or continuous monitoring and further investigation.

3.7.2 Ambient Noise Standards

As per the EHS guidelines of IFC, for residential, institutional and educational area, the one hourly equivalent noise level (Leq hourly) for day time (6.00 a.m. to 10.00 p.m.) is 55 dB (A) while the Leq hourly for night time (10.00 p.m. to 6.00 a.m.) is prescribed as 45 dB (A). Noise standards notified by the MoEF&CC vide gazette notification dated 14th February 2000 based on the A- weighted equivalent noise level (Leq) are as presented in Table 3-9.

Table 3-9: Ambient Noise Standards

Area Code Category of Area Limits in dB(A) Leq

Day time Night Time

A Industrial Area 75 70

B Commercial Area 65 55

C Residential Area 55 45

D Silence Zone* 50 40

*Silence zone is defined as area up to 100 m around premises of hospitals, educational institutions and courts. Use of vehicle horns, loud speakers and bursting of crackers are banned in these zones.

3.7.3 Noise Standards for Occupational Exposure Noise standards in the work environment are specified by Occupational Safety and Health Administration (OSHA- USA) which in turn are being enforced by Government of India through model rules framed under the Factories Act.

Table 3-10: Standards for Occupational Noise Exposure

Total Time of Exposure per Day in Hours Sound Pressure Level in (Continuous or Short-term Exposure) dB(A)

8 90

6 92

4 95

3 97

2 100

3/2 102

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Total Time of Exposure per Day in Hours Sound Pressure Level in (Continuous or Short-term Exposure) dB(A)

1 105

¾ 107

½ 110

¼ 115

Never >115 No exposure in excess of 115 dB (A) is to be permitted.

For any period of exposure falling in between any figure and the next higher or lower figure as indicated in column (1), the permissible level is to be determined by extrapolation on a proportionate scale.

3.7.4 Water Quality Standards The designated best use classification as prescribed by CPCB for surface water is as given in Table 3-11.

Table 3-11: Primary Water Quality Criteria for Designated Best Use Classes

Designated-Best-Use Class Criteria

Drinking Water Source without A  Total Coliforms Organism MPN/100ml shall be 50 or less conventional treatment but after  pH between 6.5 and 8.5 disinfection  Dissolved Oxygen 6mg/l or more  Biochemical Oxygen Demand 5 days 20°C 2mg/l or less

Outdoor bathing (Organised) B  Total Coliforms Organism MPN/100ml shall be 500 or less  pH between 6.5 and 8.5  Dissolved Oxygen 5mg/l or more  Biochemical Oxygen Demand 5 days 20°C 3mg/l or less

Drinking water source after conventional C  Total Coliforms Organism MPN/100ml shall be 5000 or less treatment and disinfection  pH between 6 to 9  Dissolved Oxygen 4mg/l or more  Biochemical Oxygen Demand 5 days 20°C 3mg/l or less

Propagation of Wild life and Fisheries D  pH between 6.5 to 8.5  Dissolved Oxygen 4mg/l or more  Free Ammonia (as N) 1.2 mg/l or less

Irrigation, Industrial Cooling, Controlled E  pH between 6.0 to 8.5 Waste disposal  Electrical Conductivity at 25°C micro mhos/cm Max.2250  Sodium absorption Ratio Max. 26  Boron Max. 2mg/l

Below-E  Not Meeting A, B, C, D & E Criteria Source: Central Pollution Control Board

As per the IFC EHS guidelines, the treated sewage discharge is required to meet the following guidelines.

Table 3-12: Treated sewage discharge guidelines as per IFC

S. No. Parameter Guideline Value

1. pH 6-9

2. BOD 30mg/l

3. COD 125 mg/l 4. Total Nitrogen 125 mg/l

5. Oil and Grease 10 mg/l

6. Total Suspended Solids 50 mg/l

7. Total coliform bacteria 400 MPN/100 ml

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4. Environmental and Socio- Economic Baseline

This section of the report presents information on the baseline condition of the physical, chemical, biological and social environment within the project area.

Primary baseline information was collected on site from project area and area of influence. Existing information sourced from scientific literature (both published and unpublished), engineering studies, technical reports and community socio-economic studies were used wherever available. Activities that facilitated establishment of the baseline data in the report include: site survey, ecological survey, social consultations and interviews, environmental monitoring, processing of satellite imagery and secondary data review from established sources such as Indian Meteorological Department (IMD) and Census of India amongst others. 4.1 Environmental Baseline Area in the 5-kilometre (km) radius from the project is considered as AoI of the project, for primary data collection. AoI covers project area, area traversed by project transmission line and substation. Nearby villages (sensitive receptors) which fall under AoI are Radhanesda village and Kundaliya village. Primary data was collected for one (01) week duration for the month of January 2020. Environmental monitoring was undertaken for ambient air quality, ground water quality, ambient noise levels, soil quality and traffic survey. Parameters monitored under environmental aspects are given in Table 4-1. One (01) time samples for ground water and soil were collected for analysis. Two (02) times monitoring for air samples was conducted in a week, and 24 hours continuous ambient noise data was collected on site.

Table 4-1: Environmental Parameters Monitored for Baseline Data Collection

S. No. Aspect Details

1. Micro-Meteorology Available information on meteorology for the area representative of the site was collected from Meteorology Department. Setting up an automatic micro-meteorological station with data logging facility at the site for continuous monitoring for micro-meteorological parameters like ambient temperature, wind direction, wind speed, relative humidity, cloud cover and rainfall for one (12) week was undertaken.

2. Ambient Air Quality Information on ambient air quality was collected through monitoring of ambient air quality for one (01) week per location for parameters such as Particulate Matter (PM-10), PM-2.5, Oxides of Nitrogen (NOx), Sulphur Dioxide (SO2), O3, Ammonia, CO, Lead, Benzene, Benzo Alpha Pyrene, Arsenic, Nickel.

3. Water Quality Ground water samples were collected for analyses of following parameters: - Organoleptic and physical parameters: Colour, Odour, pH, Taste, Turbidity, Total Dissolved Solids (TDS), Electrical Conductivity (EC); and - General parameters: Total Hardness, Total Alkalinity, Aluminium (as Al), Ammonia, Anionic detergents (as MBAS), Barium (as Ba), Boron (as B), Calcium (as Ca), Free residual Chlorine (as Cl2), Chloramines, Chloride (as Cl), Copper (as Cu), Fluoride (as F), Iron (as Fe), Magnesium (as Mg), Manganese (as Mn), Nitrate (as NO3), Phosphorus (as 2- P), Selenium (as Se), Silver (as Ag), Sulphate (as SO4), Sulphide (as S ), Zinc (as Zn), Cadmium (as Cd), Cyanide (as CN), Lead (as Pb), Mercury (as Hg), Molybdenum (as Mo), Nickel (as Ni), Pesticides, Polychlorinated Biphenyls, Total arsenic (as As), Total chromium (as Cr), Phenolic Compounds, Mineral Oil, PAHs.

4. Soil Quality Soil samples were collected and analysed for the following parameters: - Physical Parameters: Particle Size Distribution, Texture, pH, and Permeability, Porosity, Electrical Conductivity, etc.; and - Chemical Parameters: Total Nitrogen, Phosphorus, Sodium, Potassium, Cation Exchange Capacity.

5. Ambient Noise Ambient noise quality was monitored to determine hourly equivalent noise levels. The noise Quality sampling will be done once during the study period continuously for 24 hours, selected on the basis of the site sensitivities within the study area. The results of the findings were analysed to work out Leq hourly, Leq day and Leq night.

Environmental monitoring locations have been represented in Table 4-2 and Figure 4-1.

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Figure 4-1: Map showing Environment and Traffic Monitoring Locations

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Table 4-2: Environmental Monitoring Locations

S. Aspect Monitoring Latitude/Longitude Monitoring Direction from the Rationale No. Location/ Location project site Code

1. Ambient Air AAQ 1 24° 30.803'N Site Boundary South west boundary Baseline air quality 71° 15.404'E of site at project site (Downwind of site)

AAQ 2 24°32'19.4"N Habitation near East of the project Nearest Sensitive 71°16'55.7"E project site (3-4 receptor (Upwind of households) site)

AAQ 3 24° 32.161'N Empty land North of project site Crosswind to project 71° 18.221'E parcels near site site

2. Ground Water GW 1 24° 30.803'N Project site Project site Monitoring of ground 71° 15.404'E water quality in the project area

3. Ambient Noise NQ 1 24° 30.803'N Site Boundary South west boundary Noise level at project 71° 15.404'E of site site

NQ 2 24°32'19.4"N Habitation near East of the project Nearest Sensitive 71°16'55.7"E project site receptor

NQ 3 24° 32.161'N Empty land North of project site Noise level near 71° 18.221'E parcels near site project area

4. Soil Quality SQ 1 24° 30.803'N Within project Project Area Soil quality of Project 71° 15.404'E boundary Area

SQ 2 24° 32.427'N Near east East of the project Baseline Soil Quality 71° 17.717'E boundary of site site of Surrounding Area.

5. Traffic Survey TM 1 24° 32.895'N Intersection of East of the project Access road to be 71° 22.620'E State Highway site used for carrying (SH) 132 and construction village road equipment and material

4.1.1 Physiography The district can be divided in three (3) main parts – the hilly- mountainous region having high relief and rugged topography covering parts of Dhanera, Palanpur, Vadgaon and entire Danta taluka in the east, the piedmont zone all along the periphery of hilly area, and west and southwest of River Banas the area is flat plain with occasional undulations given rise to by sand dunes and mounds in the west. The western extension of this plain merges into the marshy area of Rann of Kutch.

Geomorphologically the district can be divided into six sub micro regions on the basis of physiography, climate, geology, soils and natural vegetation. a) Vav Sandy Plain: It is mostly sandy plain with an altitude of 100 m above mean sea level. There are a few small channels, which merge into little Rann of Kutch. Geologically, area is composed of Alluvium, blown sand etc. b) Sandy Plain: The region mainly extends over the north and north western parts of the district bounded by the state of Rajasthan in the north, Banas valley in the east and south and Vav sandy plain in west. The region has the sloppy gradient, towards the west in which the river Sukal flows. Geologically area is composed of Alluvium, blown sand etc. c) Banas Valley: This region extends over the central and south-western part of the district, it is mainly formed by the Banas River which flows in south-westerly direction and ultimately merges into Rann of Kutch. Northern part of this region is high in elevation than the south and western portions. Geologically area is composed predominantly of Alluvium, blown sand etc. d) Banskantha Aravalli Range: The region spreads over the eastern part of Banaskantha district, occupying Danta and part of Palanpur and small area of Vadgaon talukas. It is bounded by the state of Rajasthan from

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north, Banas Valley from west, Mehsana district from south and Sabarkantha district from east. This region is highly elevated ranging between 100 and 300 m above mean sea level. Saraswati River is the main river of the region. Geologically area is composed Alluvium, blown sand etc. e) Jasor Chhotila Hills: The region lies in Dhanera and Palanpur taluks and is enclosed by the state of Rajasthan from three sides while Banaskantha Aravalli range makes its limit in the south. It is actually disrupted part of Aravalli range by the Banas valley. It is an undulating terrain with an elevation of 300 m above mean sea level and is covered by forest. Geologically this region is mainly composed of Eranpura granite formation. f) Umardasi – Sarawati Plain: This region mainly extends over the south –eastern part of Banskantha district covering the taluks of Palanpur and Vadgaon. It is bounded by Banas valley in the west and north, Banaskantha Aravalli range in the east and Mehsana district in the south. This region is formed by the Umardasi and Saraswati River and having an elevation of 100 m above mean sea level. Geologically, area is composed of alluvium, blown sand etc.

4.1.2 Geology Geologically, the area consists chiefly of representatives of the Aravalli system, Delhi system (Ajabgadh series), Intrusive in the Delhi system and the recent deposits. Recent includes Alluvium, blown sand, river gravels. Gligoclase - dolerite dykes. Intrusive include Gabbros and dolerite Pluys, Erinpura granite— and pegmatite. Epidiorites and hornblende - Schists.

The Geological Map of the Gujarat State is represented in the Figure 4-2 below.

Figure 4-2: Geological Map of Gujarat State Source: Narmada, Water Resources, Water Supply and Kalpsar Department, Gujarat

4.1.3 Drainage The drainage network in the district is constituted mainly by the Banas and Saraswati rivers and their tributaries. In the extreme east, Sabarmati river forms district boundary with Sabarkantha district and in part controls the drainage network of the hilly area east of Danta. Other important rivers passing through or originating from the district are Arjuni, Sipu, Balaram, Khari, Khapra, Kalari, Gujudi, Dholka, Umardashi, Chekaria, Selvam, Rel, Ravi

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and Sirinala. Since the district experiences a semi-arid type of climate, the rivers flowing through it are of ephemeral nature i.e. have water during monsoon only and dry up after monsoon. Some of the rivers like Banas and Saraswati, however, carry fairly good amount of water during rainy season. Most of the rivers have south and south westerly flow directions. There are few important lakes in the district i.e. Ganga Saragar near Jethi Village in Palanpur taluka, Man Sarovar near Chitrasani village and Dantiwala lake constructed near Dantiwada Dam. Various canals drawn from the lakes irrigate the land of the district.

During rainfall, water just stands over ground at the site due to absence of natural drainage channels and also due to existence of several bunds in vicinity of Radhanesda village and Kundalia village. These bunds have been constructed to conserve rain water and to check the ingress of salt water from surrounding area. Thus, depth of flooding could be 310 mm (nearly one feet) for a 50-year return period storm rainfall of 24-hour duration at the site.7 Earth filling in the solar power park is necessary so as to raise the ground level and thus protect the area from flooding. Raising the ground level by earth filling is also required to lay internal drainage channels with adequate slope for conveying stormwater safely to the outlets on boundary of the solar park. This has been recommended in the hydrological study undertaken by IIT, Roorkee in August 2016.

The drainage map of the project site has been represented below in the Figure 4-3.

7 As per the Hydrological study of the Radhanesda Solar Park conducted by IIT Roorkee in August 2019

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Figure 4-3: Map representing Drainage within 5 km radius of site

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4.1.4 Land use and Land Cover The total land in the district was 10,743 sq. km during 2009-2010. As per the District Census Handbook, Banas Kantha (2011), in the district 7.61% area is covered under the forest area, 38.56% is covered under the irrigation and 30.59% area is un-irrigated.

The district comes under Western Plain, Kachchh And Part of Kathia zone ICAR. A major part of the district grows food crops which are less remunerative. The main kharif crops in the district are bajri, jowar, moong, math, tal, rapeseed etc. and main Rabi crop is Wheat. The land use pattern of the district has been provided in the Table 4- 3 below:

Table 4-3: Landuse classification of Banaskantha district

S. No. Classification Area (in hectares) % Coverage

1. Forests 77657.54 7.61

2. Area Under Non-Agriculture Uses 40543.98 3.97

3. Barren and Un-cultivable Land 36216.5 3.55

4. Permanent pastures and Other Grazing Lands 79331.38 7.77

5. Land Under Miscellaneous Tree Crops etc. 7671.77 0.75

6. Cultivable Waste Land 36294.1 3.56

7. Fallow Lands other than Current Fallows 17458.49 1.71

8. Current Fallows 19708.8 1.93

9. Net Area Shown 705818.72 69.15 Source: District Census Handbook, Banas Kantha (2011)

Total geographical area of the Radhanesda village, where the project site falls is 844.61 hectares.

The Project site specific Land use within 5 km radius of the proposed project site and the land use of the project site has been presented in the following Table 4-4 and Figure 4-4.

Table 4-4: Land use specific to Project Area and Site

S. No. Land use Type Land use within 5 km radius of Land use of Project Site Project Site

Area in Sq. km % of the total Area in Sq. km % of the total area area

1. Barren/Salt affected Land 3.07 13.97 - -

2. Barren/Scrub land 2.85 13.97 1.11 31.88

3. Fallow Agricultural Land 4.91 13.97 0.24 6.94

4. Rann 115.01 13.97 2.00 57.38

5. Wetland/Swamp 1.64 13.97 - -

6. Agricultural Land 13.97 9.88 0.13 3.80

Total Area in sq. km. 141.46 100 3.48 100.00

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Figure 4-4: Map showing Landuse within 5 km radius of the Proposed Project site

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Figure 4-5: Map showing Land use of the Proposed Project site

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4.1.5 Soil Types The soils of Banaskantha district can be classified into three (3) categories, viz., alluvial sandy soils, sandy loams and black soils. The alluvial soils are found in the western parts of the district beyond the rivers Sipu and Banas in the talukas of Tharad, Vav, Deodar, Santalpur, Radhanpur and western parts of Dhanera, Deesa and Kankrej. They are deep sandy with very little organic content. The sand is coarse at places and does not retain moisture. These soils are basically saline and can yield crops only under optimum rainfall conditions.

The soils of the district are derived mainly from sand stones. They are sandy, porous, well-drained and easy to work with implements. Parts of Danta, Amirgath and Palanpur talukas consist of sandy loam soils having scattered blackish patches. In parts of Vav and Deodar talukas, soils are saline as can be seen in the Figure below. On the whole, because of its good sum-soil drainage the capacity of the soil to retain moisture is very poor. This adds to regular droughts, which make the growth of vegetation more and difficult.

The site is covered with saline tract of brownish grey silt, clay, sand, and murram at depth. Map representing the type of soil in Gujarat state is presented in the Figure 4-6 below.

Figure 4-6: Soil Map of Gujarat State

4.1.6 Hydrogeology Precambrian hard rocks, semi-consolidated Mesozoic and tertiary formations and unconsolidated quaternary alluvial deposits form multi-layer aquifer system in the district. Groundwater occurs both under phreatic and confined conditions, however its development is restricted depending upon the aquifer geometry and yield characteristic of individual aquifer and/or ground water quality of the formation water. The north-eastern part of the district is mainly occupied by metasediments and Post Delhi intrusive. The occurrence and movement of ground water is governed by secondary porosity i.e. thickness and extent of weathering and size and interconnections of fractures/joints.

Northern and central parts of the north Gujarat including major part of the Banaskantha district is underlain by post Miocene alluvium and older semi consolidated Mesozoic and Tertiary sedimentary formations. These

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sedimentary formations form the most prolific multi-aquifer system comprising several confined aquifers; these sediments are mainly consisted of Coarse sand, gravel, kankar, silt, clay and clay stones. Groundwater occurs both under phreatic and confined conditions in arenaceous horizons within sedimentary. The occurrence and movement of groundwater is mainly controlled by intergranular pore spaces. The lower units comprising a few hundred meters of alternating sand and clay beds form confine aquifer system.

Confined aquifers in this area have been broadly grouped into, first confined (shallow) aquifer ranging in depth from 80 to 160 m bgl and the second confined aquifer (deep) ranging in depth from 155 to 275 m bgl. These aquifers extend from the foothill of the Aravalli in the northeast to the little Rann of Kutch in the west. The Miocene aquifers are mainly fine to medium grained sand, sandstone interbedded with clay, clay stone and siltstone.

As per CGWB classification, project area lies in ‘Saline’ ground water zonation. Ground water in the project area was informed to be highly saline and available at shallow depth of 1-2 m below ground level.

The hydrogeological map of Banaskantha district is presented in the Figure 4-7 below.

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Figure 4-7: Hydrogeological map of Banaskantha district

4.1.7 Climate and Meteorology The climate of the district is sub-tropical monsoon type and falls under semi-arid region. Climate in the district is characterised by the hot summer and dryness in the non-rainy seasons. The year is marked by four distinct seasons i.e. cold from December to February followed by the hot season from March to May (mid-June). The south-west monsoon season is from mid-June to mid-September and Post monsoon season is from mid- September to end of October. May is the hottest month with mean daily maximum temperature of 41°C. January is the coldest month in which the mean daily minimum temperature of 9.8°C recorded in 1998.

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Except during the monsoon season when the humidity is between 60 percent and 85 percent, the average humidity is low during the year. The driest part of the year is the cold and summer seasons when the relative humidity in the afternoons are less than 30 per cent. 4.1.7.1 Rainfall The south-west monsoon season is from mid-June to mid-September and post monsoon season is from mid- September to end of October. In general, monsoons are warm and moderately humid. Annual rainfall of the district is 578.8 mm. The annual rainfall is received during the south-west monsoon season from June to September, July being the month with the highest rainfall.

Recent data for last five (05) years collected from India Meteorological Department (IMD), Banaskantha shows large variation in rainfall as shown in Table 4-5.

Table 4-5: Average Annual Rainfall (in mm) for Banaskantha District

Year Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec 2014 3.4 0.0 0.0 0.0 5.7 3.7 152.1 87.9 277.2 0.0 0.0 0.0 2015 2.1 0.0 2.4 6.8 0.0 50.9 712. 32.6 27.9 0.0 0.0 0.0 2016 0.0 0.0 0.0 0.0 0.0 19.9 114.8 233.4 20.2 78.3 0.0 0.0 2017 0.0 0.0 0.0 0.1 0.3 76.8 939.7 95.0 25.3 0.0 0.0 0.6 2018 0.0 0.0 0.0 0.0 0.0 32.1 123.0 54.3 5.1 0.0 0.0 0.0 Source: IMD (http://hydro.imd.gov.in/hydrometweb/(S(rzx21qm1n5eyvwabunouztag))/DistrictRaifall.aspx)

4.1.7.2 Wind Speed

Winds are generally light to moderate with some increase in strength in the latter part of summer and early part of the monsoon season. In the period from April to September, winds blow mostly from directions between south and west, south to westerly predominating. Winds are light and variable in direction and in October, easterlies and north-easterlies being more common in mornings and westerly and north-westerly in the afternoons. From November to March, while morning winds are mostly from directions between north and east, the afternoon winds are generally from directions between west and north. Some of the depressions during July and August, originating in the Bay of Bengal move in a westerly or west-north-westerly direction and reach the district or its neighbourhood during the last stages of their travel and cause heavy rain and gusty winds. Thunderstorms occur in the latter half of the summer and early part-of the southwest monsoon season.

4.1.8 Natural Hazards 4.1.8.1 Wind Hazard Banaskantha is prone to wind and cyclone hazard, and lie in high damage risk zone, with wind speed of 47 meter per second (m/s) as seen in the Figure 4-8 below.

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Figure 4-8: Wind Hazard map of Gujarat state

Source: BMTPC, Third Edition (2019)

4.1.8.2 Seismicity

Earthquake risk is very high in Gujarat and the State has suffered major earthquakes in 1819, 1845, 1847, 1848, 1864, 1903, 1938, 1956 and 2001 (i.e. 9 times in past 200 years). The 2001 Kutch earthquake was the third largest and second most destructive earthquake in India over the last two centuries.

The proposed project site in Vav Taluka in Banaskantha district falls under High Risk Seismic Zone – IV (MSK VIII) and can be seen in the Figure 4-9 below:

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Figure 4-9: Earthquake Hazard Map of Gujarat state

Source: Gujarat State Disaster Management Authority (GSDMA)

4.2 Air, Water, Noise and Soil Baseline In order to evaluate the environmental quality in the study area, monitoring was carried out for one (1) week in the month of January 2020 at all the identified locations during site survey by an external laboratory, M/s CEG Test House And Research Centre Private Limited, which is accredited to National Accreditation Board for Testing and Calibration Laboratories (NABL) in accordance with ISO/IEC 17025:2005.

4.2.1 Ambient Air Quality Solar power projects in particular do not cause any emissions during its operation phase and fugitive dust emissions are witnessed during construction phase of the project due to construction activities and vehicular movement.

Ambient air was monitored in the project area for the month of January to estimate the quality of ambient air around the project site. The air quality was analysed at three (03) locations as mentioned in Table 4-2 to estimate the concentration of primary pollutants in the ambient air. The sampling locations were selected considering the presence of habitation nearby and their accessibility.

The ambient air quality results were compared to the National Ambient Air Quality Standards (NAAQS, 2009) for rural and residential area and the analysis results of air quality have been presented below in the Table 4-6.

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Table 4-6: Results of Ambient Air Monitoring

Pollutant Time Weighted Concentration in AAQ-1 AAQ-2 AAQ-3 Average Ambient Air (Industrial, Residential, Rural and Other Areas)

Sulphur Dioxide (SO2), µg/m3 24 Hours 80 8.28 9.31 9.18

3 Nitrogen Dioxide (NO2), µg/m 24 Hours 80 25.01 23.32 23.12 Particulate Matter (size less than 24 Hours 100 75.75 89.33 70.63 3 10 µm) or PM10, µg/m

Particulate Matter (size less than 24 Hours 60 38.41 43.68 35.66 3 2.5 µm) or PM 2.5, µg/m

3 Ozone (O3), µg/m 8 Hours 100 3.41 2.56 3.79

Lead (Pb), µg/m3 24 Hours 1 0.01 0.03 0.009

Carbon Monoxide (CO), mg/m3 8 Hours 2 0.25 0.50 0.38

3 Ammonia (NH3), µg/m 24 Hours 400 3.95 3.10 4.02

3 Benzene (C6H6), µg/m Annual 5 BDL (<1.0) BDL (<1.0) BDL (<1.0)

Benzo (O) Pyrene (BaP), Annual 1 BDL (<0.5) BDL (<0.5) BDL (<0.5) particulate phase only, ng/m3

Arsenic (As), ng/m3 Annual 6 BDL (<0.5) BDL (<0.5) BDL (<0.5)

Nickel (Ni), ng/m3 Annual 20 2.76 2.18 BDL (<0.5) Source: Laboratory Results, January 2020 BDL: Below Detectable Limit

Inference

The project site is situated in a rural setting and there are no industries and significant emission sources within 5 km radius of the Project Site. The parameters measured for ambient air quality were noted to be well within the permissible limits of the National Ambient Air Quality Standards (NAAQS), as defined by MoEF&CC. PM2.5, PM10, SO2, CO, NH3, Lead and Ozone were detected in all the samples but were noted to be well within the permissible limits. Concentration of Benzene and Benzo (O) Pyrene was not detected at any of the locations.

4.2.2 Ambient Noise Quality Ambient Noise level was monitored continuously for 24 hours at three (03) locations around the project area using Sound Level Meter at the identified receptor locations mentioned in Table 4-2. The noise levels obtained were analysed to arrive at the equivalent continuous noise level (Leq) for day and night time. The day and night time hours ranged from 06:00 to 22:00 hrs and 22:00 to 06:00 hrs respectively.

The sampling locations can be categorised as residential area. Therefore, the results of the ambient noise level monitoring presented in Table 4-7 are compared with National Ambient Air Quality Standards (NAAQS) in respect of noise limits for day time and night time for residential area.

Table 4-7: Results of Ambient Noise level Monitoring

Location Code Noise Standard NQ-1 NQ-2 NQ-3 (Residential Area)

Leq Day dB (A) 55 67.0 54.5 74.4

Leq Night dB (A) 45 60.3 45.4 40.3 Source: Laboratory Results, January 2020

Inference

The ambient noise level at location NQ 1 i.e. near the site boundary was noted to be exceeding the permissible standards of noise levels prescribed by CPCB for day time and night time. The high noise level can be attributed

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to vehicular movements, ground levelling work being undertaken nearby the site and high wind movement on the day of monitoring.

Ambient noise level at NQ 2, i.e. Radhanesda village road was noted to be within permissible limits for the day time. However, noise levels were noted to be exceeding slightly above the permissible limits for night time.

The ambient noise level at location NQ 3 i.e. empty land parcels near the site was noted to be exceeding the permissible standards of noise levels prescribed by CPCB for day time whereas the night time levels were within the permissible limits for noise level. The high noise levels at NQ 2 and NQ 3 can be attributed mainly to the high wind velocity on the day of monitoring and some construction activities being undertaken in the area in and around the Project Site (construction of the boundary wall, shops, etc.).

4.2.3 Water Quality Ground water was noted to be at a depth of 1-2 m below ground level (bgl) at the site and the same was confirmed by the village Sarpanch. However, the ground water was reported to be extremely saline and thus unsuitable for drinking or domestic purposes.

One (01) ground water sample was collected to assess the water quality at site and around the project area. Sample of groundwater was examined for physico-chemical, heavy metals and biological parameters as per standard testing procedures and compared to Drinking Water Standards, IS 10500: 2012.

Table 4-8 presents the results of analysis of the ground water sample which are compared with acceptable and permissible limits as specified in the drinking water standards IS 10500:2012.

Table 4-8: Results of Ground Water and Surface Water Quality Analysis

S. No. Parameters Unit GW1 AL(PL)

1. Colour Hazen <1.0 5 (15)

2. Odour - Agreeable Agreeable

3. Taste - Agreeable Agreeable

4. Turbidity NTU <1.0 1(5)

5. pH - 7.52 6.5-8.5 (NR)

6. Biological Oxygen Demand (BOD) mg/l -

7. Chemical Oxygen Demand (COD) mg/l -

8. Total Dissolved Solids mg/l 2515.0 500 (2000)

9. Total Alkalinity as CaCO3 mg/l 159.58 200 (600)

10. Total Hardness as CaCO3 mg/l 648.90 200 (600)

11. Chloride as Cl mg/l 1250.80 250 (1000)

12. Sulphate as SO4 mg/l 76 200 (600)

13. Fluoride as F mg/l 1.4 200 (600)

14. Nitrate as NO3 mg/l 20.0 250 (1000)

15. Phenolic Compound as C6H5OH mg/l BDL 0.001 (0.002)

16. Sulphide as S2- mg/l BDL 0.05 (NR)

17. Calcium as Ca mg/l 86.69 75 (200)

18. Magnesium as Mg mg/l 105.34 30 (100)

19. Iron as Fe mg/l BDL 0.3 (NR)

20. Mercury as Hg mg/l BDL 0.001 (NR)

21. Cadmium as Cd mg/l BDL 0.003 (NR)

22. Arsenic as As mg/l BDL 0.01 (0.05)

23. Lead as Pb mg/l BDL 0.01 (NR)

24. Manganese as Mn mg/l BDL 0.1 (0.3)

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S. No. Parameters Unit GW1 AL(PL)

25. Zinc as Zn mg/l BDL 5 (15)

26. Total Chromium as Cr mg/l BDL 0.05 (NR)

27. Copper as Cu mg/l BDL 0.05 (1.5)

28. Boron as B mg/l 0.67 0.5 (1.0)

29. Nickel as Ni mg/l BDL 0.02 (NR)

30. Selenium as Se mg/l 0.006 0.01 (NR)

31. Free Residual Chlorine mg/l BDL 0.2 (1.0)

32. Aluminium as Al mg/l BDL 0.03 (0.2)

33. Ammonia as N mg/l BDL 0.5 (NR)

34. Barium as Ba mg/l 0.36 0.7 (NR)

35. Pesticides - ND - (NR)

36. Mineral Oil mg/l ND 0.5 (NR)

37. Silver as Ag mg/l BDL 0.1 (NR)

38. Cyanide as CN mg/l BDL 0.01 (NR)

39. Molybdenum as Mo mg/l 0.008 0.07 (NR)

40. Chloramines as Cl2 mg/l BDL 4.0 (NR)

41. Polychlorinated Biphenyl (PCB) mg/l BDL 0.005 (NR)

42. Polynuclear aromatic hydrocarbons (PAH) mg/l BDL 0.0001 (NR)

43. Anionic Detergents as MBAS mg/l BDL 0.2 (1.0)

44. Total Coliform MPN/100 ml Absent Shall not be detectable in any 100 ml sample 45. E. Coli - Absent Shall not be detectable in any 100 ml sample Source: Laboratory Results, January 2020, ND- Not Detected Note: AL- Acceptable Limit; PL – Permissible Limit; NR – No Relaxation as per IS10500:2012

Inference

The pH value of the sample was observed to be within the prescribed range, indicating neutral balance. The hardness and total dissolved solids (TDS) value in the groundwater sample exceeds the permissible limit. Chemical parameters such as chloride and magnesium were noted to be exceeding the permissible limit. Calcium was noted to be exceeding the acceptable limit but is within the permissible limit. Other heavy metal parameters such as Selenium, barium, Fluoride, boron were detected in the groundwater sample but were noted to be within acceptable limit. The groundwater sample does not show the presence of faecal coliforms implying that there is no faecal contamination in the groundwater. All other parameters were observed to be within the acceptable limits as specified in the drinking water standard of IS 10500:2012. It can be inferred from the water quality that groundwater contains high number of dissolved solids and has high hardness and thus is not completely fit for human consumption prior to conventional treatment.

4.2.4 Soil Environment Soil samples from two (02) locations as mentioned in Table 4-2 were collected and analysed to evaluate the soil quality for physio-chemicals and heavy metals concentration in soil in the environment study area.

The physical and chemical characteristics of the soil samplesw ere evaluated and compared with the standard soil classification provided by the Indian Council of Agricultural Research (ICAR) as depicted in the Table 4-9 below:

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Table 4-9: Standard Soil Classification

Soil Parameters Classification pH Normal to saline 6.0 to 8.5

Tending to become alkaline 8.5-9.0

Alkaline Above 9.0

Electrical conductivity (mmhos/cm) Up to 1.00 – Normal

1.01- 2.00- Critical to germination

2.01-4.00- Critical for growth of the sensitive crops

Above 4.00 – Injurious to most crops Source: Indian Council of Agricultural Research, New Delhi

The results of soil quality analysis have been presented in the Table 4-10 below:

Table 4-10: Results of Soil quality analysis

S. No. Parameters Unit Sampling Locations

SQ1 SQ2

1 pH at 25ºC - 8.04 8.51

2 Electrical Conductivity ms/cm 7.32 0.14

3 Texture - Sandy Loam Sand

4 Phosphate (as PO4) % 0.01 0.01

5 Potassium (as K) mg/kg 137.57 80.66

6 Sodium (as Na) mg/kg 4546.8 59.47

7 Copper (as Cu) Mg/kg 4.67 3.77

8 Zinc (as Zn) Mg/kg 14.79 11.10

9 Iron (as Fe) Mg/kg 3850.53 2761.33

10 Manganese (as Mn) Mg/kg 167.26 111.14

11 Lead (Pb) Mg/kg 1.80 2.32

12 Nickel (Ni) Mg/kg 8.10 7.31

13 Barium (Ba) Mg/kg 8.89 13.80

14 Arsenic (As) Mg/kg 2.37 1.61

15 Cadmium (Cd) Mg/kg BDL BDL

16 Chromium (Cr) Mg/kg BDL BDL

17 Mercury (Hg) Mg/kg BDL BDL

18 Nitrates Mg/kg 2.20 3.01

19 Nitrites Mg/kg BDL BDL

20 Cation Exchange Capacity Meq/100g 27.91 6.96

21 Permeability Cm/sec 1.73 x10-6 4.23 x10-5

22 Porosity % 31.03 33.77

23 Particle Size Distribution

10 mm % 0.0 0.0

4.75 mm % 0.0 0.0

2 mm % 0.0 0.24

425 microns % 2.08 8.80

75 microns % 64.58 83.12

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Source: Laboratory Results, January 2020 BDL= Below Detection Limit

Inference It can be inferred from the results that the soil samples show different characteristics. The pH values of the soil samples range from 8.04 to 8.51 and the samples indicate normal to slightly saline soil conditions. Electrical conductivity of soil samples varies from 0.14-7.32 ms/cm indicating that soil at the project site (SQ1) is injurious to most crops and thus indicates high salinity of soil and the soil around the project site falls under Normal category. The Phosphate value in both the samples is 0.01%. Nitrate values in the samples ranges from 2.20- 3.01 mg/kg whereas Nitrates were not detected in any soil sample. The relatively high Sodium concentration in Soil sample at the project site indicates highly sodic soil and indicates that the soil has poor soil structure with low infiltration rate and aeration and thus the soil is not suitable for cultivation of many crops. High sodium concentration in soil can also be attributed to salty groundwater at the site. The sodium concentration around the project site is 59.47 mg/kg. The cation exchange capacity ranges from 6.96 in SQ2 to 27.91 in SQ1. Iron content in the soil samples were noted to be high in the range of 2761.33 in SQ 2 and 3859.53 mg/kg in SQ1. The samples were noted to be about 31.03-33.77% porous. Heavy metals such as chromium, cadmium, Mercury were not detected in the soil samples. Whereas other heavy metals such as lead (in the range of 1.80-2.32 mg/kg), nickel (in the range of 7.31-8.10 mg/kg), arsenic (in the range of 1.61-2.37 mg/kg) were observed in the soil samples.

As per the Soil texture diagram (shown below in the Figure 4-10) prescribed by the United States Department of Agriculture (USDA), it can be deciphered that the texture of soil sample SQ 1, i.e. the soil at the Project site is “Sandy Loam”, and the texture of soil sample SQ 2 (around the Project site) is “Sandy”.

Figure 4-10: Soil Texture Diagram

(Source: United States Department of Agriculture https://www.nrcs.usda.gov/wps/portal/nrcs/detail/soils/survey/?cid=nrcs142p2_054167)

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4.2.5 Traffic The project will involve transportation of solar panels and other components on trucks/trailers through village roads during peak construction phase. During the operation phase, traffic movement for the project activities will be restricted only to the movement of project vehicles and materials for maintenance.

The proposed Solar Project is connected through State Highway 127 (SH-127) which passes through the village Kundaliya and connects to Radhanesda village at a distance of 8 km from the site. The road further connects to Limbidya village (Limbiya- Baet road) which is an existing government paved road (~3.5 m wide) and runs parallel towards the north of the site.

Assessment of existing traffic conditions in the project area was undertaken to identify the problems with respect to traffic movement and to formulate the possible alternative solutions and the need for organizing the same in an efficient and economical manner. A traffic volume count survey was conducted at one location, i.e. Village road connecting Kundaliya village to Radhanesda village, further diverting connecting to the Limbiya- Baet road where the project site is located. This road will be used for transportation of the construction materials during construction phase and is the main connecting road for the site. The two-way traffic volume counts were recorded for twenty-four hours (8:00 am to 8:00 pm), once during the study period to assess the existing traffic composition.

The traffic monitored has been divided into the following four (4) categories/classes:

 Two wheelers (motor cycle, scooters);

 Three wheelers (auto rickshaw, motorized cart);  Four wheelers (passenger cars, pick up vans);  Six wheelers (light commercial vehicles, trucks & buses);  Bicycles; and

 Others (carts). Since the vehicles are of different types, a factor needs to be accounted for each of them in order to express them at par in single unit terms. The factors, commonly known as Passenger Car Unit (PCU) factors that are generally adopted have been given in the following Table 4-11.

Table 4-11: PCU Factors adopted for Traffic Volume Survey

Vehicle Type PCU Factor

Two Wheelers (Motor Cycle, Scooter etc.) 0.75

Three Wheelers (Autorickshaw, motorised carts etc.) 1.2

Four Wheelers/Light Vehicles (Passenger cars, Pickup vans etc.) 1

Six Wheelers/Heavy Vehicles (Light Commercial vehicles, Trucks and Buses etc.) 3.7

Bicycles 0.5

Others (Carts etc.) 2 Source: The Indian Roads Congress Code – IRC 109-1990

The hourly traffic volume counts have been furnished in the following Table 4-12 and Figure 4-11 below.

Table 4-12: Hourly Traffic Volumes

Time (Hours) Heavy Light Three Wheelers Two Wheelers Cycle Bullock Carts/Other Total Hourly Vehicles Vehicles Carts Traffic Volume

08:00-09:00 0 5 0 2.25 0 0 7.25

09:00-10:00 11.1 10 0 6 0 0 27.1

10:00-11:00 3.7 8 0 7.5 0 0 19.2

11:00-12:00 11.1 14 0 9 0 0 34.1

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12:00-13:00 3.7 17 0 14.25 0.5 0 35.45

13:00-14:00 0 11 0 6 0.5 0 17.5

14:00-15.00 0 8 0 7.5 0 0 15.5

15.00-16.00 0 13 0 6 0 0 19

16.00-17.00 7.4 24 0 7.5 0.5 0 39.4

17.00-18.00 18.5 15 0 8.25 1 0 42.75

18.00-19.00 14.8 7 0 9 0 0 30.8

19.00-20.00 3.7 10 0 3.75 0 0 17.45

20.00-21.00 3.7 7 0 3 0 0 13.7

21.00-22.00 0 2 0 0 0 0 2

22.00-23.00 0 2 0 0 0 0 2

023.00-00.00 0 0 0 0 0 0 0

00.00-01.00 0 0 0 0 0 0 0

01.00-02.00 0 0 0 0 0 0 0

02.00-03.00 0 0 0 0 0 0 0

03.00-04.00 0 0 0 0 0 0 0

04:00-05:00 0 0 0 0 0 0 0

05:00-06:00 0 0 0 0 0 0 0

06:00-07:00 3.7 3 0 0 0 0 6.7

07:00-08:00 0 6 0 0 0 0 6

Total 81.4 162 0 90 2.5 0 335.9 Source: Laboratory Results, 2020

Traffic Count 45 40 35 30 25 20 15 10

Hourly Traffic Volume 5 0 15.00‐16.00 16.00‐17.00 17.00‐18.00 18.00‐19.00 19.00‐20.00 20.00‐21.00 21.00‐22.00 22.00‐23.00 00.00‐01.00 01.00‐02.00 02.00‐03.00 03.00‐04.00 14:00‐15.00 08:00‐09:00 09:00‐10:00 10:00‐11:00 11:00‐12:00 12:00‐13:00 13:00‐14:00 04:00‐05:00 05:00‐06:00 06:00‐07:00 07:00‐08:00 023.00‐00.00 Time (Hours)

Figure 4-11: Hourly Traffic Volumes at TM1

Inference

Traffic volume count indicates that out of the total traffic at the Village road, maximum influx and outflux was observed for light vehicles (four wheelers) such as cars, vans amounting for 48% of the traffic at the road followed by two wheelers, which constituted for 26% of the traffic. This is followed by Six Wheelers/Heavy

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Vehicles such as Light Commercial vehicles, Trucks and Buses etc accounting for 24% of traffic. Further, cycles amounted for less than 1% of the traffic at the road. Other vehicles such as three wheelers, cycle rickshaws, bullock carts and other carts were not observed at the road.

Morning peak hour for maximum traffic influx was noted as 11:00-12:00 hours with 34.1 units. During night, peak traffic was observed at 17:00-18:00 hours with 32.75 units. Daily cumulative traffic movement at the village road was observed to be 335.9 units. 4.3 Biodiversity profile This section of the report summarizes the biodiversity baseline study carried out towards the ESIA. It delineates the study area covered by the assessment, describes the methodology used for the assessment and establishes a biodiversity baseline which covers the species, habitats, and ecosystem services of the study area, any invasive alien species present in the study area and the designated areas in closest proximity to the study area. This biodiversity baseline forms the basis for predicting the potential impacts of the project on the biodiversity of the study area and suggesting mitigation measures to manage the predicted impacts.

4.3.1 Delineation of the Study Area This sub-section delineates the study area covered by the biodiversity assessment. It also briefly describes the geographical and ecological status of the delineated study area.

The overall area covered by the assessment includes the following constituent areas:

a) The footprint of the project, hereafter referred to as the ‘Project Site’; b) The area extending 5 km outward from the Project Site boundary (estimated to contain the potential receptors of any project-related ecological impacts), hereafter referred to as the ‘Area of Influence’ or ‘AOI’; and c) The alignment of the external transmission line, along with the area extending 500 m on either side of the alignment, hereafter collectively referred to as the ‘Transmission Corridor’.

The ‘Project Site’, the ‘AOI’ and the ‘Transmission Corridor’ are hereafter collectively referred to as the ‘Study Area’.

Geographically, the Study Area comprises a part of the Little Rann of Kutch, a vast expanse of seasonal salt marshes containing elevated pieces of vegetated land fed mainly by the Luni River, and a part of the Vav Sandy Plain, an alluvial plain associated with the West Banas River. Ecologically, the Study Area represents a tract of Northern Tropical Thorn Forest, a forest-type typical to semi-arid tracts of north-western India, with forest sub- types including edaphic forms, such as Rann Saline Thorn Scrub and Salvadora Scrub, as well as, degraded forms, such as Euphorbia and Cassia auriculata Scrub.

The terrain of the Study Area is generally flat, with scattered shallow depressions, an overall gentle slope from northeast to southwest, and an average elevation of approximately 20 m above mean sea level. The land is drained mainly by a few shallow streams, with the drainage pattern being relatively under-developed and rainwater tending to settle in the natural depressions, creating small and large seasonal wetlands. The land-use in the Study Area is dominated by open scrub, salt marshes, seasonal wetlands, agricultural land and dispersed habitation. Crops commonly cultivated in the Study Area include Pennisetum typhoideum (Baajri), Triticum aestivum (Gau), Zea mays (Makki), Vigna radiata (Mag), Phaseolus aconitifolius (Math), Cyamopsis tetragonoloba (Guvaar), Brassica nigra (Rayda), Ricinus communis (Eranda), Cuminum cyminum (Jeera), Foeniculum vulgare (Variyali) and Citrullus vulgaris (Kalenga). Plantations around habitations, on farm bunds and along roads commonly include Euphorbia sp. (Thor), Azadirachta indica (Limda), Ailanthus excelsa (Aidua) and Moringa oleifera (Saragwa).

4.3.2 Methodology This sub-section describes the methodology used for collecting the primary and secondary data on which the biodiversity baseline of the Study Area is based. The secondary data was collated from suitably authenticated public domain sources, as also, informal consultations with local government officials and members of the local community.

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The primary and secondary data collection with respect to species was limited to the higher flora, namely angiosperms, and the higher fauna, namely vertebrates. 4.3.2.1 Primary Data

The primary biodiversity data was collected through qualitative sampling at thirty (30) sites in the Study Area. The sites were selected through stratified random sampling, governed by considerations of safety and accessibility. At each site, primary observations on species, habitats and ecosystem services were recorded.

Figure 4-12 presents the locations of the biodiversity sampling sites vis-à-vis the Study Area.

Figure 4-12: Biodiversity Sampling Sites in the Study Area The primary data was recorded during 4-7 November 2019 and 7-11 January 2020. The timings of the primary data collection covered the entire diurnal faunal activity-period, from early morning till late evening, but excluded the nocturnal faunal activity-period. Primary data on both, floristic and faunal species, was recorded through the visual encounter method. Primary data records were based on direct sightings of species, as well as, indirect evidence, such as flowers, pods, calls, nests, burrows, droppings, scats, moults and tracks. 4.3.2.2 Secondary Data

Study Area-specific secondary data was collected, as available, from local Forest Department offices, project site-personnel and members of the local community. Additional suitably authenticated secondary data was collated from sources in the public domain, including research journals, standard field guides, scientific reports by research institutions and forest department offices, and websites maintained by internationally recognized conservation organizations, such as International Union for Nature and Natural Resources (IUCN), Alliance for Zero Extinction, World Wide Fund for Nature (WWF-India), Birdlife International and Wetlands International.

The information sources quoted in this report are listed after the corresponding reportage throughout the report.

4.3.3 Species Profile of the Study Area This sub-section describes the reported and recorded floristic and faunal species of the Study Area.

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4.3.3.1 Floristic Species

The floristic species profile is based on the forest-types reported from the Study Area and the floristic species recorded in the Study Area as part of the primary data.

Reported Forest Types

According to the Champion and Seth Classification of Indian Forests, the natural vegetation of the Study Area is classifiable into the following forest-types:

Type 6B/C1 [Subtype C1 – Desert Thorn Forest of Subgroup 6B – Northern Tropical Thorn Forests]

The main forest type is spread over arid or semi-arid regions of Punjab, Uttar Pradesh, Madhya Pradesh, Rajasthan and northern Gujarat, including Saurashtra and Kachchh. The forest type is found mostly on flat alluvial or aeolian soils but can extend over low hilly country and eroded ravine lands, though intervening patches of highly saline soil remain bare of vegetation.

The dominant species vary from 4.5-10m in height and tend to be collected in clumps leaving bare ground in between. The woody growth is of all sizes from trees to dwarf shrubs, with no differentiation into storeys. Climbers are relatively numerous and usually exhibit xerophytic adaptations. The perennial grasses also grow in clumps and tussocks. There is a thin growth of annual grass after rains.

The subtype is found in Rajasthan, Punjab and Gujarat on flat to undulating country, with low hillocks or hills and soils that are partly in situ, but usually fluvial or aeolian deposits in various stages of consolidation. It is composed of very open crops of scattered trees, with locally prominent consociations of certain species, notably Acacia senegal and Prosopis spicigera.

Species characteristic of this forest subtype include:

Tree species: Azadirachta indica, Balanites aegyptiaca, Butea monosperma, Cordia rothii, Flacourtia indica, Grewia pilosa, Holoptelea integrifolia, Premna integrifolia, Prosopis cineraria, Salvadora oleioides, Senegalia senegal, Tecomella undulata, Vachellia catechu, V. jacquemontii, V. leucophloea, V. nilotica and Ziziphus jujuba;

Shrub species: Calligonum polygonoides, Calotropis gigantea, C. procera, Capparis decidua, Capparis zeylanica, Commiphora mukul, Crotalaria burhia, Euphorbia nivulia, Grewia tenax, G. villosa, Gymnosporia spinosa, Leptadenia pyrotechnica, Sericostoma pauciflorum, Tephrosea purpurea and Ziziphus nummularia; and

Herb species: Aerva javanica, Aristida spp., Barleria prionitis, Cenchrus barbatus, Cymbopogon jwarancusa, Dactyloctenium scindicum, Eleusine compressa, Eragrostis spp., Heteropogon contortus, Justicia spp., Lasiurus hirsutus, Peristrophe bicalyculata and Tragia spp.

Type 6B/DS2 [Subtype DS2 – Tropical Euphorbia Scrub fo Subgroup 6B – Northern Tropical Thorn Forest]

This degradation sub-type is especially conspicuous in westernRajasthan and Gujarat, usually occupying stony sites. It mostly results from excessive grazing and tree-felling, though edaphic factors may also be responsible. Species characteristic of this forest subtype include:

Tree species: Salvadora oleioides, Senegalia Senegal and Vachellia leucophloea;

Shrub species: Capparis decidua, C. divaricata, Cassia auriculata, Cocculus hirsutus, Euphorbia antiquorum, E. neriifolia, E. nivulia, Grewia spp., Gymnosporia spinosa, Justicia adhatoda, Mimosa hamata, Premna spp., Rivea hypocrateriformis, Sarcostemma acidum, Tinospora cordifolia and Ziziphus nummularia; and

Herb species: Aerva spp., Apluda mutica, Aristida spp., Arthrocnemum indicum, Barleria spp., Convolvulus spp., Cynodon dactylon, Dactyloctenium scindicum, Dicanthium annulatum, Eleusine spp., Eragrostis spp., Fagonia cretica, Indigofera cordifolia, Lasiurus scindicus, Rhynchosia minima, Solanum albicaule, Vernonia cinarescens, Vitis spp. and Tragia spp.

Type 6/E3 [Subtype E3 – Rann Saline Thorn Forest of Group 6 – Tropical Thorn Forest]

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This edaphic sub-type occurs in the Rann region of Gujarat. It is distributed all along the extensive marine saline flats of the Rann which are periodically inundated by the sea. Natural vegetation is very sparse, while the introduced alien species Prosopis juliflora imparts a distinctive physiognomy to the vegetation. Species characteristic of this forest subtype include:

Tree species: Prosopis juliflora (introduced), Salvadora oleioides, Vachellia spp. and Tamarix ericoides;

Shrub species: Calotropis procera; and

Herb species: Indigofera spp.

Type 6/E4 [Subtype E4 – Salvadora Scrub of Group 6 – Tropical Thorn Forest]

This edaphic subtype occurs westwards of western Uttar Pradesh in semi-arid or arid in soils that are alkaline or saline.

Species characteristic of this forest subtype include:

Tree species: Salvadora oleioides, S. persica and Tamarix ericoides;

Shrub species: Calotropis procera and Tamarix aphylla; and

Herb species: Crypsis schoenoides, Halopyrum mucronatum, Indigofera spp. and Suaeda fruticosa. Source: Champion, H. G., Seth, S. K. (1968) Revised Survey of the Forest Types of India. Manager of Publications, Government of India, Delhi.

Recorded Floristic Species

Fifty-five (55) floristic species were recorded collectively at the sampling sites.

Table 4-13 presents the floristic species recorded at the sampling sites, along with the botanical family to which each species is assigned, its habit and its status as per the IUCN Red List.

Table 4-13: Floristic Species recorded in the Study Area

S. No. Species Botanical Family Habit IUCN Status* 1 Abutilon sp. Malvaceae Herb NE 2 Achyranthes aspera Amaranthaceae Herb NE 3 Aeluropus lagopoides Poaceae Herb NE 4 Aerva javanica Amaranthaceae Herb NE 5 Aerva pseudotomentosa Amaranthaceae Herb NE 6 Ailanthus excelsa Simaroubaceae Tree NE 7 Ammania baccifera Lythraceae Herb LC 8 Aristida sp. Poaceae Herb - 9 Azadirachta indica Meliaceae Tree LC 10 Blumea sp. Asteraceae Herb - 11 Calotropis gigantea Apocynaceae Shrub NE 12 Calotropis procera Apocynaceae Shrub NE 13 Capparis decidua Capparaceae Shrub NE 14 Celosia argentea Amaranthaceae Herb NE 15 Cenchrus biflorus Poaceae Herb NE 16 Chloris barbata Poaceae Herb NE 17 Citrullus colocynthis Cucurbitaceae Herb NE 18 Cocculus hirsutus Menispermaceae Herb NE

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19 Convolvulus prostratus Convolvulaceae Herb NE 20 Cressa cretica Convolvulaceae Herb LC 21 Crotalaria burhia Fabaceae Herb NE 22 Cyperus sp. Cyperaceae Herb - 23 Dactyloctenium sp. Poaceae Herb - 24 Datura innoxia Solanaceae Herb NE 25 Echinops echinatus Asteraceae Herb NE 26 Eragroatis sp. Poaceae Herb - 27 Euphorbia nivulia Euphorbiaceae Shrub NE 28 Fagonia cretica Zygophyllaceae Herb NE 29 Ficus benghalensis Moraceae Tree NE 30 Heliotropium marifolium Boraginaceae Herb NE 31 Indigofera cordifolia Fabaceae Herb NE 32 Indigofera sp. Fabaceae Herb - 33 Launaea procumbens Asteraceae Herb NE 34 Leptadenia pyrotechnica Apocynaceae Shrub NE 35 Lycium edgeworthii Solanaceae Herb NE 36 Oligochaeta divaricata Asteraceae Herb NE 37 Pergularia daemia Apocynaceae Herb NE 38 Prosopis cineraria Mimosaceae Tree NE 39 Prosopis juliflora Mimosaceae Tree NE 40 Pulicaria wightiana Asteraceae Herb NE 41 Salvadora oleoides Salvadoraceae Tree NE 42 Salvadora persica Salvadoraceae Shrub NE 43 Senegalia polyacantha Fabaceae Tree NE 44 Senegalia senegal Fabaceae Tree NE 45 Senna italica Caesalpiniaceae Herb NE 46 Solanum trilobatum Solanaceae Herb NE 47 Solanum virginianum Solanaceae Herb NE 48 Tecomella undulata Bignoniaceae Tree NE 49 Tephrosia purpurea Fabaceae Herb NE 50 Tephrosia sp. Fabaceae Herb - 51 Tribulus terrestris Zygophyllaceae Herb LC 52 Vachellia jacquemontii Mimosaceae Tree NE 53 Vachellia nilotica Mimosaceae Tree NE 54 Vachellia tortilis Mimosaceae Tree NE 55 Vernonia cinarescens Asteraceae Herb NE 56 Ziziphus jujuba Rhamnaceae Tree LC 57 Ziziphus nummularia Rhamnaceae Shrub NE Source: AECOM Primary Survey

Figure 4-13 presents a photographic log of some of the floristic species recorded in the sampling sites.

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Solanum virginianum

Aerva javanica Cassia italica

Azadirachta indica Capparis decidua

Cressa cretica Ziziphus jujuba Figure 4-13: Some Floristic Species recorded in the Study Area Source: AECOM Primary Survey

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4.3.3.2 Faunal Species

This section of the report presents the higher faunal species, namely vertebrates, comprising mammals, birds, reptiles, amphibians and fishes, having reported ranges that include the Study Area. The detailed species-tables are provided as annexures to this report. Each annexed table gives the scientific and common names of each species, the conservation status assigned to it by the International Union for Nature and Natural Resources (IUCN) and the Schedule of the Wildlife Protection Act, 1972 (WPA) under which it is listed. Names of the species recorded as part of the primary data appear in bold font in each table.

Mammals

At least thirty-five (35) species of mammals have reported ranges that include the Study Area. With respect to the IUCN Red List, five (05) of these species are designated as globally threatened or near threatened. With respect to the WPA Schedules, ten (10) of these species are listed under Schedule I. Eight (08) species of mammals were recorded as part of the primary data.

Appendix B lists the mammal species of the Study Area.

Boselaphus tragocamelus (Nilgai) in the Project Site Boselaphus tragocamelus (Nilgai) in the Study Area Sources: AECOM Primary Survey

Birds

At least two hundred and thirty-two (232) species of birds have reported ranges that include the Study Area. These include one hundred and twenty-two (122) species which are resident with respect to the Study Area and one hundred and ten (110) species, which are migratory with respect to the Study Area. With respect to the IUCN Red List, twenty-two (22) bird species of the Study Area are designated as globally threatened or near threatened. With respect to the WPA Schedules, nine (09) bird species of the Study Area are listed under Schedule I. Eighty-eight (88) species of birds, consisting of fifty-three (53) resident species and thirty-five (35) migratory species, were recorded as part of the primary data.

Appendices C and D list the resident and migratory bird species respectively of the Study Area.

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Grus virgo (Demoiselle Crane) Calandrella brachydactyla (Greater Short-toed Lark)

Luscinia svecica (Bluethroat) Sylvia curruca (Lesser Whitethroat)

Phoenicopterus roseus (Greater Flamingo) Flock of ducks and waders

Anas clypeata (Northern Shoveler) Anas acuta (Northern Pintail) Sources: AECOM Primary Survey

Reptiles

At least forty-four (44) species of reptiles have reported ranges that include the Study Area. With respect to the IUCN Red List, one (01) of these species is designated as globally threatened. With respect to the WPA Schedules, two (02) of these species are listed under Schedule I. Two (02) species of reptiles were recorded as part of the primary data.

Appendix E lists the reptile species of the Study Area.

Amphibians

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At least nine (09) species of amphibians have reported ranges that include the Study Area. With respect to the IUCN Red List, none of these species are designated as globally threatened. With respect to the WPA Schedules, none of these species are listed under Schedule I. No species of amphibians were recorded as part of the primary data.

Appendix F lists the amphibian species of the Study Area

Fishes

At least eight (08) species of fishes have reported ranges that include the Study Area. With respect to the IUCN Red List, none of these species are designated as globally threatened. With respect to the WPA Schedules, none of these species are listed under Schedule I. No species of fishes were recorded as part of the primary data.

Appendix G lists the fish species of the Study Area

4.3.3.3 Invasive Alien Species

At least two (02) species, comprising one (01) floristic species and one (01) faunal species, reported from the Study Area, are designated as invasive alien species with respect to the Study Area. Both these species were recorded as part of the primary data.

At least 1 floristic species and 1 faunal species reported from the Study Area are designated as invasive alien species with respect to the Study Area. Both these species were recorded as part of the primary data.

Table 4-14 lists the invasive alien species of the Study Area, along with the vernacular name of each species, the conservation status assigned to it by the International Union for Nature and Natural Resources (IUCN) and its native range. The floristic and faunal species are listed in separate sections

Table 4-14: Invasive Alien Species of Study Area

SN Scientific Name Vernacular Name IUCN Status* Native Range Floristic Species 1 Prosopis juliflora Bilayati Banwal NA Central and South America Faunal Species 2 Columba livia Kabootar LC Europe

**Status assigned by the International Union for Conservation of Nature and Natural Resources, where – NA – Not Assessed and LC – Least Concern.

Sources: AECOM Primary Survey; IUCN (2019). The IUCN Red List of Threatened Species. Version 2019-2; Global Invasive Species Database, Invasive Species Specialist Group, IUCN; CABI Invasive Species Compendium; Invasive Alien Species of India, National Biodiversity Authority, Ministry of Environment, Forests and Climate Change, Government of India.

4.3.4 Habitat Profile of the Study Area The habitat-profile of the Study Area is composed of natural, as well as, modified habitats. Each of these types include both, terrestrial and aquatic habitats. The habitats of the Study Area are fragmented mainly by metalled roads, dirt roads, foot-trails and canals, while the aerial envelope of the study area is mainly interrupted by minor power distribution lines, pylons and transmission towers.

Figures 4-14and 4-15 represent the habitat profile of the project site and the transmission corridor respectively.

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Figure 4-14: Habitat Profile of the Project Site

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Figure 4-15: Habitat Profile of the external Transmission Line Corridor

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4.3.4.1 Natural Habitats

As defined by the applicable reference frameworks, natural habitats consist of land and water areas where the biological communities are formed largely by native plant and animal species, and where human activity has not essentially modified the area’s primary ecological functions.

The terrestrial natural habitats of the Study Area mainly comprise scrublands, grasslands, sandy plains and saline flats. These are present predominantly in and around the Project Site. The aquatic natural habitats of the Study Area consist of seasonal freshwater or brackish-water wetlands. The freshwater wetlands are present predominantly in the external Transmission Line Corridor, while the brackish-water wetlands are present predominantly in and around the Project Site.

Scrubland in the Project Site Saline Flat (Rann) in the Study Area

Seasonal Wetland in the Study Area Sources: AECOM Primary Survey

4.3.4.2 Modified Habitats

As defined by the applicable reference frameworks, natural habitats consist of areas where the natural habitat has apparently been altered, often through the introduction of alien species of plants and animals.

The terrestrial modified habitats of the Study Area mainly comprise cropped, uncropped or fallow farmlands, plantations, pasturelands and habitations. These are present predominantly in the external Transmission Line Corridor. The aquatic modified habitats of the Study Area consist mainly of canals and seasonal pools of rainwater accumulated within mud-embanked plots. The canals are limited to the external Transmission Line Corridor, which they intersect at about six or seven locations dispersed along the length of the corridor. The mud- embanked plots, which support seasonal rainwater pools, are limited to the north-eastern part of the Project Site

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and a few adjacent areas, while a single, large mud-embanked plot is located in the north-western part of the Project Site.

Transmission tower in the Study Area Dirt track in the Study Area Sources: AECOM Primary Survey

4.3.4.3 Critical Habitats

As defined by the applicable reference frameworks, Critical Habitat (CH) includes areas with high biodiversity value, including habitat required for the survival of critically endangered or endangered species, areas having special significance for endemic or restricted-range species, sites that are critical for the survival of migratory species, areas supporting globally significant concentrations or numbers of individuals of congregatory species, areas with unique assemblages of species or that are associated with key evolutionary processes or provide key ecosystem services and areas having biodiversity of significant social, economic, or cultural importance to local communities. Areas which are legally protected or officially proposed for protection, such as areas that meet the criteria of the World Conservation Union classification, the Ramsar List of Wetlands of International Importance or the United Nations Educational, Scientific, and Cultural Organization’s (UNESCO) world natural heritage sites are also deemed to be CH.

A Critical Habitat Screening (CHS) conducted for the Study Area identified potential CH triggers with respect to the Study Area as per the CH criteria of critically endangered or endangered species, endemic or restricted range species, migratory and/or congregatory species, as also, key evoutionary processes. The CHS identified no potential CH triggers as per the other CH criteria.

This sub-section lists the potential Critical Habitat trigger species identified with respect to the Study Area.

Critically Endangered or Endangered Species

Species listed as Critically Endangered (CR), Endangered (EN) or Vulnerable (VU) on the IUCN Red List of Threatened Species have been evaluated as part of the CH Criterion 1. Owing to the IUCN National Red Lists for mammals, birds, reptiles and amphibians being currently out-dated, only the global conservation status of species has been considered in this assessment. CR, EN and VU species are deemed to face extremely high, very high and high risk of extinction in the wild, respectively.

Of the species reported from the Study Area, nineteen (19) species, comprising four (04) CR, five (05) EN and ten (10) VU species, are potential CH Criterion 1 triggers with respect to the Study Area.

Table 4-15 presents details of the Critically Endangered and Endangered species having reported ranges that include the Study Area.

Table 4-15: Critically Endangered and Endangered Species of the Study Area

S. No. Scientific Name Common Name IUCN Status* WPA Schedule**

Mammals

1 Manis crassicaudata Indian Pangolin EN I

2 Lutrogale perspicillata Smooth-coated Otter VU I

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Birds

3 Marmaronetta angustirostris Marbled Duck VU IV

4 Aythya ferina Common Pochard VU IV

5 Falco cherrug Saker Falcon EN I

6 Neophron percnopterus Egyptian Vulture EN IV

7 Gyps bengalensis White-rumped Vulture CR I 8 Gyps indicus Indian Vulture CR I 9 Sarcogyps calvus Red-headed Vulture CR I 10 Aquila clanga Greater Spotted Eagle VU IV 11 Aquila nipalensis Steppe Eagle EN IV 12 Aquila heliaca Eastern Imperial Eagle VU IV 13 Chlamydotis macqueenii Macqueen’s Bustard VU I 14 Grus antigone Sarus Crane VU I 15 Vanellus gregarius Sociable Lapwing CR IV 16 Sterna acuticauda Black-bellied Tern EN - 17 Chaetornis striata Bristled Grassbird VU IV 18 Saxicola macrorhynchus Stoliczka’s Bushchat VU IV

Reptiles 19 Geochelone elegans Indian Star Tortoise VU IV

*Status assigned by the International Union for Conservation of Nature and Natural Resources, where –CR – Critically Endangered and EN - Endangered.

Sources: R. Grimmett, C. Inskipp & T. Inskipp (2011). Birds of the Indian Subcontinent. Oxford University Press, pp 1-528; IUCN (2019). The IUCN Red List of Threatened Species. Version 2019-3.

Endemic and/or Restricted Range Species

Endemic or Restricted Range species are species which occur only within a pre-specified limited area. Equus hemionus khur (Indian Wild Ass), a subspecies of Equus hemionus (Asiatic Wild Ass), is endemic to a restricted range which includes the Study Area. The entire global population of Equus hemionus khur, estimated to be 4000 individuals, is distributed in and around the Little Rann of Kachchh, on the north-eastern fringe of which the Study Area is located. The species itself is designated as Near Threatened (NT) as per the IUCN Red List, but no evaluation is available for the sub-species. The sub-species is listed in Schedule I of the Wildlife (Protection) Act of India, 1972.

Migratory and/or Congregatory Species

Migratory Species are defined as species of which a significant proportion of members cyclically and predictably move from one geographical area to another, including within the same ecosystem. The Study Area is located within the Central Asian Flyway, as also, in proximity to the East Asia - East Africa Flyway. Thus, the Study Area is very likely to be situated in the annual cyclical flight-paths of the various winter, summer, passage migratory or nesting birds migrating either to or through the region in which it is situated. At least one hundred and ten (110) such Migratory Species, all birds, have reported ranges that include the Study Area, which may serve as a wintering/summering destination, staging site or flight-path for these species.

Congregatory species include species that gather in globally significant numbers at a particular site at a particular time in their life cycle for feeding, breeding or mid-migration resting. The Study Area contains vast seasonal wetland habitats, which indicates probable seasonal occurrence of migratory and/or congregatory waterfowl in the wetlands and the aerial envelope of the Study Area.

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The CHS identified globally threatened or near-threatened migratory and/or congregatory species as a group of species which may potentially contain one or more CH triggers with respect to the Study Area.

Appendix D lists the migratory species of the Study Area. Figure 4-16 depicts the Central Asian Flyway vis-à-vis the Indian subcontinent.

Figure 4-16: The Central Asian Flyway

Source: Birdlife International (2020). Birdlife Data Zone: Central Asia/South Asia. Downloaded from http://datazone.birdlife.org/ on 21/01/2020

A Critical Habitat Assessment (CHA) evaluated each potential CH trigger identified by the CHS and assessed that only one (1) species, Vanellus gregarius (Sociable Lapwing) qualified as a probable CH trigger with respect to the Study Area.

Vanellus gregarius (Sociable Lapwing), a Critically Endangered (CR) migratory and congregatory species, is classified as a winter visitor with respect to the Study Area. The species has an estimated population of 16,000- 17,000 individuals, containing 5,600 pairs representing 11,200 mature individuals, which is reportedly a very rough estimate requiring refinement. The size of a migrating flock of the species may be 15-20 individuals, while the size of a wintering flock may range from a few to over a hundred birds. The migratory passage of the species is distributed across a large part of West and Central Asia, as also, Egypt in northeast Africa. The reportedly shrinking wintering range of the species is currently limited to key areas in Sudan, Saudi Arabia, Oman, Pakistan and northwest India. The species is reported to be highly faithful to its wintering grounds, but not necessarily to its breeding grounds or staging sites. As per the available secondary data, the species is likely to occur in the Study Area during the period between October and April.

At least 4 habitat-types classified as suitable for the species, namely, grassland, inland saline wetlands, desert and cultivation, are present in the Study Area. The preferred habitats of the species during its migratory passage are reportedly sandy plains with short grass, dry grassland, cultivated fields and fallow farmland, while its preferred habitats during wintering are sandy wasteland, damp grassland and harvested millet fields, ideally close

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to wetlands. Habitat-types preferred by the species during its migratory passage, namely sandy plains with short grass and dry grassland, are present mainly in and around the Project Site, while habitat-types preferred by the species during wintering, namely harvested millet fields close to wetlands, are present mainly in and around the external Transmission Line Corridor.

The diet of the species during the migration period is reportedly omnivorous, but dominated by insects, especially Orthopterans, a group of species associated with grasslands, as are present in and around the Study Area. Non- intensive grazing, as is practiced in the grasslands and fallow fields of the Study Area, reportedly favours the maintenance of habitat-features important to the life-cycle of Orthopterans.

The species is reported to be extremely vulnerable to changes in livestock grazing and agricultural intensification. The advent of canals into the Study Area, reportedly over the last decade, has led to intensification of the local agricultural system from rain-fed, single crop-based subsistence-farming to irrigated, double crop-based cash- farming. As per the annual cropping cycle prevalent in the Study Area, the millet crop is harvested around October, with the subsequent crop being sown around December. Thus, the millet fields of the Study Area are in the harvested state, preferred by the species for wintering, only during the October-December period of the year. This period coincides mainly with the in-migration period of the species and only partially with its wintering period. It is probable that this agricultural intensification has rendered the Study Area less suitable as a wintering ground for the species.

The secondary data collated contains no confirmed sightings of the species in the Study Area. During informal consultations conducted towards the Scoping, CHA and ESIA studies, the local community could not conclusively identify the species or confirm its sighting in the Study Area, reportedly owing to the similarity in its appearance with that of other species occurring in the Study Area. The eBird website contains no records at all for the western Banaskantha region, in which the Study Area is located, but it reports a significantly high frequency of sightings of the species from the adjacent regions of Kachchh and Ahmedabad, which are situated southwest and southeast respectively of the Study Area. There are also a significant number of sightings at locations due south of the Study Area reported informally by national and international bird-watcher groups and individuals. Locations nearest to the Study Area from which the species has been reported so far, presented from west to east, are Aadhav, located approximately 150 km west-southwest of the Study Area, Rozwa, located approximately 95 km south of the Study Area, Nalsarovar, located approximately 160 km south-southeast of the Study Area and Patan, located approximately 80 km southeast of the Study Area.

The species (Vanellus gregarious) was not recorded in the Study Area as part of the primary baseline data collected towards the Scoping, CHA and ESIA studies.

The CHA also identified globally threatened or near-threatened migratory and/or congregatory species as a group of species that is likely to contain CH triggers. The Study Area is part of the reported passage or wintering range of at least eleven (11) globally threatened or near-threatened species, as well as, ten (10) congregatory species. Habitat-types collectively preferred by the concerned species are present in and around the entire Study Area. All the concerned species of this group are most likely to occur in the Study Area during the period between October and April. Some of the concerned species were recorded in the Study Area as part of the primary baseline data collected towards the CHA and the ESIA (during November 2019 to January 2020), though the numbers recorded did not meet the thresholds stipulated for the Study Area to qualify as a CH with respect to any of the concerned species.

However, since the corresponding field surveys (during November 2019 to January 2020) did not cover the entire possible period of occurrence of the species in the Study Area, the CHA identified lack of adequate primary data or authenticated secondary data regarding the number of individuals of Vanellus gregarius (Sociable Lapwing) as also, the concerned globally threatened or near-threatened migratory and/or congregatory species, occurring within the Study Area as significant data gaps which prevent conclusive CH determination. Subsequently, in order to address the identified data gaps, a monitoring study, focused on the identified CH trigger species or group of species, was commissioned to generate the requisite primary data with respect to their occurrence and numbers within the Study Area. In addition to the Scoping, CHA and ESIA studies (undertaken during November 2019 to January 2020), two (2) monitoring events were also conducted towards this study, during 6-10 January 2020 and 10-14 February 2020, respectively. Observations recorded during these events did not include any sightings of Vanellus gregarius (Sociable Lapwing) either, but they did include sightings of seven (07) globally threatened or near-threatened migratory species, including two (02) congregatory species. However, the numbers of individuals

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of the latter species recorded in the Study Area during the monitoring study did not meet the thresholds stipulated for the Study Area to qualify as a CH with respect to any of the concerned species, either.

Based on the primary and secondary data available to the ESIA at this juncture, it may be concluded that it is probable that the Study Area contains staging sites or wintering habitats of Vanellus gregarius (Sociable Lapwing). The habitats available at the Project Site, considered in isolation, are preferred by the species only during its migration passage and hence, are likely to serve as a staging site for the species rather than as a wintering ground. For the Project Site to qualify as a CH for the species, it must support at least 0.5% of the estimated global population of the species, amounting to 80-85 individuals, which must include at least 5 reproductive units of the species. Considering the migrating flock-size of 15-20 individuals reported for the species, the relatively insignificant extent at the Project Site of the preferred habitat-type of the species during migratory passage, as also, the presence of similar habitats over a significantly large area in other parts of the Study Area, as well as, beyond the Study Area, it seems relatively unlikely that the Project Site represents a CH with respect to the species.

The habitats available at the Project Site, considered in isolation, are preferred by the species only during its migration passage and hence, are likely to serve as a staging site for the species rather than as a wintering ground. However, considering that similar habitats are present in a significantly large area in other parts of the Study Area, as well as, beyond the Study Area, it is unlikely that the Project Site represents a CH with respect to the species.

Based on the primary and secondary data available to the ESIA at this juncture, it may also be concluded that the Study Area contains staging sites, as well as, wintering habitats of the globally threatened migratory and/or congregatory species identified as potential CH triggers with respect to the Study Area. However, considering the relatively insignificant proportion of the global populations of the concerned species recorded in the Study Area, as well as, presence of similar habitats in a significantly large area beyond the Study Area, it is unlikely that the Study Area represents a CH with respect to the concerned species.

Note: The monitoring study8 observations include sightings of nine (09) species which are neither reported by the secondary sources, nor recorded as part of the primary data, used towards the Scoping, CHA and ESIA studies.

Sources: BirdLife International 2019. Vanellus gregarius (amended version of 2018 assessment). The IUCN Red List of Threatened Species 2019: e. T22694053A155545788; Gardiner T (2018) Grazing and Orthoptera: a review. Journal of Orthoptera Research 27(1): 3-11; BirdLife International (2020) Species factsheet: Vanellus gregarius.; ERM’s Consolidated Bird Monitoring Study Report (February 2020).

4.3.5 Designated Areas Designated areas include legally protected areas, such as National Parks, Wildlife Sanctuaries, Reserve Forests, Protected Forests, Community Forests and Conservation Areas notified by the Government of India, as well as, internationally recognized areas, such as Ramsar Wetlands, Important Bird Areas, Key Biodiversity Areas or UNESCO World Heritage Sites. Designated areas in proximity to the Study Area is provided in the following sections.

The Figure 4-17 represents the locations of the designated areas in closest proximity to the Study Area.

8 The following additional actions are recommended to strengthen the monitoring study reportage and, by extension, the CHA: (i) The locations of each water-body, as well as, the extremities and bends of each transect, at which observations are being recorded, must be duly stated in the monitoring reports, as has been done for each point count and vantage point location; (ii) The habitat-type(s) present in the view-shed of each point-count, vantage point, water-body or saltpan location, as well as, each transect alignment, must be stated in the monitoring reports; (iii) The raw primary data collected during each monitoring event must be appended to the corresponding report, to enable temporal profiling of species occurring in the Study Area; and (iv) The monitoring study must seek to identify sites of high bird use along the external transmission line alignment to guide the mitigation planning.

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Figure 4-17: Designated Areas around the Study Area

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4.3.5.1 Legally Protected Areas

Wild Ass Sanctuary

This is the Legally Protected Area in closest proximity to the Study Area. It is notified as a Wildlife Sanctuary as per the provisions of the Wildlife (Protection) Act of India, 1972 (WPA). Though the primary purpose of according legal protection to the area is conservation of the sole habitat of Equus hemionus khur (Indian Wild Ass), a sub- species of Equus hemionus (Asiatic Wild Ass), the area is also protected as a migratory and/or congregatory species habitat of high biodiversity value. The Study Area is located approximately 1.5 km due east of the nearest point on the boundary of the Wild Ass Sanctuary. The Project Site itself is situated approximately 6.5 km west- northwest of the nearest point on the boundary of the Wild Ass Sanctuary.

Rann of Kutch Wildlife Sanctuary Ramsar Site: The Rann of Kutch Wildlife Sanctuary (RKWS) is the Ramsar Site in closest proximity to the Project Site. The Project Site is situated approximately 17 km northeast of the nearest point on the boundary of the RKWS Ramsar Site. This Ramsar Site is also designated as an Important Bird Area (IBA; Code PK055) and a Key Biodiversity Area (KBA).

Thus, the Project Site is situated within distances of 5 km to 17 km from the boundaries of at least five (05) designated areas that are internationally and/or nationally recognized as being of high biodiversity value, namely the Kachchh Biosphere Reserve, the Kachchh Desert Sanctuary, the Wild Ass Sanctuary, the Wild Ass Sanctuary IBA/KBA and the Rann of Kutch Wildlife Sanctuary Ramsar Site/ IBA/ KBA. However, the Project Site does not coincide with or overlap any of the designated areas situated in closest proximity to it.

Hence, it was concluded that coincidence or overlap with designated areas does not qualify as a CH Criterion 6 trigger with respect to the Project. 4.3.5.2 Internationally Recognized Areas

Wild Ass Sanctuary IBA (IBA Code IN097): The Wild Ass Sanctuary (WAS) Important Bird Area (IBA) is the IBA in closest proximity to the Project Site. The Project Site is situated approximately 12 km northwest of the nearest point on the boundary of the WAS IBA. This IBA is also designated as a Key Biodiversity Area (KBA).

Kachchh Biosphere Reserve: The Kachchh Biosphere Reserve (KBR), composed collectively of the Wild Ass Sanctuary and the Kutch Desert Sanctuary, is the Legally Protected Area in closest proximity to the Project Site. The Project Site is situated approximately 5 km north-northwest of the nearest point on the boundary of the KBR.

Note: An erroneous map on the Protected Planet website depicts the Project Site as being part of the legally protected area of the Kachchh Desert Sanctuary (KDS). As per the map appended as Annexure I to the Eco- sensitive Zone Notification of the KDS, dated 29 August 2019, issued by the Ministry of Environment, Forest and Climate Change (MoEFCC), Government of India, the Project Site is situated approximately 5 km north-northwest of the nearest point on the boundary of the KDS.

4.3.6 Ecosystem Services This sub-section presents an overview of the ecosystem services provided by the Study Area to the local community.

Provisioning Services

As per inputs received from the local community, the Study Area provides the following provisioning ecosystem services to the community members:

Water: The groundwater and surface water bodies of the Study Area are the main sources of drinking, domestic and irrigation water. Groundwater is accessed through dug-wells and bore-wells. Almost all the natural surface water-bodies, except the saline ones, from small ponds to large lakes, are regularly accessed to collect water for drinking and domestic purposes and to water livestock.

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Dug-well in the Study Area Livestock grazing in the Project Site Sources: AECOM Primary Survey

Cultivated Foods: The soils of the Study Area are used by the local community to cultivate the following cereal, millet, pulse, oil-seed, spice, vegetable and fruit crops: Pennisetum typhoideum (Baajri), Triticum aestivum (Gau), Zea mays (Makki), Vigna radiata (Mag), Phaseolus aconitifolius (Math), Cyamopsis tetragonoloba (Guvaar), Brassica nigra (Rayda), Ricinus communis (Eranda), Cuminum cyminum (Jeera), Foeniculum vulgare (Variyali) and Citrullus vulgaris (Kalenga).

Wild Foods: Prosopis cineraria (Khejdi), Senegalia senegal (Kummat), Salvadora oleioides (Jhaal) and Capparis decidua (Kerda)

Medicines: Tribulus terrestris (Kaante), Solanum virginianum (Phutengdi)

Fodder: Natural vegetation (especially grasses), as well as, crop residue.

Timber: Tecomella undulata (Royeda), Vachellia nilotica (Desi Bawal), Azadirachta indica (Limda), Ziziphus jujuba (Bordi)

Thatching: Crotalaria burhia (Shingitra), Leptadenia pyrotechnica (Chipda)

Brooms: Tephrosia purpurea (Sharniya)

Regulating Services

The Study Area is likely to be providing regulating services, such as groundwater recharge, sediment regulation and temperature regulation to the local community.

Supporting Services

The Study Area is likely to be providing supporting services, such as primary production, pollinating services and storm buffering to the local community.

Cultural Services

The Study Area seems to be providing cultural services to the local community in terms of aesthetic value, with community members commenting, during informal consultations, on the beauty and grandeur of the vast Rann of Kachchh landscape, especially during the twilight periods. As per inputs received from community members, the local community traditionally revers the migratory bird species visiting the Study Area during winter as ‘honoured guests’ and voluntarily abstains from hunting them. The latter sentiment also amounts to a cultural ecosystem service.

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4.4 Socio-economic Profile 4.4.1 Socio-Economic Environment The section endeavours to represent the socio-economic characteristics of the project area and identify the direct and indirect project impacts with the help of collection and analysis of primary and secondary data. Relevant information and statistical data used in the section have been drawn from secondary sources such as the Census of India, 2011 and the Village Directory 2011.

4.4.2 Approach and Methodology Methodology adopted:

 Identification of project impacted area (direct and indirect project impact area) in accordance with the project site location; and  A radius of five (05) kilometres from the project area was earmarked as the indirect project impact area for the ESIA. Identification of villages falling within the specified five (05) kilometres radii was undertaken.

─ Primary data collection: . Interaction with relevant government stakeholders were undertaken; . Interaction with Village Panchayat Members of the directly impacted project villages was undertaken; . Consultations with opinion leaders (leader, principal/teacher of Government School, Radhanesda village) was undertaken; . Focus Group Discussions with the community members of Radhanesda and Kundaliya villages was undertaken; and . Consultations with members of Rabari Community (OBC) engaged in animal grazing was undertaken; Socio-Economic Baseline from the macro (district) level to micro (village) level was developed through consultations with community members/ village heads/opinion leaders. It is supplemented through secondary data base available in the public domain. They are as below:

─ Secondary data collection: The following government publications (secondary database) were referred to while developing the socio- economic baseline for the study; . Primary Census Abstract, 2011; Office of the Registrar General & Census Commissioner, India; Ministry of Home Affairs; . Village Directory Abstract 2011, Office of the Registrar General & Census Commissioner, India; Ministry of Home Affairs; and . District Census Hand Book, Banas kantha; Directorate of Census Operations, Gujarat.

4.4.3 Administrative Profile 4.4.3.1 State profile: Gujarat

Gujarat was created out of seventeen (17) northern districts of the former state of Bombay on May 1, 1960. Located on the western coast of India, it has the longest coastline of 1,600 Km and is bounded by the Arabian Sea to the west and south west and by Pakistan in the North. It has a population of approximately 6.03 Crore (4.99% of Indian Population). The State of Gujarat is surrounded by the States of Rajasthan and Madhya Pradesh towards the north east and east, Maharashtra and the Union Territories of Daman, Diu and Nagar Haveli, towards the south. Gandhinagar, the capital city of Gujarat is located close to Ahmedabad, the commercial capital of the State which is also the most populated District in the State, with 7.20 million people.

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The State has diverse climatic conditions with mild and pleasant winters and hot and dry summers and heavy monsoon. The state currently has 33 districts9.

Demographic profile of the state of Gujarat has been provided in Table 4-166.

Table 4-16 Demographic Profile of State of Gujarat

Description 2011 2001

Population 60,439,692 50,671,017

Male 31,491,260 26,385,577

Female 28,948,432 24,285,440

Population Growth 19.28% 22.48%

Percentage of total Population 4.99% 4.93%

Sex Ratio 919 920

Child Sex Ratio 890 883

Density/km2 308 258

Density/mi2 798 669

Area (Km2) 196,244 196,024

Area mi2 75,770 75,685

Total Child Population (0-6 Age) 7,777,262 7,532,404

Male Population (0-6 Age) 4,115,384 4,000,148

Female Population (0-6 Age) 3,661,878 3,532,256

Literacy 78.03 % 69.14 %

Male Literacy 85.75 % 79.66 %

Female Literacy 69.68 % 57.80 %

Total Literate 41,093,358 29,827,750

Male Literate 23,474,873 17,833,273

Female Literate 17,618,485 11,994,477

‘Source: https://www.census2011.co.in/census/state/gujarat.html

4.4.3.2 District profile: Banaskantha

Banas Kantha district falls in the north- western part of the State and is the fourth largest district in Gujarat in terms of area. It lies between 23° 55’ and 24° 43’ North latitudes and 71° 16’ and 73° 0’ East longitudes. The area covered by the district is 10,743 sq. km i.e. 5.47 % geographical area of Gujarat. The density of the district is 290 persons per sq. km compared to 308, the density of the State of Gujarat. In the north it is bounded by Marwar and Sirohi area of the Rajasthan State, in the east by a part of Sirohi and Sabar Kantha district, in the south-east by the district of Mahesana, to the south by the district of Patan and in the west by the Rann of Kachchh which forms frontier with Pakistan. It is divided into 12 talukas. Palanpur town is the district headquarters10. 4.4.3.3 Project Area

The villages under direct project impact is Radhanesda village. The study area has been further divided into direct impact area (the area where the project will be located) and indirect impact area (within 05 km of the

9 https://gujaratindia.gov.in/state-profile/demography.htm 10 DCHB, Banas kantha District, Directorate of Census Operations, Gujarat

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project area). Kundaliya village falls within the 5-kilometre radii of the project. It is expected that the area of influence of the project will be five (05) kilometre as the project is a Solar Power project and the socio-economic impacts of the project is anticipated to be minimal. This is because solar power projects in general do not have any significant impacts on community health and safety and the current project is not envisaged to have any physical resettlement or major economic impacts. Risks pertaining to community health and safety would be restricted primarily during the construction phase due to increased traffic movement and influx of labour migrants Table 4-17 depicts the villages and hamlets that fall within five (05) kilometre radii of the project area.

Table 4-17 Villages falling within five (05) kilometre radii.

District Tehsil Villages & Hamlets

Banas kantha Vav 1.Radhanesda 2.Kundaliya

Source: Google Earth Pro

4.4.4 Demographic profile of the Study Area

The demographic profile section below intends to present an understanding of the prevalent demography in the study area. The population of the study area has been analysed below with a focus on the size and its composition. 4.4.4.1 Population level Table 4-18 represents the population level of the study area.

Table 4-18 Population Level

Administrative Unit Total Population Male Population Female Population (2011) (2011) (2011)

District

Banas kantha 31,20,506 16,10,379 15,10,127

(51.6%) (48.3%)

Tehsil

Vav 2,46,156 1,28,166 1,17,990 (7.8%)

(52%) (47.9%)

Villages

Kundaliya 3327 1,703 1,624 (1.3%)

51.1% 48.8%

Radhanesda 1732 839 (0.7%) 893

51.5% 48.4%

Source: PCA 2011

It can be noted from the table above that Vav tehsil comprises of 7.8% (2,46,156) of the total population of Banas kantha district which stands at 31,20,506. Kundaliya village comprises of 1.3% (3327) and Radhanesda village comprises of 0.7% (1732) of the total population Vav Tehsil ((2,46,156).

The percentage of female population in all three (3) administrative units are below 50 percent as it is 48.3% and 47.9% in Banas kantha district and Vav tehsil respectively. At the village level the female population stands at 48.8% and 48.4% in Kundaliya and Radhanesda villages respectively. 4.4.4.2 Social stratification: Vulnerable groups, SCs and STs

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Vulnerable groups are those groups of people who may find it difficult to lead a comfortable life and lack developmental opportunities due to their disadvantageous positions. Further, due to adverse socio-economical, cultural and other practices present in each society, they find it difficult many a times to exercise their human rights fully11.

The accessibility to development opportunities or its absence thereof can be attributed to the level of integration and responsiveness to mediums which enhance and improve livelihoods. Marginalization from the resources can be a result of social exclusion thereafter hindering all round development and improvement of livelihood of these groups. Categories such as scheduled tribes, scheduled castes primitive tribal group, legally released bonded labour and manual scavengers and other backward classes are recognised as socially excluded categories by the constitution of India. Recognising the relative backwardness of these weaker/socio-economically disadvantaged sections of the society, the Constitution of India guarantees equality before the law (Article 14) and enjoins the State to make special provisions for the advancement of any socially and educationally backward classes or for SCs (Article 15(4)).

The section below aims to define the status of these socially excluded categories/ groups within the study area. Table 4-19 represents the presence of vulnerable sections of the community in the study area.

Table 4-19 Presence of Vulnerable Sections of Community within the study area

Administrative Unit Total SC Male SC Female SC ST Male ST Female ST Population Population Population Population Population Population Population (2011) (2011) (2011) (2011) (2011) (2011) (2011)

District

Bans kantha 31,20,506 3,27,460 1,69,288 1,58,172 2,84,155 1,44,355 1,39,800

(10.4%) (51.6%) (48.3%) (9.1%) (50.8%) (49.1%)

Tehsil

Vav 246156 44,071 22,900 21,171 2215 1180 1035

17.9%) (51.9% (48%) (0.8%) (53.2%) (46.7%)

Villages

Kundaliya 3327 646 337 309 16 9 7

(19.4%) (52.1%) (47.8%) (0.4%) (56.2%) (43.7%)

1732 3 2 1 0 0 0 Radhanesda (0.1% 66.6% 33.3% (-) (-) (-)

Source: PCA 2011

Table 4-19 above denotes that there is negligible presence of Scheduled Tribe (ST) and Scheduled Caste (SC) communities in the study area. At the district level, it is noted that the SC population comprises of 10.4% (3,27,460) and ST population comprises of 9.1% (2,84,155) of the total population (31,20,506). At the tehsil level, it is noted that the SC population comprises of 17.9% (44071) and ST population comprises of 0.8% (2215) of the total population (2,46,156).

At the village level, it is noted that Radhanesda village has no presence of Scheduled Tribe community while the SC community has a negligible presence of 0.1% (3) of the total population (1732). Kundaliya Village has 0.4% (3327) presence of ST community members and 9.4% (646) of SC Community members.

From consultations with the Sarpanches (Village Heads) of Radhanesda and Kundaliya villages it could be derived that there were no scheduled tribe communities present in the village. With regard to SC community it was stated that there is one (01) household present in Radhanesda village and in Kundaliya village SC community comprises of 10-15% of the total population. 4.4.4.3 Gender Profile

11 Human Rights of Vulnerable & Disadvantaged Groups; Dr. T. S. N. Sastry; University of Pune; 2012

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The Table 4-20 below represents the gender profile of the study area.

Table 4-20 Gender Profile of the Study Area

Administrative Unit Total Population Female Population Female Literate Female Workforce Population Population

District

Banas kantha 31,20,506 15,410,127 6,56,521 4,12,332 (48.3%) (38.5%) (33%)

Tehsil

Vav 2,46,156 1,17,990 42,988 44,215 (47.9%) (35.3%) (38.9%)

Villages

Kundaliya 3,327 1,624 516 933 (48.8%) (37.1%) (50.2%)

Radhanesda 1,732 839 149 399 (48.4%) (38.4%) (47.2%) Source: PCA 2011

The gender profile of the study area is presented in the table above. It can be noted that the female population in relation to the total population at all administrative units stand below 50 percent as Banas kantha District has 48.3% (15,410,127) and Vav tehsil has 47.9% (1,17,990) of female population. At the village level, Kundaliya village has 48.8% (1624) and Radhanesda village has 48.4% (839) of female population vis-à-vis the total population of 3327 and 1732 respectively.

Literacy level amongst the women in the area is also below 50 percent at all administrative units. Banaskantha district has 38.5% (6,56,521) Vav tehsil has 35.3% (42,988) and at village level, Kundaliya village has 37.1% (516) and Radhanesda village has 38.4% (149) of literate female population. There are various schemes being undertaken by the State government in order to improve and promote inclusive education. The schemes are Beti Bachao Beti Padao (BBBP) Scheme programmes which have been launched with the primary objective to empower the girl chid and ensure her education, essentially addressing the pre and post birth discrimination against the girl child, is implemented in the State of Gujarat.

Participation in the workforce population amongst the women in the study area also is below 50 percent. Bans kantha district has 33% (4,12,332) Vav tehsil has 38.9% (44,215) and at the village level Kundaliya village has 50.2% (933) and Radhanesda village has 47.2% (399) of women involved in the workforce population.

During consultations with the sarpanches of Kundaliya as well as Radhanesda village, it was stated the women of the village are primarily engaged in household chores. However, it was stated that the women worked in family owned agricultural fields during major agricultural activities such as cropping and harvesting as well as in agricultural lands of their family members.

4.4.5 Education level For measurement of literacy level in the census, any person aged seven years or above, who can both read and write any Indian language with understanding, is considered to be a literate person. The literacy level of the study area has been represented in this section.

The literacy level of the study area is presented in the Table 4-21 below:

Table 4-21 Literacy profile of Study Area

Administrative Unit Total Population Literate Population Literate Male Literate Female (2011) (2011) Population Population (2011) (2011)

District

Banskantha 31,20,506 17,04,923 10,48,402 6,56,521

(54.6%) (61.4%) (38.5%)

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Tehsil

Vav 2,46,156 1,21,485 78,497 42,988

(49.3%) (64.6%) (35.3%)

Villages

Kundaliya 3327 1388 872 516

(41.7%) (62.8%) (37.1%)

Radhanesda 1732 388 239 149

(22.4%) (61.5%) (38.4%) Source: PCA 2011 Table 4-21 above represents the literacy level in the study area. It can be noted that the literacy level is below 55 percent in all administrative units. It is further noted that the female literacy level at all administrative units is below 40 percent. The literate population in Banaskantha district is 54.6% (1704923) wherein 61.4% (1048402) comprises of male population. In the tehsil level, Vav tehsil has a literate population of 49.3% (121485) wherein 64.6% (78497) comprises of male population.

At the village level, it is noted that Radhanesda village has a dismal literacy percentage at 22.4% (388) while Kundaliya Village is at 41.8% (1388). During consultations with the sarpanches of Radhanesda and Kundaliya villages, it was stated that the reason for a very low female literacy percentage is due to cultural reasons such as early marriages that is still prevalent in the area as well as the after high school, girl children drop out of school and do not pursue further education as the nearest high school is located at a distance of 20 kilometres away from the village. Connectivity to and from the villages to the nearest village was yet to be strengthen hence girl children did not pursue further education.

4.4.6 Occupation and Livelihood Occupational pattern distribution of a population in an area indicates the development and diversification of an economy. The trend suggests that developed countries have higher distribution of population in the services and secondary sectors and the developing or underdeveloped countries have higher concentration of population in the primary (i.e. the agricultural) sector. For the Census Survey, the occupations are classified into Cultivators, Agricultural Labourers, Household (HH) Industries and Others12.

12 the type of workers that come under this category of 'OW' include all government servants, municipal employees, teachers, factory workers, plantation workers, those engaged in trade, commerce, business, transport banking, mining, construction, political or social work, priests, entertainment artists, etc

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Table 4-22 Occupational pattern in the Study Area

Admin. Unit Total Main Main Male Female Main Agri. Male Agri. Female Main HH Male HH Female Others Male Others Female Workforce Workforce Cultivator Cultivator Cultivator Labourers Labourers Agri. Industries Industries HH Occupation Occupation Others Populatio Population Population Population Population Population Population Labourers Industries Occupation (2011) (2011) (2011) n Population (2011) (2011) (2011) (2011) (2011) (2011) (2011) (2011) (2011) (2011) (2011)

District

Banas 12,48,600 10,12,080 4,35,409 3,79,070 56,339 2,39,333 1,62,991 76342 8,755 6,737 2018 3,28,583 2,30,918 97,665 kantha (81%) (43%) (97%) (12.9%) 23.6% (68.1%) (31.8%) 0.8% (76.9%) (23%) 32.4% (70.2%) (29.7%)

Tehsil

Vav 1,13,500 86,079 46,510 35,743 10,767 21,838 13,435 8,403 709 522 187 17,022 12,757 4265

(75.8%) (54%) (76.8%) (23.1%) 25.3% (61.5%) (38.4%) 0.8% 73.6% (26.3%) 19.7% (74.9%) (25%)

Villages

Kundaliya 1858 993 704 625 79 247 88 159 0 0 0 42 30 12

(53.4%) (70.8%) (88.7%) (11.2%) 24.8% (35.6%) (64.3%) (-) 4.2% (71.4%) (28.5%)

Radhanesda 845 32 9 9 0 4 4 0 0 0 0 19 16 3

(3.7%) (28%) (100%) (-) (12.5%) (100%) (-) `(-) (-) (-) (59.3%) (84.2%) (15.7%)

Source: PCA 2011

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Table 4-22 above denotes that majority of the population in all administrative units except for Radhanesda village is engaged in agricultural activities as their main occupation. Banas kantha district has 66.6 % of workforce population engaged in agricultural activities. Vav Tehsil has 79.3% engaged in agricultural activities. Kundaliya and Radhanesda villages have 95.6% and 40.5% respectively who are engaged in agricultural activities as their main occupation.

At the village level, it is noted that Radhanesda village has majority of its main workforce population engaged in Others occupation. During consultations with the Sarpanch of Radhanesda village, he stated that the Radhanesda community members were engaged as agricultural labourers and cultivators however as the agricultural practice in the village was limited, majority of the workforce population migrated to nearby towns of Tharad and Vav tehsil as semi-skilled and skilled workers. Families would migrate to these towns in search of better employment opportunities. They comprise about around 60-70 percent of the workforce population of Radhanesda village. 4.4.6.1 Land use pattern The details of land use pattern in the study area has been presented in the Table 4-23 below:

Table 4-23 Land Use Pattern of Study Area

Villages Total Area Forest Area under Barren & Permanent Land Cultura Fallows Curre Net (in Area Non- Un- Pastures and Under ble Land nt Area hectares) (in Agricultura cultivable Other Grazing Miscellan Waste other Fallo Sown Hectar l Uses (in Land Area Land Area (in eous Land than ws (in es) Hectares) (in Hectares) Tree Area (in Current Area Hect Hectares) Crops Hectare Fallows (in ares) etc. Area s) Area (in Hect (in Hectare ares) Hectares) s)

Kundaliya 4844.39 0 152.7 0 715.9 0 0 609.6 0 3366. 19

(3.1%) (-) (14.7%) (-) (-) (12.5%) (-) (69.4 %)

Radhanesd 844.61 0 0 0 333.2 0 41.21 0 0 470.2 a (-) (-) (-) (39.4%) (-) (4.8%) (-) (-) (55.6 %)

Source PCA 2011

Table 4-8 above represents the land-use pattern of the study area villages, it can be noted that the highest percentage of land use in Kundaliya village is the net area sown at 69.4% (3366.19) as well as in Radhanesda village wherein the net area sown is 55.6% (470.2). Permanent Pastures and Other Grazing Land Area form the second highest land use in both villages with Radhanesda village at 39.4% (333.2) and Kundaliya village at 14.7% (715.9). 4.4.6.2 Irrigation The table 4-24 below presents the irrigation pattern of the study area villages.

Table 4-24 Irrigation Pattern in Study Area

Village Total Area Total Net Area Sown Total Unirrigated Irrigated Land (in hectares) (in hectares) Land (in hectares) (in hectares)

Kundaliya 4844.39 3366.19 3366.19 0

(69.4%) (100%) (-)

Radhanesda 844.61 470.2 470.2 0

(55.6%) (100%) (-)

Source: VDA 2011

Table 4-9 above that 69.4% and 55.6 % of total area of Kundaliya village and Radhanesda village respectively are under agricultural activities. The net area sown in both villages are not irrigated. During consultations it was

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stated that the villages were entirely dependent on rainfall for agricultural activities. A canal had been constructed to supplement irrigation in the area however the benefits of the canal has not reached the area. Ground water could not be utilised for agricultural activities due to its high salinity. 4.4.6.3 Workforce Participation Rate As main workforce population comprises majority of the workforce population in the state, district and village levels.

Table 4-25 Workforce Population in the Study Area

Administrative Total Total Male Female Main Main Male Main Female Unit Population Workforce Workforce Workforce Workforce Workforce Workforce (2011) Population Population Population Population Population Population (2011) (2011) (2011) (2011) (2011) (2011)

District

Banas kantha 31,20,506 12,48,600 8,36,268 4,12,332 10,12,080 7,79,716 2,32,364

40% (66.9%) (33%) 81% (77%) (22.9%)

Tehsil

Vav 2,46,156 1,13,500 69,285 44,215 86,079 62,457 23,622

46.1% (61%) (38.9%) 75.8% (72.5%) (27.4%)

Villages

Kundaliya 3,327 1,858 925 933 993 743 250

55.8% (49.7%) 50.2% 53.4% (74.8%) (25.1%)

845 446 399 32 29 3 Radhanesda 1,732 48.7% (52.7%) 47.2% 3.7% (90.6%) (9.3%)

Source: PCA 2011

On review of, Table 4-25, it can be noted that the workforce population in all administrative units in the Study Area is below 60%. Banas kantha district has 40% (1248600), Vav tehsil has 46.1% (113500). At the village level, Kundaliya village has 55.8% (1858) and Radhanesda village has 48.7% (845).

Main workforce population in Banas kantha District stands at 81%(1012080) there are 77% (779716) males and 22.9% (232364) female workforce population. Vav Tehsil has75.8% (86079) engaged as main workforce population. At the village level, Kundaliya village has 53.4% (993) of main workforce population in which 25.1% (250) comprises of main female workforce population. In Radhanesda village,9.3% (03) women are engaged as main workforce population.

4.4.7 Physical Infrastructure and Civic Amenities 4.4.7.1 Health Profile and Infrastructure During consultations with the Kundaliya Village Panchayat it was stated that there is a Community Health Centre (CHC) in Kundaliya village. A nurse is present in the CHC during working hours for six (06) days a week.

There are three (03) Accredited Social Health Activists (ASHA) catering to the villages of Radhanesda and Kundaliya. One (01) each Rural Child Care Centres (Anganwadi Centres) is present in Kundaliya and Radhanesda village. Arogya Sanjiwani Wahan (Mobile Health Clinic) passes through the villages of Kundaliya and Radhanesda once a week. 108 Ambulance services operated under National Health Mission (NHM) is available in the village.

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The nearest hospital for delivery services is Tadav village located at a distance of approximately 20 kilometre from Radhanesda village. For other health emergencies, community members travel to Tharad located at a distance of approximately 30-40 kilometres from the village of Radhanesda and Kundaliya. 4.4.7.2 Drinking Water Drinking Water supply is primarily through panchayat supplied water pipes and is supplemented by privately owned borewells. 4.4.7.3 Sanitation Swachh Bharat Abhiyan scheme was stated to be implemented in both the villages. Consultations with Radhanesda and Kundaliya Sarpanches indicated that there was 100 percent coverage of Sanitation facilities in Kundaliya village. 4.4.7.4 Banks, Roads and Post Offices One post office is located in Kundaliya village. there is no presence of banks (government and private) in either Kundaliya and Radhanesda villages. State Highway (SH) 127 passes through village Kundaliya and connects Radhanesda village at a distance of eight (08) km from the site. The village roads are a combination of paved (pucca)and unpaved(kuccha) roads. 4.4.7.5 Electricity supply Radhanesda village is yet to receive electricity supply. Households in Radhanesda village have installed private solar panels within their premises for generation of electricity. While all households in Kundaliya village were stated to have electricity. 4.4.7.6 Cooking Fuel All households in Kundaliya and Radhanesda villages have Liquified Petroleum gas (LPG) connections. T is however further supplemented through the use of firewood/twigs collected from trees/plants within the household premises. 4.4.7.7 Religious Sites Limda Mata mandir(temple) is located within the premises of the upcoming solar power project. This temple was undergoing renovation during the time of site visit. All community member of Radhanesda and Kundaliya villages revere the temple and Navratri festival is celebrated there. Although, it is located within the project area it was stated by the project proponent, that there would be no restriction of access for the community members to visit the temple area.

Photo Documentation Government Middle School, Radhanesda village, Vav tehsil Limda Mata mandir(temple) is located within the premises of the Project area.

Water Tank at Radhanesda Village RCC and Unpaved Roads in Radhanesda village

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Government Middle School,Kundaliya village,Vav tehsil Lake in Kundaliya Village ,Vav Tehsil

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5. Stakeholder Engagement and Consultation 5.1 Introduction Stakeholder mapping refers to the process of identifying individuals or groups having influence over a project and assessing the effects of their actions on the project. Stakeholder mapping helps in identifying the different stakeholders as primary or secondary based on the degree of influence on a project and by analysing the stakes or interest each of them has in the project and the way both the stakeholder group as well as the project can benefit from each other.

Stakeholder identification and their inclusion in the decision-making process is critical in prioritizing, analysing and addressing issues; and developing management systems and mechanisms to address their respective concerns as well as apprehensions. This also helps in instilling trust within stakeholders regarding the project.

The AECOM team visited the project site from 7th- 9th January 2019. The team was able to conduct consultations with stakeholders in Radhanesda and Kundaliya villages. For the purpose of the project, stakeholder mapping has been carried out with the following objectives;

 Identify relevant stakeholder groups;  Study the profile and characteristics and the nature of stakes each stakeholder group has;  Assess their respective influence levels on the project; and

 Appreciate the precise issues and concerns as well as the expectations from the project that each group possesses. 5.2 Stakeholder Consultation and Disclosure Requirement for the project The disclosure of project information and consultations with stakeholders has been increasingly emphasized by project finance institutions and government regulatory bodies. A brief overview of the requirements of public disclosure and stakeholder consultation applicable to this project is provided in Table 5-1.

Table 5-1 Overview of Disclosure and stakeholder consultation requirement

Institution/ Reference Requirements Regulatory Regulation/ Body Standard IFC PS-1  Community engagement is to be undertaken with the affected communities and must be free of external manipulation, interference, or coercion, and intimidation.  Furthermore, in situations where an affected community may be subject to risks or adverse impacts from a project, the proponent must undertake a process of consultation so as to provide the affected communities with an opportunity to express their views on the project risks, impacts, and mitigation measures, as well as allow the proponents to consider and respond to them.  Informed participation: For projects with significant adverse impacts on affected communities, the consultation process must ensure that free, prior and informed consultation with affected communities occurs and that processes exist to facilitate participation by those affected.  Apart from such a consultation process, the project proponents are also to establish a Grievance Redressal Mechanism, which will allow the affected communities’ concerns and grievances about the project proponent’s environmental and social performance to be received and allow for steps to be taken to resolve the same  Broader stakeholder engagement: The proponent must identify and engage with stakeholders that are not directly affected by the project but those that have established relationships with local communities and/or interest in the project – local government, civil society organizations, etc. – and establish a dialogue.

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5.3 Stakeholder Categorisation A stakeholder is “any identifiable group or individual who can affect the achievement of an organization’s objectives or who is affected by the achievement of an organization’s objectives”1. Stakeholders thus vary in terms of degree of interest, influence and control they have over the project. While those stakeholders who have a direct impact on or are directly impacted by the project are known as Primary Stakeholders, those who have an indirect impact or are indirectly impacted are known as Secondary Stakeholders. Keeping in mind the nature of the project and its setting, the stakeholders have been identified and listed below.

Table 5-2 Stakeholder Group Categorisation

Stakeholder Groups Primary Stakeholders Secondary Stakeholders Community  Local Laborers  Local community  Agricultural Laborers  Vulnerable Communities  Grazing lad users Institutional Stakeholders  Developers and Contractors  Civil Society/ Local NGOs  Gram Panchayats Government Bodies  Regulatory Authorities  District Administration Other Groups  Migrant Workforce 5.4 Approach and Methodology of Stakeholder Analysis The significance of a stakeholder group is categorized considering the magnitude of impact (type, extent, duration, scale and frequency) or degree of influence (power and proximity) of a stakeholder group and urgency/likelihood of the impact/influence associated with the particular stakeholder group in the project context. The magnitude of stakeholder impact/influence is assessed taking the power/responsibility2 and proximity3 of the stakeholder group and the group is consequently categorized as negligible, small, medium or large. The urgency or likelihood of the impact on/influence by the stakeholder is assessed in a scale of low, medium and high. The overall significance of the stakeholder group is assessed as per the matrix provided below (Table 5-3):

Table 5-3: Stakeholder Significance and Engagement Requirement

Likelihood of Influence on/by Stakeholder Low Medium High Magnitude of Negligible Negligible Negligible Negligible Influence/ Small Negligible Minor Moderate Impact Medium Minor Moderate Urgent Large Moderate Urgent Urgent

5.5 Stakeholder Analysis Error! Reference source not found. has been used to classify the identified stakeholders (directly or indirectly impacting the project) in accordance to their levels of influence on the project. The influence and priority have both been primarily rated as:

 High Influence: This implies a high degree of influence of the stakeholder on the project in terms of participation and decision making or high priority to engage with the stakeholder;  Medium Influence: Which implies a moderate level of influence and participation of the stakeholder in the project as well as a priority level to engage the stakeholder which is neither highly critical nor are insignificant in terms of influence; and

1. Freeman, R. and Reed, D. (1983). Stockholders and Stakeholders: A new perspective on Corporate Governance. California Management Review. pp. 88 – 106. 2. Power/Responsibility: Those stakeholders to whom the organisation has, or in the future may have, legal, financial, and operational responsibilities in the form of regulations, contracts, policies or codes of practice. 3. Proximity: indicates stakeholders that the organisation interacts with most, including internal stakeholders, those with long- standing relationships and those the organisation depends on its day-to-day operations.

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 Low Influence: This implies a low degree of influence of the stakeholder on the project in terms of participation and decision making or low priority to engage that stakeholder. The intermediary categories of low to medium or medium to high primarily imply that their influence and importance could vary in that particular range subject to context specific conditions or also based on the responses of the project towards the community.

The coverage of stakeholders as stated above includes any person, group, institution or organization that is likely to be impacted (directly or indirectly) or may have interest/influence over project. Keeping this wide scope of inclusion in stakeholder category and the long life of project, it is difficult to identify all potential stakeholders and gauge their level of influence over project at the outset of the project. Therefore, the project proponent is advised to consider this stakeholder mapping as a live document which should be revised in a timely manner so as to make it comprehensive for any given period of time.

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Table 5-4: Stakeholder Analysis

Primary Stakeholder GPCL/ GUVNL/ GEDA  The entire project is located on  Constituting the Consultations with  The major concern High government land that has been most critical GPCL/ GUVNL/ GEDA of the stakeholder allotted to ESPL on lease basis for stakeholder group, pointed towards their group is that of a period of 25 years; GPCL that will allot concerns for regulatory compliance by the  It was reported that land are sandy, land for the project compliance by the players operating in barren, saline and uncultivable land have previously players operating in the the solar power power park including that are not used for agriculture done land allotment park. ESPL. purpose; for similar solar  The lease of such land will not projects in the result in any form of economic or neighbouring physical dislocation. As the land is districts – owned by the GPCL, no private Charanka solar procurement of land is necessary power park; for which the project will not result  It was reported that in landlessness; ESPL is obtaining  GUVNL is responsible for the land on lease development of the common basis; and infrastructure and utilities in the  The level of impact power park; and of loss of land is GEDA is responsible for providing envisaged to be clearances and permits for erection of negligible as none the power project and commissioning of of the land parcels the project including evacuation of located within the power. solar park or the ones allotted to ESPL are under cultivation. Developer and Contractors As indicated earlier, ESPL is the  Hassle-free  Non-compliance to The contractors and Medium developer for the 200 MW solar power procurement of the the legal sub-contractors play an project proposed to be set up on 2 land identified plots of requirements; important role during the parcels allotted by GPCL. The EPC land for the project;  Not meeting the project construction contract for the project is in the process and community phase for timely of being finalised. commissioning of the Smooth operation of the expectations; and project with quality construction activity and Leaving behind a legacy construction and within to complete the work of conflict-ridden the stipulated budgetary within the scheduled relationship with local provisions. time and cost. communities.

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Local Labourers  A considerable section of the The local wage earners  Any labour unrest The major concerns of Medium working population of the local area have developed high and protests will this stakeholder group are agriculture labourers; expectations for cause delays in include: -  Due to the lack of industries in the employment in the construction  Regular payment of region, the availability of project. schedule and wages for the work employment in the unskilled create a non- rendered; category is limited; and congenial social  Continued  However, during the harvesting atmosphere; and employment even season, availability of unskilled  The delay in beyond the labour is a concern. construction completion of activities will have construction work; financial  implications on the Health and Safety project. issues at work; and  Holidays and leaves as per labour laws applicable etc.

Gram Panchayats (GPs)  Constituting the lowest strata of The project will create  GPs play an The expectations/ Medium Decentralized Local Governance in collective benefit for the important role in concerns of the GPs the Country, a typical Panchayat local community. overall mobilization include; consists of one or more revenue and shaping the  Employment villages. This body of local perception and Opportunities for governance was created through opinions of the the Local Youth; the 73rd Amendment to the people in the  Constitution of India; and project area. They CSR activities for development of Sarpanch and other members of also serve as the local area; and the Gram Panchayat need to be official forum for  actively involved in various consent and Nature of impact activities relating to the economic approval required that the project development and social justice of for the project. would have on the their Panchayat. The smooth and livelihoods of hassle-free functioning of the communities. project is also the onus of the Panchayats.

Regulatory Authorities  The office of District Industries The project will comply  - The sole expectation of Low Commissioner (DIC) regulates with the applicable the Regulatory regulatory framework Authorities from the

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Industrialization at the District comprising of the project Proponents is Level; and guidelines and policies abidance to all  Gujarat Transmission Corporation of the State Government applicable guidelines, Limited (GTCL) for power such as the Gujarat evacuation/ grid connectivity etc. Solar Power Policy policies and laws. 2019. Permission and coordination with the District Industries Centre, Banaskantha is mandatory for creation of local infrastructure and smooth operation of the industry.

District/Tehsil Administration  The project area is administered at The process of land  There are several The key concerns of the Low three levels by different lease registration for the permissions and District Administration Government Bodies: at the district 2 land parcels was regulatory authorities might level, at the block/tehsil level and at reported to have been approvals that are the Panchayat level in each completed at the time of required prior to as include; village/or cluster of villages; the site visit. The District well as after the  Matters concerning  In this context, local administration Administration has construction of the local employment; refers to the district level and block played a significant role project from the  Preference to local level administration comprising of in the matter in District youths in matters of the offices of the Tehsildar, District collaboration with the Administration. vehicle hire and Magistrate Collectors, and GPCL. Delay in issuance of issuance of Revenue officer etc.; and the relevant permits contract job etc.; 1. The sub-registrar of the revenue can adversely and department is responsible for impact the timely Local area development registration of sale of land, land execution of the through CSR project. Similarly, mutation, updating of records of interventions. transfer of land. unresolved matters relating to land such as litigation, non- payment of compensation and encroachment might create complications, drag the firm into legal disputes thereby

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Migrant Workforce  Project-related construction  Migrant workers  Retaining the The major concerns of Low activities are yet to be allotted to may see this as a migrant workforce, this stakeholder group any contractors. An estimated better economic especially during may include; migrant workforce comprising of and livelihood the construction  Regular payment of 180 - 200 labourers will be opportunity for phase of the project wages for the work engaged in the project-specific them; and is extremely critical. rendered; construction activities, especially in  The fluctuation of This is because  Continued the skilled and highly skilled the supply of local there are similar employment even categories accounting for 30 % of labour in harvest experiences of the beyond the the total workforce. and other lack of availability of completion of agricultural peak manpower in the construction work; seasons can be local area.  met by deployment Health and Safety of migrant workers. issues at work;  Holidays and leaves as per labour laws applicable etc.; and  Issues relating to conflicts with the local labour and host community. Secondary Stakeholders Local Community  The stakeholder group comprising  There are several  The broad support  Expectations of  Low of local communities around a community of the local getting employment radius of 2 kms inhabit the Villages members who community will benefits from the of Radhanesda and Tharad might be indirectly create a hindrance project; and  The study area comprises of; dependent on the or risk-free  Growing o Caste Hindus: Brahmins; land proposed to business process. community o SC: Holar; and be sold to the demands for o Minorities: Muslims, mostly project, and hence implementing Sunni; and must be welfare  The community in the study area is compensated interventions in the dependent on wage labour and through adequate region by the other labour-intensive activities entitlements. project Proponent. such as civil construction.  In addition, the Agriculture and livestock rearing CSR activities

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Stakeholder Category Relevant Stakeholders Profile/Status Impact/Influence of Impact/Influence of Expectations, Overall Rating of the project on this the Stakeholder Opinions Key Stakeholder Stakeholder Group Group on the Concerns of Influence project Stakeholders are not the major sources of focused on livelihood. education and health, among others should also target at the neighbouring villages and the immediate local community which will lead to improvement in livelihood. Vulnerable Communities  This stakeholder group comprises  In view of the poor  The stakeholder . Key concerns of . Low of SC Communities in the study social and group will have a this stakeholder area. SCs account for economic negligible impact on group will primarily approximately 12 – 14 % of the conditions of the the project. revolve around total population in the study area. Vulnerable targeted support Communities, the being extended for project Proponent availing the may have to benefits of provide community engagement interventions by the avenues to its project Proponent. members. . Agricultural Laborers  There are only a few large farmers  Land for the project  The stakeholder Low in the study area. Most of the group will have a is located on farmers are small to marginal negligible impact on sandy, saline, farmers who cultivate their land and the project. work as agricultural Laborers, barren and mostly in neighbouring farms uncultivable land situated at a distance of 10 – 15 where no farming kms from the study area; activities are  The agricultural census of India undertaken; and defines farmers on the basis of the  The local following; community will be o Marginal – Farmers having less benefitted by than one hectare of land; means of the local employment

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Civil Society/Local NGOs  The local NGOs, mostly based out With respect to  The NGOs and The opinion of the Low of the Cities of Ahmedabad, Civil Society contributing towards the NGOs and Civil Society Gandhinagar and Rajkot are acting cause of local Groups often play a Groups towards a as a social watchdog in matters development, the project critical role in relating to securing the livelihoods proponent can either bringing to the project is determined of rural communities along with participate in the limelight the issues largely by whether the ongoing developmental their related socio-cultural facets; of vulnerable activities of the impacts of setting up of and Government or might the development venture

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 However, the number of such take up interventions on communities in the is being viewed/ its own or through society; and NGOs active in the study area perceived in positive partnerships with NGOs  They can also play is highly limited. light by the local and CBOs after a major role in obtaining prior approval community population with special from competent mobilization, reference to the authorities. building trust and vulnerable communities

even participate in or not. The key concerns implementing CSR of this stakeholder group initiatives. centres around justice and equal opportunities in matters of economic and social development being provided to the . Vulnerable Communities.

Note: It is significant to note that the stakeholder analysis is based on the current situation. The stakeholder influence on the project is dynamic and may change during the project life. Consequently, the stakeholder analysis needs periodical reassessment and updating.

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Summary of overall stakeholder influence is presented in the Table 5-5-5.

Table 5-5 Summary of overall stakeholder influence

Stakeholder Relevant Magnitude of Likelihood of Overall Rating of Category Stakeholders Influence/Impact Influence on/by Stakeholder Stakeholder Influence Primary GPCL/ GUVNL/ EDA High High High stakeholder Developers and Contractors Medium Medium Medium Local Labourers Negligible Medium Medium Gram Panchayats Medium Negligible Medium Regulatory Authorities Negligible Negligible Low District/ Tehsil Administration Negligible Negligible Low Migrant Workforce Negligible Negligible Low Secondary Local Community Negligible Negligible Low Stakeholders Vulnerable Communities Negligible Negligible Low Agricultural Labourers Negligible Negligible Low Civil Society/Local NGOs Negligible Negligible Low

5.6 Stakeholder Consultations and Engagement The section provides a summary of the consultations undertaken with the Stakeholders of the project. Participant List for the stakeholder consultations undertaken have been provided as Appendix A

5.6.1 Consultations with Mamlatdar (Magistrate Executive), Department of Revenue, Vav Tehsil. Basic details Location: Vav District: Banas kantha Project Title: ESIA of 200 MW solar power project of ESPL Date: 9th January 2020 Stakeholder Group Title: Mamlatdar, Department of Revenue, Vav Tehsil

Objective of the Interview/Consultation To understand the historical genesis, associated encumbrances and related issues with the Radhanesda Power Park. Guiding Questions or Points for Discussion 1. What has been the historic and recorded use of the land encompassing the Power Park?

The land use of the designated solar power park is barren land. No agricultural activity has been undertaken in the land parcel due to the infertility of the land parcel with its high saline content making it unfavourable for agricultural.

2. For how many years has the government been owning the land?

As the project area is in a strategic location near Indo-Pakistan border area. The land has always been owned by the Government of Gujarat.

3. Till when can the records of ownership/ Record of Rights (RoR) of the Power Park land be traced?

It has always been owned by the Government of Gujarat. 4. Are there any issues of encumbrances/ encroachments?

There were no physical structures such as house/homes within the project area as the area is a Border Security Force (BSF) controlled area, every person entering the premises has to register and submit proof of identity on venturing into the area.

5. Are there or have there been any settlements/ structures on the concerned land?

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Within the premises of the Solar Power Park, there is one (01) temple Limda Mata Mandir. The temple is utilized by community members of Radhanesda and Kundaliya village. However, the solar power plant is also the access road for the temple and will be utilised by both Kundaliya and Radhanesda village population to reach the temple. 6. For how many years is the land being leased to the Power Producers?

The land has been handed over to GPCL by the Revenue department. Hence the details of such is not available with his office.

Photo Documentation Consultation with the Mamlatdar, Vav Tehsil

5.6.2 Consultations with Sarpanch (Village Head) of Radhanesda Village Panchayat Radhanesda village previously was under Kundaliya Panchayat. However, in the year 2018, Radhanesda Village Panchayat was formed. There is one (01) village Radhanesda Village under Radhanesda Village.

Summary of consultations undertaken with the Sarpanch of Radhanesda village on 8th January 2020 has been presented in the table below. Basic details Location: Radhanesda Village,Vav Tehsil District: Banaskantha Project Title: ESIA of 200 MW solar power project of ESPL Date: 8th January 2020 Stakeholder Group Title: Sarpanch (Village Head) of Radhanesda Village

Objective of the Interview/Consultation To understand the socio-economic baseline of Radhanesda village and an assessment of the perception of the upcoming project amongst the community members.

Key discussion points 1 What is the demographic of the village?

Approximately 1971 population are present in Radhanesda village residing in approximately 600 households. It comprises of 60 percent Male population and 40 percent female population.

2 Communities present in the village and their primary occupational activity.

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All members fall under the Other Backward Classes (OBC) community of the villages which is divided into sub-castes of Thakur (Kohli) and Rabari Communities. It was stated that all these communities fall under the Other Backward communities (OBC) in Gujarat.

 Thakurs are primarily involved in agricultural activities. They are small- marginal landowners but they also work as agricultural labourers on fields within the village and other nearby villages.  Rabari community members comprises of approximately 25 percent of total population of Radhanesda village. Rabari Community is traditionally a pastoral nomadic community of the Kutch region. They were traditionally camel herders, in present times they rear cattle, sheep and goats. They are highly dependent on the sale of dairy products. Nearest dairy is present in Kundaliya village

3 Occupational Pattern and Livelihood Activities.

 Primary occupational activity comprises of cultivators and agricultural labourers. The agricultural activity was largely dependent on rainfall in the area. Agricultural labourers receive a daily wage of 300-350 per day in the village. Women are also engaged as agricultural labourers in the village.  Live-stock rearing was a primary occupational activity amongst the Rabari community.  Secondary occupational activity comprises of semi- skilled workers for government schemes such as MGNREGA scheme which ensures 100 days of employment for the enrolled working population. Semi- skilled which nearby towns of Tharad and Vav Tehsil.

4 Agricultural Crops Grown in the area

 The primary agricultural crops grown in the village is Cumin (local name: Jeera) is the primary crop grown in the area. Pearl Millet (local name: Bajra) is grown in the area. It is a single crop season in the area. Cumin (local name: Jeera) is the main cash crop of the area. The nearest agricultural market is located in Tharad Tehsil.

Livestock Population

 It was stated that all households in the village possess livestock. Majority of the reared livestock is for self-consumption. Rabari community members are dependent on livestock for their livelihood as well. Rabaris who were traditionally camel herders, in present times rear sheep and goats.  They sell the dairy products to dairy cooperative present in Kundaliya village. It was stated that each Rabari household on an average owned 100 number of livestock in the village.

5 Migration Trend in the Village

 It was stated that as the lands in the village were not very fertile and agricultural activity was minimal in the village. Community members of the village practiced season migration to nearby villages to work as agricultural labourers as well as nearby towns for semi-skilled employment opportunities. Migration was specifically very high during the dry summer months of April and May as the village faced water scarcity and there was reduction (around 90 percent) in agricultural activities.  Rabari community members also migrated to nearby villages in search of green pastures especially during the dry season.  It was stated that as the youth population of the village also migrated to nearby towns to work as semi -skilled workers as well as agricultural labourers in nearby villages. Hence the migration trend amongst the youth population was high in the village.

6 Educational Profile

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 Radhanesda village has one (01) Middle School within its premises. It was stated that Kundaliya village has been sanctioned funds for the upgradation of its existing middle school to a High school. At present, the nearest high school is in Tadav village located at a distance of approximately 20 kilometres away from Radhanesda village.  Three primary reasons for high dropout rate were:

a. travel to Tadav village posed as a challenge especially for the girl children; b. the average age of marriage for girls was around 15-16 years and c. Children along with their parents seasonally migrate with their parents during the lean/dry seasons to nearby villages/towns in search of employment opportunities.

7 Women Profile

 All girl children of Radhanesda village were enrolled in school. However, it was stated the girl children after Class 8 had a higher dropout rate. Three primary reasons for high dropout rate were i. Nearest high school is in Teda Village which is located at a distance of 20 kilometres travelling to Teda posed as a challenge especially for the girl children; ii. the average age of marriage for girls was around 15-16 years and, iii. Children along with their parents seasonally migrate with their parents during the lean/dry seasons to nearby villages/towns in search of employment opportunities.  Women of the village are primarily engaged in household chores. However, it was stated that the women worked in family owned agricultural fields during major agricultural activities such as cropping and harvesting as well as in agricultural lands of their family members.

8 Youth Profile

The youth of Radhanesda village were primarily engaged as agricultural labourers if they resided in the village. Majority of the youth approximately 60 percent of youth migrated to nearby villages and towns to pursue employment opportunities. Majority of the youth were educated upto class 8. Girl children/youth were engaged in household work and 9 Social Perception of Project:

Community Members of Radhanesda village are aware of the upcoming 700 MW Solar Power Park Project. It was stated that the people were positive about the upcoming project. As there were other solar power projects within the state of Gujarat, community members were aware of a Solar Power Project. 10 Benefits/ Expectations from the Project

11 Concerns regarding the Project He stated that prior to the initiation of the project, there was discontentment amongst the community members as the project area served as grazing area for the community members. However, after negotiations with the government has now earmarked approximately 167.96 acres as Grazing (Gauchar) land within the project area. After which the community members do not have any concerns regarding the project area.

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Photo Documentation Consultation with the Sarpanch of Radhanesda View of the Village Panchayat Ghar Village Panchayat

5.6.3 Consultations with Sarpanch (Village Head) Kundaliya Village Panchayat Summary of consultations undertaken with the Sarpanch of Kundaliya village on 8th January 2020 has been presented in the table below.

Basic details Location: Kundaliya Village, Vav Tehsil District: Banaskantha Project Title: ESIA of 200 MW solar power project of ESPL Date: 8th January 2020 Stakeholder Group Title: Sarpanch (Village Head) of Kundaliya Village

Objective of the Interview/Consultation To understand the socio-economic baseline of Kundaliya village and an assessment of the perception of the upcoming project amongst the community members. Key discussion points 1 What is the demographic of the village?

It was reported that at present, approximately 6000-7000 people are residing in the village, comprising 60% of male population and 40% female population.

2 Communities present in the village and their primary occupational activity.

Most members fall under the communities listed under the Bakshi Commission and are further divided into the Thakur and Rabari Communities. It was stated that both of these communities fall under the Other Back Ward communities (OBC) in Gujarat State. Rabari communities are enlisted as Scheduled Tribes in some other parts of Gujarat state. Apart from these communities, a small number of Harijan community members are also residing in the village. The Harijan community falls under the Scheduled Caste in the Gujarat State.

Thakurs are primarily involved in agricultural activities. They comprise of both landowners as well as agricultural labourers on fields of other community members.

Rabari Community Members comprise approximately 200 households of the Kundaliya Village. Rabari Community is traditionally a pastoral nomadic community of the Kutch region. They were traditionally camel herders, in present times they rear cattle, sheep and goats. They are highly dependent on the sale of dairy products for their livelihood. Nearest dairy is present in Kundaliya village.

3 Occupational Pattern and Livelihood Activities.

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Primary occupational activity comprises of cultivators, agricultural labourers and livestock breeding. The agricultural activity was largely dependent on rainfall in the area. Agricultural labourers receive a daily wage of 300-350 per day in the village. It was stated that the entire family including women and children above the age of 15 are engaged as agricultural labourers in the village.

During summers, owing to the scarcity of water in the village, most of the population move out to work as agricultural labours or workers in livestock care and breeding farms.

Secondary occupational activity comprises of semi- skilled workers for government schemes such as MGNREGA scheme which ensures 100 days of employment for the enrolled working population.

It was reported that recently, a small part of youth has also started moving to the cities such as Ahmedabad to work in the diamond manufacturing sector.

The average family income was reported to be INR 50-60,000 per year in the Kundaliya village.

4 Agricultural Crops Grown in the area The primary agricultural crop grown in the village is Cumin (local name: Jeera). It is a single season crop grown during winters. It is the main cash crop of the area. The nearest agricultural market is located in Tharad Tehsil. It was reported that recently the cultivation of pomegranate has also been started in the village, however, it has not been very successful due to the water intensive nature of the crop.

Livestock Population

It was stated that all households in the village possess livestock. Majority of the reared livestock is for self-consumption but for Rabari community members livestock is also the means of their livelihood. Rabaris who were traditionally camel herders, in present times rear sheep and goats as well. They sell the dairy product to dairy cooperative present in Kundaliya village. It was stated that the number of livestock in each Rabari household was on an average around 100.

As per the Census 2011 data procured from the Village Veterinary Officer, the village had 1857 goats, 1905 buffaloes, 887 Sheep and 224 goats.

5 Migration Trend in the Village

It was stated that as the lands in the village were not very fertile and agricultural activity was minimal in the village. Community members of the village migrated in significant numbers to nearby villages to work as agricultural labourers as well as nearby towns for semi-skilled employment opportunities. Migration was specifically very high during the dry summer months of April and May as the village faced water scarcity and there was reduction (around 90 percent) in agricultural activities.

It was stated that as the youth population of the village also migrated to nearby towns to work as semi-skilled workers as well as agricultural labourers in nearby villages. Hence the migration trend amongst the youth population was high in the village.

6 Educational Profile

Kundaliya village has one (01) Middle School within its premises. It was stated that Kundaliya village has been sanctioned funds for the upgradation of its existing middle school to a High school. At present, the nearest high school is in Tadav village located at a distance of approximately 14 kilometres away from Kundaliya village.

Three primary reasons for high dropout rate were: i. Travel to Tadav village posed as a challenge especially for the girl children;

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ii. the average age of marriage for girls was around 15-16 years and iii. Children along with their parents seasonally migrate with their parents during the lean/dry seasons to nearby villages/towns in search of employment opportunities.

7 Women Profile

It was reported that approximately 400 children of the village are going to school. These comprise of 40% girl children. However, it was stated the dropout rate after class 8 was much higher for girl students. Three (03) primary reasons for high dropout rate included the following: i. Nearest high school is in Tadav Village which is located at a distance of 14 kilometres and travelling to Tadav posed as a challenge especially for the girl students and the frequency and availability of buses was quite low, plying only at certain hours of the day; ii. the average age of marriage for girls was around 15-16 years and iii. Children along with their parents seasonally migrate with their parents during the lean/dry seasons to nearby villages/towns in search of employment opportunities.

8 Social Perception of Project:

Community Members of Kundaliya village are aware of the upcoming 700 MW Solar Power Park Project. It was stated that the people were positive about the upcoming project. They are hopeful of getting employment through the upcoming project. As there were other solar power projects within the state of Gujarat, community members were aware of a Solar Power Project.

9 Benefits/ Expectations from the Project

 They anticipated increased employment opportunities in terms of skilled and unskilled workers, contract and vendor opportunities as well.  Benefits that were anticipated for the project was improvement in the transportation facility in the area.  Additionally, recognition of the village and provision of more resources is being anticipated by the village population.

10 Concerns regarding the Project The general perception of the people was positive towards the solar plant. The initial concern regarding acquisition of their grazing land was resolved through provision of 167.96 acres of grazing (known as Gauchar in the local language) land to the Kundaliya Panchayat. However, it was stated that the village population had high expectations of getting employment from the project and were apprehensive to the idea of sourcing labour from outside the village.

Photo Documentation Consultation with the Sarpanch of Kundaliya Village Panchayat

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5.6.4 Consultations with Opinion Leader of Kundaliya village Summary of consultations undertaken with the Opinion Leader of Kundaliya village on 8th January 2020 has been presented in the table below Basic details Location: Kundaliya Village, Vav Tehsil District: Banaskantha Project Title: ESIA of 200 MW solar power project of ESPL Date: 8th January 2020 Stakeholder Group Title: Opinion Leader of Kundaliya Village

Objective of the Interview/Consultation To understand the perception of the upcoming project amongst the community members. Need Assessment of the village.

Key discussion points 1 Youth Profile

Youth of the village were stated to have attained minimum education of 8th standard (Middle School). Majority approximately 60-70 percent of them dropped out after completion of middle school. The youth of the village were engaged as agricultural labourers in the village and semi- skilled workers in nearby villages and towns.

2 Social Perception of Project:

Community Members of Kundaliya village are aware of the upcoming 700 MW Solar Power Park Project. It was stated that the people were positive about the upcoming project as there was a lack of industrial units and factories in the areas.

Additionally, as there were other solar power projects within the state of Gujarat, community members were aware of Solar Power Project. 3 Benefits/ Expectations from the Project There were certain expectations of the community members from the project. The following expectations have been listed below:

 They anticipated increased employment opportunities for the youth of the villages of Radhanesda and Kundaliya villages. Employment opportunities in unskilled, semiskilled and skilled were expected from the project.  Contract and vendor opportunities for material requirement along with logistics support were expected from the local community.

4 Concerns regarding the Project

He stated that the community members had no concerns/issues with the project. On discussions regarding the grazing area present within the project area premises. It was stated that as the community members had been assigned the grazing (gauchar) land, the locals no longer had any problems/concerns with the upcoming project.

5.6.5 Consultations with Principal/Teacher, Government Middle School, Radhanesda village, Vav Tehsil Basic details Location: Radhanesda Village, Vav Tehsil District: Banaskantha Project Title: ESIA of 200 MW solar power project of ESPL Date: 8th January 2020 Stakeholder Group Title: Principal/Teacher of Government Middle School, Radhanesda village, Vav Tehsil

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Objective of the Interview/Consultation To understand the educational profile of the village as well as to get an understanding on perception of the upcoming project amongst the community members. Additionally, to understand the needs of the village.

Key discussion points 1 Educational Profile

 There is one (01) Middle School I Radhanesda Nearest village of Kundaliya has recently been sanctioned funds for the upgradation of its existing middle school to a High school. At present, the nearest high school is in Teda village located at a distance of approximately 20 kilometres away from Radhanesda village.  Three primary reasons for high dropout rate were:

a. travel to Teda village posed as a challenge especially for the girl children;

b. the average age of marriage for girls was around 15-16 years and c. Children along with their parents seasonally migrate with their parents during the lean/dry seasons to nearby villages/towns in search of employment opportunities.

2 Youth Profile

3 Social Perception of Project:

Community Members of Radhanesda village are aware of the upcoming 700 MW Solar Power Park Project. The people viewed the project positively as they anticipated employment opportunities from the project. As there was a need to diversify the livelihood opportunities of the people of Radhanesda village.

Additionally, as there were other solar power projects within the state of Gujarat, community members were aware of Solar Power Project.

4 Benefits/ Expectations from the Project There were certain expectations of the community members from the project. The following expectations have been listed below:

5 Concerns regarding the Project

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Government Middle School, Radhanesda village,Vav tehsil

5.6.6 Consultations with Anganwadi Worker, Kundaliya Village, Vav Tehsil Basic details Location: Radhanesda Village, Vav Tehsil District: Banaskantha Project Title: ESIA of 200 MW solar power project of ESPL Date: 8th January 2020 Stakeholder Group Title: Principal/Teacher of Government Middle School, Radhanesda village, Vav Tehsil

Objective of the Interview/Consultation To understand profile of women and children of Kundaliya and Radhanesda village. Key discussion points 1 Profile of Children  It was stated that all children of Kundaliya village attended the Anganwadi located in the village. It serves a creche and a additional nutritional centre for the children of the village.  Vaccinations for all children are undertaken within the premises of the Anganwadi centre.

 There were no major diseases/epidemics found amongst the children of Kundaliya and Radhanesda villages.

2 Women Profile

Most women of the villages of Kundaliya and Radhanesda were engaged in household chores. However, few women worked as agricultural workers in family owned fields as well fields of other community members. Few women were engaged in tailoring activities within the premises of their homes. Tailoring related training was undertaken by a private entity in the year 2019 and had distributed around 30 tailoring machines on completion of training.

3 Health Profile of Women Women were stated to suffer from normal diseases. There is no prevalence of increase women related diseases in the villages of Kundaliya and Radhanesda. Ante Natal Check-up (ANC)and Post Natal Check-ups (PNC) were conducted regularly by CHC in Kundaliya village and awareness of importance of institutional deliveries were spread by the ASHAs in the village.

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Photo Documentation Consultation with the Anganwadi Worker

5.6.7 Consultations with Veterinary Officer, Vav Tehsil Basic details Location: Vav Tehsil District: Banaskantha Project Title: ESIA of 200 MW solar power project of ESPL Date: 9th January 2020 Stakeholder Group Title: Veterinary Officer, Directorate of Animal Husbandry, Vav Tehsil

Objective of the Interview/Consultation To understand the Livestock Status, government schemes that are implemented in Radhanesda and Kundaliya villages. An understanding of livestock status of Rabari community members.

Guiding Questions or Points for Discussion 1 Status of Livestock in Kundaliya and Radhanesda village According to the Livestock census of 2011, there are following number of livestock in this villages: Village Cows Buffalo Sheep Goat Total

Kundaliya 1857 1905 887 224 4873

Radhanesda 1266 1264 540 `994 4064

Source: Livestock Census 2011

On an average, every household in Kundaliya and Radhanesda villages possessed livestock. Each household were able to produce diary at least for self-consumption.

2 Government Schemes implemented in these villages

The following vaccinations are given to the livestock in these villages:  Semi- Annual Vaccination for Foot and Mouth Disease  Annual vaccination against Haemorrhagic septicaemia (HS)

 Annual vaccination against Peste des petits ruminants (PPR) for the livestock Additionally, regular camps for infertility and surgical camps are conducted in Radhanesda and Kundaliya village.

3 Any recurrent diseases/epidemics of amongst the livestock of the study area villages

There is no pattern of recurrent diseases/epidemics amongst livestock in these study area villages.

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4 Veterinary Facilities in the Study Area

The nearest Veterinary dispensary for Radhanesda and Kundaliya village is in Mavsari village. Mavsari village is located at a distance of approximately ten (10) kilometres. At present, it was stated that there were no plans to develop/construct a veterinary Dispensary in the study area villages. Another dispensary is present in the Sanval village, located at a distance of 15 km from the villages.

5 Livestock Status of Rabari Community It was stated that the livestock status of the Rabari community had increased over the years. Earlier they were cattle herders but at present times they reared primarily sheep and goats. The health status of livestock owned by Rabari community members were healthy and well-looked after. They utilised available pasturelands of Kundaliya and Radhanesda villages. Alongside livestock were also grazed on lands were Bajra was previously grown after the harvesting season. Additionally, the cattle/sheep and goats would require supplements to enhance their nutritional growth.

Photo Documentation Consultation with the Veterinary Officer, Vav Tehsil

5.6.8 Focus Group Discussions with Rabari Community Members Summary of discussions held with Rabari Community members on 9th January 2020 has been presented in the table below.

Basic details Location: Radhanesda Village, Vav Tehsil District: Banaskantha Project Title: ESIA of 200 MW solar power project of ESPL Date: 9th January 2020 Stakeholder Group Title: Rabari Community Members

Objective of the Interview/Consultation To understand the socio-economic situation, lifestyle and livelihood of Rabari community. To understand the perception of the community members on the upcoming solar power park.

Key discussion points 1 Number of households belonging to Rabari Community Members

There are 100 Rabari community households in Kundaliya village and 25 households in Radhanesda village

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2 Occupational Pattern and Livelihood Activities.

Primary occupational activity for the Rabari community members is livestock rearing. In earlier times, Rabari communities were engaged as cattle herders however in recent times, they have started rearing cattle, sheep and goats. Dairy farming was the primary source of income for Rabari communities.

3 Lifestyle Trends

The Rabari have permanent houses in the villages of Kundaliya and Radhanesda villages. They have built houses of permanent and temporary structures within the premises of the village. 4 Migration Trend

It was stated that during the dry months of April and May, one (01) member of the family travels to nearby villages such as Mavsari, Tadav in search of pasturelands for their livestock. 5 Livestock Population

All Rabari households in the village possess livestock. Majority of the reared livestock is for self- consumption. On an average one Rabari household owns 100 livestock. Most of the livestock comprises of sheep and goats.

6 Migration Trend amongst the Rabari communities

During the dry months of April and May, there is substantial reduction in the grazing area for their livestock. Hence during they travel to nearby villages/districts looking for greener pastures for their

It was stated that as the lands in the village were not very fertile and agricultural activity was minimal in the village. Community members of the village practiced season migration to nearby villages to work as agricultural labourers as well as nearby towns for semi-skilled employment opportunities. Migration was specifically very high during the dry summer months of April and May as the village faced water scarcity and there was reduction (around 90 percent) in agricultural activities. Rabari community members also migrated to nearby villages in search of green pastures especially during the dry season.

It was stated that as the youth population of the village also migrated to nearby towns to work as semi -skilled workers as well as agricultural labourers in nearby villages. Hence the migration trend amongst the youth population was high in the village.

7 Educational Profile

Radhanesda village has one (01) Middle School within its premises. It was stated that Kundaliya village has been sanctioned funds for the upgradation of its existing middle school to a High school. At present, the nearest high school is in Teda village located at a distance of approximately 20 kilometres away from Radhanesda village. Three primary reasons for high dropout rate were: i. Travel to Teda village posed as a challenge especially for the girl children; ii. the average age of marriage for girls was around 15-16 years and iii. Children along with their parents seasonally migrate with their parents during the lean/dry seasons to nearby villages/towns in search of employment opportunities. 8 Women Profile

All girl children of Radhanesda village were enrolled in school. However, it was stated the girl children after Class 8 had a higher dropout rate. Three primary reasons for high dropout rate were i. Nearest high school is in Teda Village which is located at a distance of 20 kilometres travelling to Teda posed as a challenge especially for the girl children; ii. the average age of marriage for girls was around 15-16 years and iii. Children along with their parents seasonally migrate with their parents during the lean/dry seasons to nearby villages/towns in search of employment opportunities.

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Youth Profile

Benefits/ Expectations from the Project

Concerns regarding the Project He stated that prior to the initiation of the project, there was discontentment amongst the community members as the project area served as grazing area for the community members. However, after negotiations with the government, an area of approximately 167.96 acres have been earmarked as Grazing (Gauchar) land within the Radhanesda Solar Park. After the grazing area was designated by the government, the community members do not have any concerns regarding the project area.

Photo Documentation Consultation with the Rabari Community of the Kundaliya Village

5.6.9 Consultations with the Gujarat Power Corporation Limited (GPCL)

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Basic details Location: Gandhinagar District: Gandhinagar Project Title: ESIA of 200 MW solar power project of ESPL Date: 6th January 2020 Stakeholder Group Title: Head – Projects

Objective of the Interview/Consultation To understand the key functions of GPCL and its specific responsibilities in the development of the Radhanesda Solar Power Park. Guiding Questions or Points for Discussion  What is the key role of GPCL in the power sector of Gujarat?

GPCL is primarily engaged in the business of power generation and distribution. Incorporated under the Companies Act, 1956, the company has been designated as the Nodal Agency by the Government of Gujarat for development of Solar Parks in the state.  What are the major functions of GPCL?

The major functions of GPCL include: -

 Identification of the need for setting up power projects based on various forms of fuel;  Preparation of techno-economic feasibility Reports for the identified power projects;  Identification of private players to collaborate and implement the identified power projects under the PPP mode;  Obtaining the statutory and non-statutory clearances, licences and permits required for implementation of the power projects; and  Pursuance of formalities concerning land procurement and fuel linkages for the power project.  What are the key sectors that GPCL has set up its projects in?

GPCL has set up its projects in the following sectors: -

 Gas;  Nuclear;  Rooftop solar;  Solar;  Tidal;  Mining; and  Wind  Which is the largest solar power project that GPCL has set up and what is its role in the development of the Radhanesda Solar Power Park?

GPCL has set up only one Solar Park i.e. the Gujarat Solar Park located over 5,384 acres of land in village Charanka in Patan district. It is the largest solar power park of the state with 500 MW installed capacity and 224 MW production capacity by 20 developers.

For the Radhanesda Solar Power Park, GPCL will be responsible for obtaining the following key clearances if they are applicable to the project: -

 Water and air pollution clearance;  Forest clearance;  Environmental and forest clearance; and  Civil aviation clearance

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6. Analysis of Alternatives

This section of the report presents the analysis of the alternatives considered for the proposed solar power project. The following scenarios have been considered.

 No Project Scenario;  Alternate Location for the Proposed Project;  Alternate Methods of Power Generation;  Alternate Technology for Proposed Project; and

 Alternate Routes for Transmission Lines. 6.1 No Project Scenario India being a tropical country is blessed with good sunshine over most parts, and the number of clear sunny days in a year are also quite high. The country receives solar energy equivalent to about 5,000 trillion kWh per year, with most parts receiving over 4-7 kWh per sq. m per day. India’s equivalent solar energy potential is about 6,000 million GWh of energy per year. The State of Gujarat is blessed with about 300 sunny days per year.

According to a survey conducted by the World Energy Council, as the population increases and as the growing rate of electrification places huge requirements on energy supplies, the total primary energy demand of India is expected to increase by almost 150% by 2035.The anticipated power supply position of Gujarat in terms of Energy requirement and demand for the year 2018-2019 is given in Table 6-1.

Table 6-1: Anticipated Power Supply position of Gujarat in 2018-2019

State Requirement (Million Availability (Million Units) Surplus (+) Units) Million Units %

Gujarat 111,660 112,741 1081 1.0

Source: Load Generation Balance Report, 2018-2019, Central Electricity Authority, Ministry of Power

Above data suggests that there is minor surplus in power availability against requirements. However, looking at the aggressive growth targets of setting up solar power plants of around 100,000 MW across India by 2020 under Jawaharlal Nehru National Solar Mission, there seems to be a progressive deficit.

Gujarat's total Installed Solar power capacity was reported to be 1127 MW as per the Vibrant Gujarat Summit 2017 Research Report. However, in line with the country's renewable energy target of 175 GW by 2022, the state of Gujarat has set a tentative target of 8020 MW of solar power capacity, thus to meet the target requirements, increase in the solar power potential is emphasized.

The annual global radiation in India varies from 1600 to 2200 kWh/m2. As per the data provided in the Detailed project Report, Global Horizontal Irradiation at the proposed Site varies from 40 to 111 kWh/m2 per month. As per the Solar Atlas, the proposed site receives Global Horizontal Irradiation of 5.497 kWh/m2 per day. As per the prevailing technical norms, any place with DNI more than or equal to 5.00 kWh/m2/day is considered suitable for solar thermal power projects that use only direct solar radiation. As regards with SPV power projects, they use both direct and diffuse radiation and hence values below 5.00 kWh/m2/day are also acceptable. The Table 6-2 below presents the levels of irradiance (month wise) at the project site.

Table 6-2: The levels of irradiance at the proposed Project Site (Month wise)

Month Average Monthly Global Horizontal Irradiation (kWh/m2/month)

January 144

February 147

March 204

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April 213

May 221

June 192

July 134

August 119

September 161

October 174

November 143

December - Source: Detailed Project Report (December 2018)

The proposed project is an opportunity to utilize the solar potential of the area for power generation. A “No Project Scenario” assumes that the project will not be carried out. A “No Project Scenario” will not solve the issue of progressive deficit. An alternative without the project is undesirable, as it would worsen the power supply-demand scenario, which would be a constraint on economic growth. Additionally, continued use of traditional fossil fuel sources for power generation will have adverse effect on the environment. 6.2 Alternate Location for Project Solar power projects are non-polluting energy generation projects and are dependent on the availability of sufficient solar irradiation. The state of Gujarat receives good amount of solar irradiation. Due to its geographical and environmental advantages, Gujarat has huge potential for solar power generation. India’s Ministry of New and Renewable Energy (MNRE) estimates Gujarat’s renewables potential to be 72.7GW, equally balanced between solar and wind energy potential. Gujarat receives 300 Sunny days and solar irradiation of 5.6 -6.0 kwh/m2 / day. The states of Rajasthan, Andhra Pradesh, Gujarat and Madhya Pradesh have large tracts of government owned wasteland which receive good solar insolation which make them suitable for development of solar parks. Gujarat has almost 13 % of culturable wasteland which is ideal for setting up solar and wind power projects. The state of Gujarat has the potential of developing 36 GW on wasteland16.

The proposed Site is selected by the GPCL to develop a 700 MW solar power park. The site is government owned wasteland, with no reported habitations and receives Global Horizontal Irradiation of 5.497 kWh/m2 per day. As the proposed site is part of a solar power park surrounded by other three (3) proposed Solar projects, hence this site becomes favourable as it would reduce resource transportation to another site, manpower requirements, construction time and effort etc. It would also ease up the surveillance efforts required by the ESPL team.

The following additional criteria have been considered for site selection:

 The proposed site is located away from major settlements;

 The site does not fall under any reserved or protected forests;  The land procured for the site mainly comprises of salty land which is barren in nature and practically unusable for any other purpose; and  No environmentally sensitive features such as water bodies, forests, archaeological sites are located in the immediate site surroundings. The limda mata temple is located at a distance of about 1 km from the site but the same is not affected by the site. Reportedly, all of land selected for the project is fallow land and observed to be vacant without any use from last 10 years. Therefore, considering all the above details of the location and site settings, the identified site was chosen as a suitable option for the project. 6.3 Alternate Source of Power Generation

16 Source: Institute for Energy Economics and Financial Analysis' Report on Gujarat's Electricity Sector Transformation

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As per 2018 report, India is World’s third largest producer of electricity after China and United States of America. Between April 2017 and January 2018, India generated 1003.52 billion units of electricity, with installed capacity of 334.4 Giga Watt (GW). The total installed capacity for electricity generation in the country has increased from 174639 MW as on 31 March 2009 to 399000 MW as on 31 Mach 2018, registering a compound annual growth rate (CAGR) of 8.61% (Table 2.3). The highest rate of annual growth from 2016-17 to 2017-18 in installed capacity in utilities is from Other Renewable Sources (ORS- 20.58%) followed by Thermal Power (2.10%).17

India also intends to add around 100 GW of power capacity between 2017 and 2022, focusing more on hydro, renewable, and gas–based power, besides looking at the adoption of clean coal technology.

Coal fired power plants have the highest Greenhouse Gas (GHG) emission intensities on a lifecycle basis. Although natural gas, and to some degree oil, have noticeably lower GHG emissions. Biomass, nuclear, hydroelectric, wind, and solar photovoltaic all have lifecycle GHG emission intensities that are significantly lower than fossil fuel-based generation. UNEP’s report estimates that the lifecycle GHG emission intensity of solar power generation is consistent with renewable energy sources including biomass, hydroelectric and nuclear. Among other non-conventional sources, only, nuclear power is better than solar power with respect to emissions. However, nuclear power is not a viable option in the identified site and require longer gestation period.

Various power generation options can be evaluated on the levelled cost of power generation which includes the capital and O&M costs and reliability of power generation in terms of plant load factor. The comparative analysis of various power generation options based on these factors has been presented in Table 6-3.

Table 6-3 Comparative analysis of Various Power Generation Options

S. No. Power Generation Method Cost (Rs/kWh) * Plant Load Factor** Average Life Cycle of GHG Emission (tonnes CO2e/ GWh) ***

1. Coal 2.5 65-85% 888

2. Natural Gas 3.9 70-85% 500

3. Hydro 3.8 30-50% 26

4. Nuclear Power 2.5-5.7 65-85% 28

5. Wind Energy 4.2 25-40% 26

6. Solar 15.3-17.1 10-15% 85

Source: *LBNL, CERC, CSTEP & NPCIL; ** Renewable UK; *** World Nuclear Association Report

Although power generation options using conventional sources offer advantages such as lower levelled costs of power generation and higher plant load factors, the operation and maintenance of solar power projects does not involve air emissions or effluent discharges. Other environmental pollution (stack emissions, ash management etc.) issues are also insignificant. Also, there are no significant social issues associated with solar power projects as the land was government owned and did not have any habitations.

Considering all the above-mentioned favourable scenarios existing nationally and locally for solar power generation, there is no requirement of an alternative method. Low GHG emissions during the entire project life cycle; availability of appropriate lands, solar power generation is the most appropriate alternative in the project area. 6.4 Alternate Project Technology There are different types of solar panels available for accumulation of solar energy, the proposed project intends to utilize Crystalline Silicon Photovoltaic Technology based on general comparisons of various parameters such as temperature & efficiency, cost effectiveness, durability, and bankability of modules. The production of

17 Source: Energy Statistics Report 2019, Ministry of Statistics and Program Implementation, Government of India

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polycrystalline cells is more cost-efficient which are manufactured by cooling a graphite mould filled with molten silicon. These cells have module efficiency of around 17.01%.

The energy accumulated from the solar panels is converted from DC to suitable AC power for feeding to the grid. This process is environmentally advanced than creating battery bank for storage of energy, which minimizes the hazards related to handling and disposal of batteries. A comparison of the characteristics of the most popular cell technologies have been presented in Table 6-4.

Table 6-4: Characteristics of some PV Technology Classes

Parameter Crystalline Thin Film Thin Film CPV

Types of Polycrystalline Amorphous Silicon, Micro Amorphous Triple Junction GaAs Cell Materials CdS, CdTe etc. & lens, tracker

Handling Better protection against Not Guaranteed Guaranteed but not Installation would be at breakage proven site. Not Guaranteed

Power Efficiency 13-16% 6-8% 9-11 % 20-25%

Technology Well Developed Stable for Proven Under development Under development Performance

Module Weight Light weight modules Heavier modules Heavy modules Heaviest System

Area utilization Higher power generated Less power per unit Less power per unit Highest power per unit per unit area due to high area area area efficiency

Temperature Temperature variations Least impact of Lesser impact of High variation Effects affect output Temperature variations Temperature variations

Irradiance Used particularly for Better performance with Better performance with Works only for Normal Normal radiations Diffuse radiations Direct and Diffuse radiations radiations

Module quantity Lesser no. required due More modules required Moderate number of Lowest nos. of modules to high efficiency modules required required

Output per MW High Highest Output in Indian Varies as per sunlight Very High(due to tracking) installed Conditions condition and various locations

Transportation Lower Transportation Higher cost Lesser cost compared High cost Cost cost to amorphous

Fewer Mounting More Mounting More Mounting Sophisticated mounting Mounting structure required per structures required structures required required Structure KW power

Land Largest space Larger space required Lowest space required Requirement Lesser space required requirement per MW per MW

Inverter High inverter flexibility Limited inverter flexibility Limited inverter flexibility Limited inverter flexibility

Cost High cost per Watt Lower cost per Watt Higher Cost per watt Highest cost per Watt

Stable power output at Stability achieved after Stability achieved after Stabilization initial stages 4-6 months 4-6 months Unknown

Power Less Degradation Lower Degradation Lower Degradation High Degradation Degradation

Plant Less maintenance Highest maintenance Less maintenance High maintenance Maintenance required after installation required, so highest required after required, so high so lower cost maintenance cost installation so lower cost maintenance cost

Cooling Not required Not required Not required Requires active or passive Requirement cooling which could increase cost

Cabling Well known, and lower Well Understood but yet Well Understood but yet Complex and under cabling losses difficult due to higher difficult due to higher development. Cabling number of arrays number of arrays losses expected to be high Source: Detailed Project Report

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The calculation of the performance ratio for a given solar power installation needs to take into account several key losses. These typically fall into three broad categories:

 Irradiation Losses  PV Module Losses  System Losses As per the DPR, all these losses have been analysed and taken into consideration before selection of the technology. 6.5 Alternate Transmission Line Route As per information provided by ESPL, a 33kV/220 kV internal common pooling substation (PSS) will be constructed by GUVNL near the Project Site for all the Solar Power Developers in the Solar Park and the power will be further evacuated through a 400-kV transmission line of length ~35 km. Although the RoW of the transmission line yet to be finalized, it is mostly passing through agricultural land parcels. The final route for the transmission line would be selected based on the following factors.

 To avoid any habitations along the route;  No house or community structures are located under the transmission line;  Areas requiring extensive clearing of vegetation have been avoided; and  Selection of the transmission route avoids any environmental sensitive site, if identified.

Hence, with multiple benefits of clean energy production, employment generation and attempt to elevating the standards of rural economies, the project would prove advantageous to all realms of the society and nation. The transmission line details were not available, however, as per the discussions with the Site representative, the project with all the chosen options such as site selection, mode of power generation, selections of technology, transmissions lines etc., is appropriate alternative causing minimal disturbance to the surrounding regions.

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7. Impact Assessment

This chapter describes the environmental and social impacts identified by accessing the primary and secondary information gathered. Impacts have been identified based on review of available project information, discussions with representatives of the project and the local community, as well as, sector-specific professionals and subject experts. Impacts anticipated during the operation phase have also been included and classified.

Additionally, this chapter evaluates the significance of each identified impact on the basis of the collective severity of its spread, duration, intensity and nature. Mitigation measures have been suggested for each identified impact evaluated as significant. 7.1 Impact Assessment Criteria Identified impacts have been appraised along the criteria of spread, duration, intensity and nature. As presented in Table 7-1, each appraisal criterion is further classified based on the level or type of its spread, duration, intensity or nature, while stating the defining limit of each level or type.

Table 7-1: Impact Assessment Criteria

Criteria Sub-Classification Defining Limit Remarks

Spread: Refers to area of Local spread impact is restricted within the In case of biodiversity, the farthest direct influence from the foot prints of the Project directly impacted habitat or impact of a particular project boundary ecosystem service would be activity. considered Medium Spread impact is spread up to 2 km In case of biodiversity, the farthest around the project area directly impacted habitat or ecosystem service would be considered High spread impact is spread beyond 2 km In case of biodiversity, the farthest from footprint boundary of the directly impacted habitat or Project ecosystem service would be considered Duration: Based on duration Short Duration when impact is likely to be In case of biodiversity, the of impact and time taken by restricted for a duration less anticipated recovery time of an environmental aspect to than 2 years impacted habitats or ecosystem recover to its original state services would be considered Medium Duration when impact extends up to five In case of biodiversity, the years anticipated recovery time of the impacted habitats or ecosystem services would be considered Long Duration when impact extends beyond In case of biodiversity, the five years anticipated recovery time of the impacted habitats or ecosystem services would be considered Intensity: Defines the Low intensity when changes in the prevailing In case of biodiversity, percentage magnitude of impact (baseline) environmental of loss or degradation of habitats conditions does not exceed and/or ecosystem services would 20% be considered Moderate intensity when changes in the prevailing In case of biodiversity, percentage (baseline) environmental of loss or degradation of habitats conditions does not exceed and/or ecosystem services would 30% be considered High intensity when changes in the prevailing In case of biodiversity, percentage (baseline) environmental of loss or degradation of habitats conditions exceeds 30% and/or ecosystem services would be considered Beneficial - Useful to Environment and Community

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Nature: Refers to whether the Adverse - Harmful to Environment and effect is considered beneficial Community or adverse

Table 7-2 presents the Impact Significance Matrix applied in order to assess the overall significance of the impacts appraised as per the Impact Assessment Criteria outlined in Table 7-1.

Table 7-2: Impact Significance Matrix

Spread Duration Intensity Overall Significance

Adverse Beneficial Local Short Low Insignificant Insignificant Local Short Medium Minor Minor Medium Low Medium Medium Medium Short Low Local Long Low Local Short High Moderate Moderate Local Medium High Local Long Medium Medium Short Medium Medium Medium Low Medium Medium Medium Medium Long Low Medium Long Medium High Short Low High Short Medium High Medium Low High Medium Medium High Long Low Local Long High Major Major Medium Short High Medium Long High High Short High High Medium High High Long Medium High Low Low High Low High

7.2 Impact Identification Table 7-3 below presents the Activity-Impact Interaction matrix for pre-construction, construction, operation and decommissioning phases of the project, based on environmental and occupational health and safety variables. Each of the impacts identified has been further discussed and corresponding mitigation measures have been proposed.

Table 7-3: Activity- Impact Interaction Matrix – Pre-Construction, Construction, Operation & Decommissioning Phase

Project Activities Receptors/Resources isual impacts impacts isual Ambient Air Air Ambient Noise and Quality Quality Soil and Surface Ground water Quality Water resources Use Land & Traffic Transport Ecological Impact Social- Economic Impact Community and Health Safety Occupational and Health Safety Hazards Aesthetics and and Aesthetics V Pre-Construction and Construction Phase

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Project Activities Receptors/Resources isual impacts impacts isual Ambient Air Air Ambient Noise and Quality Quality Soil Surface and Ground water Quality Water resources Use Land & Traffic Transport Ecological Impact Social- Economic Impact Community and Health Safety Occupational and Health Safety Hazards Aesthetics and and Aesthetics V Land Procurement

Site Clearance, Site Levelling and Grading Sourcing and Transportation of Construction Materials and equipment Storage and Handling of Raw Materials and Debris Establishment and Use of Labour Camp Civil Works (PV Module foundations, access road construction etc.) Operation of DG sets

Erection of Solar Modules and Laying of Transmission Lines Transformer yard construction Handling and Disposal of Wastes Operation Phase Solar Panel Operation Maintenance of ancillary facilities such as store, yard, site office Site Maintenance and Security Handling and Disposal of Waste Material Handling and Storage Water Requirements for employees Repair and Maintenance of Solar Panels Inspection and maintenance of transmission lines Decommissioning Phase Removal of Solar Panels

Removal of Foundations

Site Restoration

Waste Management

Material Handling and Storage Water Requirement for Employees Loss of Employment

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7.3 Environmental Impacts and Mitigation Measures 7.3.1 Impacts during the Pre-construction and Construction Phase During the construction phase, the following activities may have impacts on environment:

 Site Preparation  Excavation and levelling;  Hauling of earth materials and wastes;

 Cutting and filling;  Erection of concrete and steel structures;  Painting and finishing;  Clean up operations; and

 Landscaping 7.3.1.1 Ambient Air Quality

Anticipated Impacts

The impact on ambient air quality is anticipated due to the various Project activities. Project components such as site preparation, transmission cable laying, switchgear, internal road network, transportation of raw materials and porta cabins, along with land clearing, levelling, excavation, grading activities, vehicle movement and Diesel Generator (DG) sets operation. The main impacts associated with construction activities will be:

 Dust Generation: resulting from earthworks such as levelling, grading, excavation works and movement of vehicles across dirt/unpaved roads, especially during windy conditions.

 Exhaust Emissions: Exhaust emissions of SO2, NOX, CO, CO2 and PM10 will be attributed predominantly to the construction of the plant, road activities such as movement of trucks and vehicles during construction works and point source emissions from the batching plant to be installed during construction phase. These emissions will be restricted to the project area and are anticipated to be generated in medium concentration. However, it will be dispersed rapidly within the area leading to an impact of low significance. This implies the effects to be of localized nature and temporary which indicates that any deterioration in air quality at project location is unlikely to be significant and is expected to be transient.

Mitigation Measures

 The ESPL and contractors shall ensure the reduction and control of air emissions from construction activities by minimizing dust from material handling sources.  Loading and unloading of raw materials should be carried out in the most optimum way to avoid fugitive emissions.  Sprinkling of water to be carried out by the respective contractors to suppress dust from construction activities.  Best practices such as halting of activity during sustained strong winds should be opted for. It shall be ensured that all stockpiles are covered, and storage areas provided with enclosures to minimize dust from open area source.  Vehicles engaged for the project will be required to obtain “Pollution under Control” (PUC) certificates.  Sufficient stack height needs to be provided to D.G. sets as per the Central Pollution Control Board (CPCB) norms.

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 Speed of vehicles on the village road and on the internal roads shall be limited to 10-15 km/hr in order to reduce fugitive dust emissions.  Cease or phase down work if excess fugitive dust is observed, or there are any community grievance related to dust. Investigate the source of dust and ensure proper dust suppression.

Significance of Impact

The impact on ambient air quality will have moderate intensity with medium spread for a short duration which will result in an overall moderate impact without mitigation. With mitigation, after control of intensity the significance of the impact will reduce to minor owing to the short duration of construction.

Table 7-4: Impact Significance – Ambient Air Quality

Aspect Scenario Spread Duration Intensity Overall

Ambient Air Quality Without Mitigation Local Short High Moderate

With Mitigation Medium Short Medium Minor

7.3.1.2 Soil Quality

Anticipated Impacts

The project will be constructed on open fallow land. Loose top soil will be generated due to excavation on project site during site levelling for erection of module structures and internal roads preparation. The impact anticipated here is loss of top soil, which can be due to inappropriate storage. However, these activities and associated impacts are limited to be within the project boundary and during construction phase only. The intensity of the impact can be considered as medium as the site was observed to be relatively flat and levelling would be required only at a few places. Soil contamination may result due to accidental spillage and inappropriate storage of PV panel components, diesel or transformer oil during construction phase.

Mitigation Measures

Following mitigation measures are recommended to reduce impact on soil due to project activities.

 Allow only covered transportation of top soil within project site.  Use top soil at the time of plantation.  Re-vegetation to be done in the area after the completion of construction, in order to reduce the risk of soil erosion.

Significance of Impact

Considering the distribution of impact within the project boundary and short duration of construction phase with low intensity makes impact of low significance and can be controlled with the recommended mitigation measures.

Table 7-5: Impact Significance – Soil Quality

Aspect Scenario Spread Duration Intensity Overall

Soil Quality Without Mitigation Local Short High Moderate

With Mitigation Medium Short Moderate Minor

7.3.1.3 Impact on Surface and Ground Water Quality

Anticipated Impacts

Surface Water:

The surface topography of the project site can be characterized as mix (flat and mild undulations). Based on visual observations and as reported by villages, precipitation fall on land would accumulate on the project area during rainy season and also flows towards seasonal pond located at an aerial distance of approximately 6.0 km

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towards western direction of the project site boundary. There is no other surface waterbody within 10 km radius of the project boundary.

Runoff from site preparation activities could result in an increase in turbidity and organic load of surrounding water bodies. This will adversely affect the water quality and aquatic organisms.

Alteration of soil structure during construction could lead to erosion and subsequent siltation in the surface water bodies at the downstream areas. Changes in surface hydrology can in turn adversely affect conditions that maintain healthy biological resources especially the avifauna. Accidental spillage of hazardous materials, improper disposal of solid, liquid and hazardous wastes and contaminated surface runoffs from the Site.

During the construction works, there is a possibility of contaminated runoff from the site as the activities involve the installation of solar modules, underground or slightly aboveground (0.5-1m) cables, soil compaction, increased run off and sedimentation of surface waters. Any spillage of chemicals or disposal of waste in or near surface seasonal streams can cause water pollution issues in nearby areas.

Ground Water:

As per Central Ground Water Board (CGWB) classification, project area lies in ‘Saline’ ground water zonation. Ground water in the project area was informed to be highly saline and available at shallow depth of 1-2 meter below ground level.

During the construction phase, labour camp and portable cabins will be set up at the project site and hence generation of domestic wastewater from the labour camp and portable cabins is anticipated. Improper disposal of sewage and wastewater from worksite and construction debris can contaminate the groundwater resources in the area since groundwater depth is very shallow.

Mitigation Measures

 Construction of dedicated storm water drains for reduction any contamination to runoff due to project activities. Storm water drains shall be designed considering natural topography to avoid any obstruction to natural flow and final outlet shall be connected to propose storm water drains by Solar Power Park Developer;  Proper drainage to be provided for wastewater generated from the Porta Cabins and labour camps and shall be treated on Site septic tanks and soak pits as per the specifications in IS 2470:1995 (Part I and Part II);  Periodic monitoring shall be carried out to ensure that the waste water is not finding its way into surface and groundwater;  All solid wastes such as construction debris, used or waste oil, paint cans, etc. will be stored on impervious surface in secure location to avoid soil and groundwater contamination;  Paved impervious surface and secondary containment to be used for fuel storage tanks;  Loading and unloading protocols should be prepared and followed for diesel oil and used oil;  Drip pans to be provided to vehicles with leaks to prevent water contamination;  Leak proof holding tanks for sanitary waste water to protect the shallow ground water level.

Considering the distribution of impact within project boundary and short duration which will result in an overall moderate impact without mitigation. However, with proper implementation of suggested mitigation the overall impact will be negligible.

Table 7-6 Impact Significance – Impact on Surface and Ground Water Quality

Aspect Scenario Spread Duration Intensity Overall

Impact on Surface Without Mitigation Local Short High Moderate and Ground Water Quality With Mitigation Local Short Low Insignificant

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7.3.1.4 Impact on Water Availability

Anticipated Impacts

In the construction phase, Water will be required for civil work during the preparation of concrete, construction of the foundation and building structure of all facilities, as well as for worker needs water for their daily use. The Project’s water use has the potential to result in decreased water available for other users, particularly in the Project area where known water resource challenges. Water requirement for construction activities will be about 10,000 to 15,000 litres per day and domestic use is estimated about 5,000 to 6,000 litres per day. As per the information provided by the Site personnel, the main water supply will be provided by the Solar Power Park Developer which will be supplied from Narmada Canal located at an aerial distance of 40 km from the Project site boundary. Domestic water requirement will be only for drinking, which will be met by packaged drinking water.

Since water from Narmada Canal also supplied to nearby villages and surround areas for drinking, bathing and irrigation purposes, there is a potential to result in decreased water available for other users, particularly in the Project area where known water resource challenges.

The primary source of water in the area is water supplied through Narmada Canal and/or groundwater. However, as reported by the local residents, no groundwater is used by nearby villages and surround areas as water quality is not fit for drinking and other purposes due to high dissolved solids concentrations. Since there is no ground water will be used for Project, direct depletion of ground water resource is not anticipated.

Mitigation Measures

Water for construction activities, flushing and washing purpose will be met through water supplied from Narmada Canal. The other mitigation measures to be implemented are:

 Conservation of water to be undertaken at all project locations and ancillary facilities and if possible, recycling and reuse of water to be taken utilising every opportunity.

Significance of Impact

The impact on water quality will have moderate intensity with a medium spread for a short duration which will result in an overall moderate impact without mitigation. However, with proper implementation of suggested mitigation the impact will be reduced to minor.

Table 7-7: Impact Significance – Impact on Water Availability

Aspect Scenario Spread Duration Intensity Overall

Impact on Water Without Mitigation Local Short High Moderate Availability With Mitigation Medium Short Moderate Minor

7.3.1.5 Ambient Noise Quality

Anticipated Impacts

Construction will cause increased noise levels due to activities such as grading, excavating and drilling for foundations, concrete batching, construction of ancillary structures, and operation of diesel generators, material movement and site clean-up, and construction equipment like dozer, scrapers, concrete mixers, generators, pump, rock drills etc. There is potential for disturbance to habitations in proximity of construction site. Movement of traffic during night hours can also disturb the local community. Approximately 90 – 92 dB (A) of noise is expected to be generated from construction activities which will attenuate to less than 45 dB(A) i.e. night time prescribed noise level at about 80 m. The nearest habitations from the proposed Project site include Radhanesada Village located at an aerial distance of approximately 6.5 km towards eastern side of project boundary.

Additionally, the baseline noise levels measured at South west, north and eastern boundary indicated that the baseline noise is below the Industrial Zone Standards specified in Noise Pollution (Regulation and Control) Rules, 2000 however observed to be above the Residential Zone standard limits.

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Mitigation Measures

 In case of complaints of uncomforting noise received from the inhabitants of nearby settlements through Grievance Redressal Mechanism (GRM) there should be considered possibility of putting noise barriers near to the receptor.  Mobile noise sources such as cranes, earth moving equipment and HGVs shall be routed in such a way that there is minimum disturbance to receptors.  EPC Contractor shall instruct their safety officers to arrange for inherently quiet construction equipment and machines to maintain the noise level to minimum.  Only manual construction activities shall be carried out during night-time (i.e. no use of machinery). The hours of operation for specified pieces of equipment or operations, especially mobile sources operating through community areas should be limited. It is also to be ensured that no village road will be utilized for movement of equipment during the night-time. All loud and sudden noises will be avoided wherever possible and fixed noise sources shall be located at least 50 m away from the site boundary.  Rubber padding/noise isolators will be used for construction equipment or machinery.  Temporary noise barriers shall be provided surrounding the high noise generating construction equipment.  The personnel involved in high noise generating activities shall be provided with personal protective devices to minimize their exposure to high noise levels.  Construction vehicles and machinery will be well maintained and not kept idling when not in use.  Periodic monitoring of noise level should be conducted and compared with the ambient noise standard. It should also be made sure that the levels do not exceeded the national ambient air quality standard (NAAQS) level. Significance of Impact

The impact due to noise and vibration will have moderate intensity with a local spread for a short duration which will result in an overall minor impact without mitigation. However, with proper implementation of suggested mitigation the impact will be reduced to minor.

Table 7-8: Impact Significance – Ambient Noise Quality

Aspect Scenario Spread Duration Intensity Overall

Ambient Noise Quality Without Mitigation Local Short High Moderate

With Mitigation Medium Short Moderate Minor

7.3.1.6 Solid and Hazardous Waste Management

Anticipated Impacts

The construction activities such as site clearance, excavation works, and installation of modules will generate different types of solid and hazardous wastes. The construction demobilization which will entail removal of machinery, and other temporary structures will also result in generation of waste. The following types of wastes will be generated due to construction of the project:

 Domestic solid waste and sewage from labour accommodations;  Used oil, oil lined containers, oil-soaked rags from generator and other construction machinery;

 Packaging waste such as gunny bags, plastics, etc.;  Empty paint containers, metal scrap, chemical lined containers etc.;  Broken or damaged solar panel(s); and  Construction debris.

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The construction debris generated due to the construction activities will have the potential for spread to areas outside the project boundary during construction phase. The dust particles from debris generated during construction activities can be carried along with the wind into nearby areas, thereby increasing the particulate matter in the area. However, this will happen only for a temporary period as the construction activities will be for small duration only. Improper disposal of solid waste from the labour camps and lack of proper sanitation facility for labour can lead to unhygienic conditions due to open defecation and spread of diseases in the area. It can also lead to discontent of local community and result in conflicts with the labour engaged at site.

Improper disposal of packaging materials, boxes, plastics, ropes etc. can lead to littering in the construction site and surrounding areas. Hazardous wastes such as used oil from DG sets, lubricants, hydraulic oil etc. can cause contamination of soil and water bodies if adequate precautions for storage, management and handling are not undertaken. Use of chemicals such as paints, curing chemicals can lead to contamination of soil.

Mitigation Measures

The quantity of domestic waste generated daily from the labour accommodations will be small and limited as most of the workers will be hired locally. Also, one labour camp will be set up wherein migrant workers will be accommodated. The EPC Contractor shall ensure that the labour camp has adequate waste disposal facilities. Arrangements for collection of garbage in dustbins and daily disposal to the nearest dumpsite shall be made.

Provision of segregated toilets for male and female workers (if any) in the ratio of 1:15 and 1:10 (toilet to workers) respectively shall be made at the project site in order to maintain hygienic and clean surroundings. Washing and bathing areas should be provided with proper drainage system so that wastewater is not accumulated in the project site. Disposal of sewage shall be made through a septic tank – soak pit arrangement.

Waste/used oil generated from generators and construction machinery and equipment, oil lined containers, oil- soaked rags etc. should be stored on paved surface in a secure location at the project site. Appropriate secondary containment capable of containing 110 percent of the content of the largest storage tank should be provided. The used oil and oil lined containers, which are characterized as hazardous wastes according to the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, should be sold to Gujarat Pollution Control Board (GPCB) approved vendors at frequent intervals. All packaging material should also be collected at the storage area and sold to authorized scrap dealers. Storage of oil/chemicals shall be undertaken on paved impervious surface and secondary containment shall be provided for fuel storage tanks.

Construction debris and excavated material to be stored in a confined area to prevent spread by wind or water. The construction debris to be used for backfilling of excavated areas and for foundation works at site.

Recyclables viz. paper, plastic, glass, scrap metal waste etc. will be properly segregated and stored in designated waste bins/containers and periodically sold to local recyclers. Any recyclable waste should be encouraged to be recycled at the site. Any waste/damaged part of solar panel(s), broken solar panels will be sent back to panel vendor for disposal.

Significance of Impact

The impact due to waste disposal will have moderate intensity with a local spread for a short duration which will result in an overall minor impact without mitigation. However, with proper implementation of suggested mitigation measures the overall impact will be minor.

Table 7-9: Impact Significance – Waste Storage and Disposal

Aspect Scenario Spread Duration Intensity Overall

Waste Storage and Without Mitigation Local Short High Moderate Disposal With Mitigation Medium Short Moderate Minor

7.3.1.7 Traffic and Transport

Anticipated Impacts

The construction phase shall involve transportation of construction materials, solar modules and mounting structures. The proposed Project is accessible through State Highway No. (SH#) 127 which passes through the

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village Kundaliya and connects to Radhanesda village at a distance of 8 Km towards east of the Site. The road further connects to Limbidya village (Limbiya-Baet road) which is an existing government paved road (~3-5 m wide) and runs parallel towards the north of the Site. This road network will be utilized for transportation of machines and solar modules. The Project construction activities will lead to additional traffic and increased risk of traffic related accidents and industries to community and to workers.

The traffic density along the State Highway No. 127 is low and has adequate carrying capacity to accommodate the additional traffic due to the construction activities. However, the village road at Radhanesda and Kundaliya villages are narrow (~3-5 m wide) and hence increased vehicular movements in the Project area, through the village roads may have adverse impacts in the community due to increased risk of traffic related accidents and injustices and increased pollution.

Mitigation Measures

A Traffic Management Plan is required for the management of traffic due to movement of vehicles for transport of equipment and material. Additional traffic on the village road connecting to Project site can be managed by following mitigation measures:

1. Only trained drivers with valid license shall be recruited by the EPC Contractor for transfer of material; 2. during decommission phase; 3. Training program for all the drivers, regarding awareness about road safety and adopting best transport and traffic safety procedures shall be provided before initiation of the decommissioning activities; 4. Mitigation measures such as emphasizing on safety amongst drivers, adopting limits for trip duration and arranging driver roster to avoid overtiredness and avoiding dangerous routes and times of day to reduce risk of accident shall also be implemented; 5. Regular maintenance of vehicles and use of manufacturer approved parts should be adopted to minimize potentially serious accidents caused by equipment malfunction or premature failure; 6. The villagers shall be made aware about the schedule prior to the movement of trucks and transportation in the Project area.

Significance of Impact

Table 7-10 Impact Significance – Impact on Traffic and Transport

Aspect Scenario Spread Duration Intensity Overall

Impact on Traffic and Without Mitigation Local Short High Moderate Transport With Mitigation Medium Short Moderate Minor

7.3.1.8 Occupational Health and Safety

Anticipated Impacts

Occupational Health and Safety (OHS) of workers is important during construction and operation phases where local and migrant workers are involved. The activities included in the construction phase that have potential impact to OHS of workers are land clearance for establishment of temporary structures, batching plant, access road, mobilisation of equipment and solar PV installation.

There are likely to be potential impacts on worker’s health and safety due to exposure to risk through the project development activities. The following occupational health and safety risks are frequently present, in particular during the construction phase:

 Mobile vehicles and heavy equipment accidents;  Heat stress when working in humid and high temperatures;

 Manual handling and musculoskeletal disorders;  Hand are vibration impacts from concrete breakers, grinders, hammer drills, chipping hammers, chainsaws, scrabbles and needle guns;

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 Temporary or permanent hearing loss from noise generated machinery used for excavation or piling work;  Dermatitis that can rise from contact with small substances such as wet cement and asphalt;  Tripping due to uneven surfaces and obstacles;  Falling during working at height;  Fire due to hot works, smoking and failure in electrical installations; and

 Electrical shocks.

Mitigation Measures

The above identified risks are typical on any construction site of this nature. Therefore, it is anticipated that the sub-contractor will have the necessary management measures in place to manage potential OHS issues under their responsibility. Appropriate OHS programme and procedures are also expected to be in place to align with the local regulations, as well as IFC PS-2. The procedure will include at minimum, the following measures:

 Develop and implement a Health and Safety (H&S) plan to follow throughout the construction phase;  Provide occupation health and safety orientation training to all employees and workers consisting of basic hazard awareness, site-specific hazards, safe working practices, and emergency procedures;  The contractors will be committed to ensure all Health and Safety measures are in place to prevent accidents and reduce the consequences of non-conformance events;  The contractors will provide training, awareness and supervision to ensure all of its construction workers comply with the OHS procedures;  The contractor will provide appropriate resources i.e. PPE to workers on Site; and  An emergency response procedure and infrastructure will be available on Site to ensure provision of first aid for personnel in case of emergency.

Heat related Stress

 As the construction work will be carried out in months of extreme summer heat, heat- related illness can have significant impact on health of the workers engaged at the site. Heat-related illness is a spectrum of disorders due to environmental exposure to heat. It includes conditions such as heat cramps, fainting, convulsion, heat fatigue, rashes, and heat exhaustion as well as the more severe condition known as heat stroke. The heat stress can be due to many factors such as air temperature, humidity, radiant heat, wind speed, workload, physical fitness of the worker, hydration status of the workers and clothing (including PPE that may restrict air flow across the skin and hinder evaporation of sweat).  Additionally, Ultraviolet (UV) radiation burns occurs when the skin is exposed to UV radiation from been out in the sun or from activities such as welding. The symptoms include reddening and inflammation of the skin and blistering and peeling of the skin in severe cases.

Mitigation Measures

The above identified risks are typical on any construction site of this nature. Therefore, it is anticipated that the EPC contractor will have the necessary management measures in place to manage potential issues under their responsibility. The procedure will include at minimum the following measures:

 Increase air velocity for indoor workers by using natural cross-ventilation from windows and doors or mobile or ceiling fans. This increases both evaporation of sweat and convective heat loss, and may significantly improve thermal comfort at air temperatures as high as 40°C;  Operate effective general and local exhaust ventilation and air conditioning;  Avoid non-essential sources of hot ventilation (e.g. air conditioner outlets adjacent to working areas);

 Install a shield between employees and a source of radiant heat such as curtains on windows or other insulating barrier, enclose the heat source, or move the heat source away from employees;  Provide cooled drinking water as close as possible to the work site;

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 Arrange shade for outdoor workers where practicable;  Provide a cool rest area in which workers can take their meal breaks and tea breaks;

 Modify the work schedule or shift times so that outdoor and physiologically demanding work is done in the early morning or late afternoon, when it is generally cooler, and the sun’s radiation is less intense than during the middle of the day;  Allow workers to self-regulate their pace of work. This may involve working continuously at less than full capacity, and/ or working for short periods followed by rest pauses in a cool area;  Workers should be encouraged to present to work in a well hydrated state, and take frequent small drinks throughout each shift to replace fluid lost through sweating;  Diuretic Fluids such as tea, coffee, alcohol and some soft drinks should not be used to replenish fluid lost due to heat;  Use PPE that reduces exposure to ultra violet radiation and heat (such as reflective masks or aprons, large brimmed hat, sunscreen); and  Workers returning from periods away from hot environments should be given the opportunity to acclimatise before being expected to undertake work in very hot conditions at full capacity.

Significance of Impact

The health and safety impacts will have high intensity with a local spread for a short duration which will result in an overall moderate impact without mitigation. However, with proper implementation of suggested mitigation, the intensity can be reduced to minor.

Table 7-11: Impact Significance – Impact to Occupational Health and Safety of Workers

Aspect Scenario Spread Duration Intensity Overall

Impact to Without Mitigation Local Short High Moderate Occupational Health and Safety of Workers With Mitigation Medium Short Moderate Minor

7.3.2 Impacts during Operation Phase 7.3.2.1 Visual Impacts and Aesthetics

Anticipated Impacts

Visual impacts are assed with reference to the presence of PV panels, reduced vegetation, erection of ancillary facilities and transmission lines/towers. The visual effects are evaluated with reference to passing motorists and fixed settlement, primarily the villages in close proximity to the site.

The Project site is located on flat to undulated land and is visible from considerable distance along the village roads present within the study area. There will be a significant change to visual quality of the area resulting from the development and change in land use that will alter the landscape.

Presence of a large area of PV panels is not expected to constitute a risk for glare since it is situated far from airport, and residential dwellings.

Also, no visual impacts are anticipated due to the PV system design, which is specifically designed to include dark, light-absorbing materials and covered with an anti-reflective coating (ARC) for glass surfaces, which reduces the reflectance from PV panels to 2.5%-2.6% while at the same time improving their efficiency. However, there will be a change of landscape due to installation of solar panels and related structures.

Mitigation Measures

The solar panels to be installed at a low height and to be kept closer to the ground so that it does not pop out of the general landscape of the area. The panels to be arranged in a systematic manner which will give an aesthetic sense to it.

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Significance of Impact

The impact on aesthetics and visual aspects will have low intensity with a local spread for a long duration which will result in an overall minor impact without mitigation. The residual minor impact, even after control of intensity and spread, will remain minor owing to the duration of project.

Table 7-12: Impact Significance – Aesthetic and Visual Impacts

Aspect Scenario Spread Duration Intensity Overall

Visual and Aesthetics Without Mitigation Local Long Low Minor

With Mitigation Local Long Low Minor

7.3.2.2 Impact on Soil and Water Quality

Anticipated Impacts Due to Contamination

Operation of solar photovoltaic panels for power generation will not have any direct impact on soil. However, compaction of soils from increased levelling and grading of areas within the site will result in lower permeability and therefore, decreased infiltration and increased runoff. Water, as will be used for the washing activities may contaminate the soil if chemical is used for washing. Without appropriate measures, runoff from PV panels, compacted areas and hard standing areas in addition to erosion by wind may increase erosion and increase the sediment load in run-off.

In operation phase water is used for cleaning of solar panels, where in the use of chemicals cannot be ruled out. Hence, run-off from the plant site with leaked solar washed waste water, waste oil, and seepages from hazardous waste stored without secondary containment may affect the ground water quality. Portable cabins will be set up for site officials, equipped with urinals and toilets during the construction phase. Proper septic tanks will be constructed for discharge of waste water, hence the risk of waste water runoff into the surface water would be reduced.

Anticipated Impacts Due to Improper Waste Handling

Once the plant is commissioned there will be limited disturbance to soil. With reference to Section 2, solid wastes generated during operation will include domestic solid waste; lubricant, used oil/waste oil and oil contaminated rags and limited quantities of broken solar panels. Domestic waste will be collected be local waste collectors. Since the PV panels have a lifespan of 20-25 years, limited quantities of solar panels will be generated during operation (only faulty broken panels).

Mitigation Measures

Options of buyback agreements for defunct panels and for replacement and disposal of transformer oil by the supplier are to be explored, otherwise arrangements for disposal of defunct panels and waste oil to authorized recyclers are to be made.

Fuel and used oil will be stored in demarcated storage areas with adequate secondary containment and appropriate capacity. Spill control and prevention mechanism will be developed, and all the staff will be trained.

If the solar panels are washed with chemicals, it should be ensured that the chemicals are non-hazardous and biodegradable.

Storage of oil/chemicals shall be undertaken on paved impervious surface and secondary containment shall be provided for fuel storage tanks;

Significance of Impact

The impact on land due to improper waste disposal and other operational activities will have high intensity with a local spread for a short duration which will result in an overall moderate impact without mitigation. However, with proper implementation of suggested mitigation measures the overall impact will be negligible.

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Table 7-13: Impact Significance – Impacts on Soil Quality

Aspect Scenario Spread Duration Intensity Overall

Impacts on Soil Without Mitigation Local Short Moderate Moderate Quality With Mitigation Local Short Low Insignificant

The impact on water resources will be of moderate intensity with high spread and long duration for water quality, which will result in an overall major impact without mitigation. However, impact on surface and ground water quality can be moderated by mitigation measures, as discussed above.

Table 7-14 Impact Significance – Surface Water Quality

Aspect Scenario Spread Duration Intensity Overall

Impacts on Surface Without Mitigation High Long Moderate Moderate Water Quality With Mitigation High Long Low Minor

7.3.2.3 Impact on Water Availability

Anticipated Impacts

During the operational phase, the water requirements for the plant will be predominantly for washing of solar PV modules periodically to remove bird droppings, dust and other dirt and domestic water consumption. Whereas, for domestic water consumption for the Project will be restricted to man power engaged at Project site.

As informed, water from Narmada Canal will be used for panel cleaning and domestic purpose. Water requirement of 2.5 litres per m2 of modules is anticipated for cleaning of modules and with a cleaning schedule of twice a month, approximately 3400 litres per month (2 cycles) of water consumption is anticipated. However, depletion of surface water resources due to extraction from Narmada Canal Water during operation phase of the Project is anticipated.

Since no ground water will be used during operation phase, depletion of ground water resources due to extraction during operation phase of the project is not anticipated.

Additionally, run-off from the plant site with leaked waste oil, and seepages from hazardous waste stored without secondary containment may affect the ground water quality.

Mitigation Measures

Following mitigation measures are recommended:

The site office shall be provided with sewage line and the collected sewage shall be channelized to a septic tank with soak pit arrangement.

Significance of Impact

The impact on water resources will be of moderate intensity with high spread and long duration for water quantity, which will result in an overall major impact without mitigation. However, impact on ground water quantity can be moderated by mitigation measures, as discussed above.

Table 7-15: Impact Significance – Impact on Water Availability

Aspect Scenario Spread Duration Intensity Overall

Impacts on Water Without Mitigation High Long Moderate Major Availability With Mitigation High Long Low Moderate

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7.3.2.4 Occupational Health and Safety of Workers

Anticipated Impacts

During the operation phase, the risks will be quite limited due to nature of operation activities; the activities will be limited to guarding and on call and/or onsite technical support (maintenance and cleaning). There will be potential impacts on personnel’s health and safety during operation phase due to exposure to risks such as:

 Slipping and tripping;

 Falling during working at height;  Exposure to hazards such as electric shock and thermal burn hazards;  Exposure to chemicals, hazardous and flammable materials; and  Maintenance activities are expected to be carried out in hot weather conditions, thus workers are exposed to dehydration, heat exhaustion and heat stroke. Also, Electromagnetic Fields (EMF) emanate from any wire carrying electricity. Possible effects associated with the electric and magnetic fields from transmission lines (or similar electrical sources) fall into two categories:

 Short-term effects that can be perceived and may represent a nuisance  Possible long-term health effects.

The issue of whether there are long-term health effects associated with exposure to fields from transmission lines and other sources has been investigated for several decades. There is little evidence that electric fields cause long-term health effects. Estimates of magnetic-field exposures have been associated with certain health effects in studies of residential and occupational populations. Research in this area is continuing to determine whether such associations might reflect a causal relationship.

Mitigation Measures

ESPL will prepare and implement Occupational Health and Safety Plan (OHSP) with clearly identified roles and responsibilities of the personnel involved within the project. The OHSP to include but not limited to the following: site specific safety plan, electrical safety, fire safety, heat stress, personnel protective equipment, emergency response plan, reporting and investigation and others.

Mitigation measures that will be followed include the following:

 Regular electrical safety training to workers with safety procedures and other safety requirements that pertain to their respective job assignments;  Implement Lock out/ Tag Out (LOTO) system;  Use work equipment or other methods to prevent a fall from occurring. Collective protection systems, such as edge protection or guardrails, should be implemented before resorting to individual fall arrest equipment. In addition, safety nets or airbags can be used to minimize the consequences of a fall should it occur.  Loading and unloading operation of equipment should be done under the supervision of a trained professional.  All material will be arranged in a systematic manner with proper labelling and without protrusion or extension onto the access corridor.  Personal Protective Equipment (PPEs) e.g., shock resistant rubber gloves, shoes, other protective gear etc. should be provided to workers handling electricity and related components and monitored that they are used by the employees  The transformer yard should be provided with fire extinguishers and sand buckets at all strategic locations to deal with any incident of fire; and  There should be arrangement for hygienic and scientific sanitation facilities for all the labourers working in the site.  An accident reporting, and monitoring record shall be maintained.

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Significance of Impact

The impact on occupational health and safety will have medium intensity with a local spread for a long duration (project duration) which will result in an overall moderate impact without mitigation. However, with proper health and safety measures the intensity of impact can be reduced to low resulting in an overall minor impact.

Table 7-16: Impact Significance – Occupational Health and Safety of Workers

Aspect Scenario Spread Duration Intensity Overall

Occupational Health Without Mitigation Local Long High Moderate and Safety of Workers With Mitigation Local Long Low Minor

7.3.3 Impacts during Decommissioning Phase 7.3.3.1 Environment and Occupational Health & Safety

Anticipated Impacts

Typical activities during the solar energy facility decommissioning and site reclamation phase include facility removal, breaking up of concrete pads and foundations, removal of access roads that are not maintained for other uses, re-contouring the surface, and re-vegetation.

Dismantling operation however will have impact on environment due to noise and dust arising out of it. During de- installation, a specific strategy shall be adopted to handle each type of item to keep the impact during the actual activity, low. The decommissioning will also have social impact. The impact due to decommissioning on power, social and environmental scenario will be guided by applicable laws and guidelines. The key issues associated with demobilization phase will include:

 Issue of loss of job when the workers will be asked to leave;  Improper disposal of demolition waste and obsolete machineries will lead to contamination of soil and discontent of community;  Demolition activity is anticipated to generate dust and exhaust emissions which can be carried downwind to habitations;  Risks associated with health and safety issues such as trip and fall, electrical hazard etc.;

 The decommissioning activities of dismantling the solar power plant and removing the ancillary facilities can lead to increased noise levels;  During the dismantling of the solar power plant, visual intrusions will be likely by removal of ancillary facilities, but their consequence will be negligible due to fact that such impact would be temporary (over a short period);  Depending on the type used, photovoltaic cells may contain toxic substances such as gallium arsenide, copper-indium-gallium-selenide and cadmium telluride. If any solar panel is damaged during dismantling of the facility, these toxins are likely to spill and leach into the soil and water of the area, posing threat to environmental and public health;  If the solar panels are not handled or disposed of appropriately during the decommissioning phase, any toxic substances contained within them are likely to escape into the surrounding air, water or soil, creating serious environmental and public health risks.

Mitigation Measures

Demobilization will require removal of machinery, workers and other structures. The mitigation measures for decommissioning shall include:

 The proponent shall inform the workers and local community about the duration of work;

 The workers shall be clearly informed about the expected schedule and completion of each activity;

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 All waste generated from decommissioning phase shall be collected and disposed of at the nearest municipal disposal site;  Sprinkling of water is being carried out to suppress dust from decommissioning activities and transport movement;  All necessary PPEs shall be used by the workers during demolition work;  ESPL will be committed to ensure all health and safety measures are in place to prevent accidents and/or reduce the consequences of non-conformance events;  Institution of suitable training modules for project personnel and labour contractors involved in the dismantling process to ensure avoidance or minimization of solar panel damage as far as possible and adherence to appropriate decontamination protocols in the event of any unavoidable damage and adhere to proper safe disposal methods. In addition to above, it is anticipated that the contractor will have the necessary management measures in place to manage potential OHS issues under their responsibility. Appropriate OHS programme and procedures are also expected to be in place to align with the local regulations, as well as IFC PS-2. The procedure will include, at minimum, the following measures:

 Develop and implement a health and safety plan to follow throughout all phases of a project;  Provide occupation health and safety orientation training to all employees consisting of basic hazard awareness, site-specific hazards, safe working practices, and emergency procedures;  The contractors will be committed to ensure that all Health and Safety measures are in place to prevent accidents and reduce the consequences of non-conformance events;  The contractors will provide training, awareness and supervision to ensure all of its construction workers comply with the OHS procedures;  The contractor will provide appropriate resources i.e. PPE to workers on Site; and  An emergency response procedure and infrastructure will be available on Site to ensure provision of first aid for personnel in case of emergency Significance of Impact

Impact value for decommissioning is assessed to be moderate without mitigation measures, and minor with preventive measures.

Table 7-17: Impact Significance – Environment Occupational Health and Safety Hazards

Aspect Scenario Spread Duration Intensity Overall

Environment and Without Mitigation Medium Short Moderate Moderate Occupational Health and Safety With Mitigation Medium Short Low Minor

7.3.3.2 Impact on Land Due to Improper Waste Disposal

Anticipated Impacts

The PV modules have a lifespan of 20-25 years. The PV modules contain heavy metals and cannot be disposed in landfills. A PV module is essentially made up of glass, metals, silicon and polymer fractions, and there are few materials like polymers as well as metals (small quantities of zinc, tin, copper and silver), metallic compounds and alloys which are classified as potentially hazardous. PV waste recycling is still at a nascent stage globally, both in terms of technical standards and physical infrastructure. So, at present, PV module recycling is not commercially viable.

The polymer component used in solar modules is difficult to recycle and can only be incinerated which again poses a significant health and environmental risk due to the formation of highly corrosive gases at the incineration stage. If landfilled inappropriately, waste and waste constituents can find ways into soil and water, resulting in a potentially damaging impact on the ecosystem. The scope of the India e-waste rules do not include solar panels and therefore there is no legal responsibility for any party to take back or recycle solar panels.

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Inappropriate handling or disposal of solar panel during decommissioning phase, are likely to cause damage to the panels. Any damage or unsafe disposal of solar panels will cause release of toxic substances contained within them. These hazardous chemicals are likely to escape into the surrounding air, water or soil, creating serious environmental and public health risks.

Mitigation Measures

 Project developer to research and be involved in programmes and research for recycling solar panels.

 Project developer h to ensure that solar panels are disposed of in accordance with the law and best practice.  Project developer to develop protocol/procedure for dismantling and handling panels.  Project-personnel and labour contractors involved in the dismantling process to receive training ensure avoidance or minimization of such damage as far as possible and adherence to appropriate decontamination protocols in the event of any unavoidable damage. Significance of Impact

Table 7-18 Impact Significance – Impact on Land due to Improper Disposal of Waste

Aspect Scenario Spread Duration Intensity Overall

Impact on Land Due Without Mitigation High Medium High Major to Improper Waste Disposal With Mitigation Local Short Medium Moderate

7.4 Ecological Impacts and Mitigation Measures The main direct ecological impacts anticipated from the Project consists of loss or degradation of near-natural habitats at the Project Site, along with the attendant loss of provisioning services, mainly in the form of fodder resources for the local livestock. The significance of these anticipated impacts is deemed to be moderate, owing to the presence of comparable alternative natural habitats and provisioning services in the vicinity of the Project Site.

As per the applicable reference frameworks, significant conversion or degradation of natural habitat is acceptable only if the following conditions are applicable: (i) No alternatives are available; (ii) the overall benefits from the project are expected to substantially outweigh its environmental costs; and (iii) the conversion or degradation is appropriately mitigated.

As per the applicable reference frameworks, the corresponding mitigation measures must aim to achieve at least no net loss of biodiversity. The mitigation measures may involve a combination of actions, such as post-project restoration of habitats, offset of losses through the creation or conservation of ecologically comparable areas that are managed for biodiversity, while respecting the ongoing use of such biodiversity by Indigenous Peoples or traditional communities, or compensation to direct users of biodiversity.

Owing to the Project Site being a part of a government-promoted Solar Park and having been specifically allocated to the client by the concerned governmental authorities, no alternative is available in terms of project- siting. Owing to the anticipated impacts of the Project being of overall moderate significance, the benefits of the Project arguably outweigh its environmental costs. The inevitable conversion or degradation of the natural habitats at the Project Site is sought to be appropriately mitigated to achieve no net loss of biodiversity, as well as, to off-set any foreseeable loss of provisioning ecosystem services accruing to the local community.

The following sections present the ecological impacts anticipated directly from the Project in a phase-wise manner, along with corresponding mitigation measures based on international industrial good practices.

It may be noted that ecological impact of considerably higher significance is anticipated from the external transmission line, a shared facility of the Project, which can potentially cause direct mortality to avifauna through collision and/or electrocution.

The impacts anticipated from the external transmission line, along with the corresponding mitigation measures, are discussed in a separate section.

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7.4.1 Impacts during the Construction Phase Removal of natural vegetation: The removal of vegetation to clear the Project Site for construction will cause loss of near-natural habitat, amounting to approximately 0.75 square km of natural scrubland and 0.5 square km of slightly modified grassland. The habitat loss at the Project Site will directly cause loss of habitat for scrubland and grassland fauna and loss of provisioning ecosystem services, mainly wild foods and fodder. The removal of natural vegetation would also indirectly cause exposure of soil to desiccation by wind and sunlight, loss of soil anchorage and increased vulnerability of soil to erosion by wind and water, leading to changes in the soil regime and the corresponding loss or degradation of the related ecosystem services.

The loss of the natural scrubland habitat of the Project Site is of relatively high significance owing to absence of alternative comparable habitat around the Project Site. This impact is of additional significance owing to the natural scrubland habitat of the Project Site being part of a natural scrub forest officially designated as reserved pasture for local livestock currently being grazed on land coinciding with the Solar Park. The loss of the natural grassland habitat of the Project Site is of relatively moderate significance owing to presence of comparable alternative habitats around the Project Site.

Levelling or grading of land: The current topography of the Project Site supports scrubland and grassland habitat at relatively higher elevations and saline mudflat habitats at lower elevations. Levelling or grading of land could lead to alteration of the natural topography, and consequently, the natural drainage and the natural habitat distribution. Obstruction of natural drainage channels may also lead to accumulation of salts and increase soil salinity, turning hitherto freshwater habitats into brackish water ones. Excavation and land-filling involved in levelling and grading can also alter the natural soil-profile, change soil properties and disrupt sub-soil habitats. This could affect the natural rainwater percolation into sub-surface layers, thereby impacting the natural groundwater recharge process and degrading the related ecosystem services.

The loss of the natural scrubland habitat of the Project Site is of relatively high significance owing to absence of alternative comparable habitat around the Project Site. This impact is of additional significance owing to the natural scrubland habitat of the Project Site being part of a natural scrub forest officially designated as reserved pasture for local livestock currently being grazed on land coinciding with the Solar Park. The loss of the natural grassland or saline flat habitat of the Project Site is of relatively moderate significance owing to presence of comparable alternative habitats around the Project Site.

Laying of roads and paving of surfaces: The laying of roads or paving of surfaces within the Project Site will hinder or obstruct the percolation of rainwater into the ground. This will cause reduction of groundwater recharge and increase in surface run-off, leading to loss or degradation of soil and sub-soil habitats, as well as, the related regulating and supporting services.

This impact is of relatively minor significance owing to availability of a large extent of comparable alternative habitats and ecosystem services around the Project Site.

Movement of vehicles and heavy machinery: Movement of vehicles and operation of construction machinery would expose the natural environment to vehicular emissions and unnatural levels of dust, noise, light and vibrations. This would generally lead to pollution of natural resources and possible contamination of food webs. It would cause compaction of soil substrates, leading to injury or death of soil organisms. It would also reduce percolation of rainwater into sub-soil layers and increase surface run-off, impacting the natural groundwater recharge process and destroying or degrading the related ecosystem services.

This impact is of moderate significance owing to the location of the Project Site in proximity to wildlife habitats.

Artificial Illumination: Use of artificial lighting to illuminate the Project Pite and during night-time will lead to unnatural illumination in the area during the natural dark part of the day. Use of vehicles during night may also lead to artificial illumination. Interruption of the natural night period by light is known to disrupt the natural biological cycles of many floristic and faunal species.

This impact is of moderate significance owing to the location of the Project Site in proximity to wildlife habitats.

Installation of solar panels: The introduction of the large, geometrically arranged, reflective surfaces of solar panels into a natural area would cause visual obstruction or visual irritation to wild fauna, especially aerially

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moving fauna. The overall visual effect of the solar panelling would also degrade the aesthetic qualities of the natural landscape, thus affecting the cultural services of the area.

This impact is of high significance owing to the location of the Project Site in proximity to human habitations and wildlife habitats, including habitats used by migratory and/or congregatory species, as also, within two avian migratory flyways.

Installation of internal transmission cables: Installation of over-head transmission cables would disrupt the aerial habitat space of the area, leading to death or damage to aerially moving organisms such as birds and bats through accidental collision and electrocution. Installation of underground or slightly aboveground (0.5-1m) transmission cables would disturb the natural soil-profile and fragment sub-soil habitats. These effects would lead to injury or death of organisms, thereby impacting ecosystems and the related ecosystem services.

This impact is of high significance owing to the location of the Project Site in proximity to wildlife habitats, including habitats used by migratory and/or congregatory species, as also, within two avian migratory flyways.

Mitigation Measures

 Enable or facilitate the conservation of the approximately 0.75 square km of natural scrubland habitat in and around the Project Site, to the extent possible.  Conserve the 0.50 square km of slightly modified grassland habitat in and around the Project Site to the extent possible.  Offset the loss of any natural vegetation removed from the Project Site by planting the same species, but higher numbers of individuals, of trees, shrubs and herbs, as applicable, in or adjacent to the Project Site.  Opt for diverse but strictly native species in any additional plantation carried out towards the Project. Species typical to the natural forest-types of the Study Area, as reported in the baseline data, may be used in plantations. Alternatively, advice may be sought from the local forest department office, which can also provide saplings of local native species for plantation.  Conserve the natural topography of the Project Site by integrating the natural topographical features into the project construction plans.  Minimise the number and the width of all internal roads.  Maintain the connectivity and integrity of existing natural water-channels while building internal roads or embankments.  Ensure that vehicles and machinery used in the construction activities comply with the prescribed emission standards.  Restrict movement of construction-related vehicles, especially heavy vehicles or machinery, strictly to pre-designated routes.  Restrict construction activities requiring high levels of illumination to daylight hours to the extent possible, to prevent disruption of the natural night period by artificial lighting.  Ensure that any unavoidable night-time illumination is restricted within the Project Site, directed towards the Project Site, uses low-intensity artificial lighting and is equipped with downward facing shades to minimize dispersion of the light into adjacent habitats.  Plant relatively tall-growing native vegetation at a suitable distance along the boundary of the Project Site to visually screen it from wildlife habitats and human habitations in the surrounding area, as also, to help counter the heat island effect created by the solar installations.  Insulate any over-ground transmission cables to prevent electrocution of organisms colliding with them or install bird deflector devices on them to render them relatively more visible to aerially moving organisms. Alternatively, opt for underground transmission cabling.  Install the solar panels in as small and discrete clusters as feasible, rather than installing them in continuous swathes.

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 Opt for crystalline silicon type solar panels over other currently available technologies, to avoid introduction of toxic chemicals into the local ecosystems.  Opt for solar panels with anti-reflective coating (ARC), preferably in conjunction with white, non- polarizing gridding, to reduce reflectiveness and light-polarization.  Opt for underground or slightly aboveground (0.5 to 1 m) internal transmission cabling.  Ensure that all electrical components are adequately insulated to prevent electrocution of fauna through accidental contact with project-installations.

Aspect Scenario Extent Duration Intensity Type Significance

Degradation of Without Medium Long High Adverse Moderate Habitats Mitigation

With Mitigation Local Medium Moderate Adverse Minor

Fragmentation of Without Medium Long High Adverse Moderate Habitats Mitigation

With Mitigation Local Long Moderate Adverse Minor

Loss of Ecosystem Without Medium Long Moderate Adverse Moderate Services Mitigation

With Mitigation Medium Medium Low Adverse Minor

7.4.2 Impacts during the Operation and Maintenance Phase Physical Hindrance by On-ground Installations: The physical presence of the solar panelling and related installations would hinder faunal movement within and through the area, affecting their current access to habitats and resources. Aerially moving fauna, such as insects, birds and bats, may accidentally encounter electrical components of the project installations, leading to injury or death. Certain bird species such as raptors are known to avoid PV sites and surrounding areas due to a loss of hunting/nesting habitat. The regular activity of humans in the solar park also deter raptors, thus changing the bird community structure in the nearby areas. The solar panelling and related installations would also cast a shadow on the soil underneath, cutting off the existing natural insolation available to the soil and ground flora of the shaded area. Altered insolation patterns would also affect the existing soil-moisture conditions. These effects would collectively degrade or alter the existing floristic profile of the affected area, thus impacting its existing primary production and the associated ecosystem services. Owing to the length of solar panel-strings, as also, the large scale of the proposed installations, the physical presence of the solar panelling would lead to fragmentation of existing contiguous faunal habitats and prevent faunal access to habitats and habitat features such as roosts, feeding grounds, nest sites, tools and nesting materials beyond the solar park.

This impact is of high significance owing to the Project Site being located in proximity to wildlife habitats, including habitats used by globally threatened, as also, migratory and/or congregatory species.

Reflectivity of Solar Panels (Albedo Effect): Especially vulnerable to solar panel reflectivity are aerially moving diurnal organisms, mainly birds. Detours taken by migratory birds as an avoidance response to disturbances or irritants in their natural flight path are known to cause an often-fatal increase in the flight energy expenditure of many long-distance migrant species. The unnatural polarization of light caused by solar panels is known to trigger maladaptive behaviours in polarization-sensitive organisms and alter their ecological interactions, including preferential egg-laying on panel surfaces by insects. Such faunal behaviour-alteration could lead to undesirable long-term impacts on food webs in which affected species occupy critical trophic niches. Birds in flight, mistaking the reflective surface of the panels for water, may collide with the panels in an attempt to drink it. Birds that drink water on the wing (such as swallows) are at a greater risk of mortality from this effect than those that drink from a perched position.

Source: Gábor Horváth, György Kriska, Péter Malik and Bruce Robertson (2009). Polarized light pollution: a new kind of ecological photo-pollution. Front Ecol Environ 2009; 7(6): 317–325; Taylor, R., Conway, J., Gabb, O. and Gillespie, J. (2019).

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Potential ecological impacts of ground-mounted photovoltaic solar panels: An introduction and literature review. Report for BSG Ecology.

This impact is of high significance owing to the Project Site being located in proximity to wildlife habitats, including habitats used by migratory and/or congregatory species.

Heat Generation by Solar Panels (Heat Island Effect): The large-scale solar installation would heat the air in and around the project site, leading to an overall rise in the ambient temperature, thereby degrading the natural environment of the area. This effect is known to significantly affect areas up to approximately 300 m from the perimeter of the solar-panelled area and up to a height of 5-18 m. The latest available research indicates that temperatures over a PV plant were regularly 3–4°C warmer than associated natural habitats at night. The impact of increase in ambient temperature is known to be especially deleterious to organisms of warm tropical regions, where the normal temperatures are likely to be already near the tolerance limits of the organisms.

Sources: Nicolas Barth, Benjamin W. Figgis, Ahmed Ennaoui, Said Ahzi, "Field-scale Computational Fluid Dynamics applied to wind velocity profiles of photovoltaic plant: Case of the QEERI solar test facility Doha Qatar", Renewable and Sustainable Energy Conference (IRSEC) 2016 International, pp. 613-618, 2016; Barron-Gafford, G. A. et al. “The Photovoltaic Heat Island Effect: Larger solar power plants increase local temperatures.” Sci. Rep. 6, 35070; doi: 10.1038/srep35070 (2016)

This impact is of high significance owing to the Project Site being located in proximity to human habitations and wildlife habitats, including habitats used by migratory and/or congregatory species.

Physical Hindrance by Overhead Transmission Lines: The physical presence of overhead transmission lines would disrupt the existing contiguous aerial habitat of the area, leading to death or injury to aerially moving organisms such as birds and bats, through accidental collision with cables.

This impact is of high significance owing to the Project Site being located in proximity to wildlife habitats, including habitats used by migratory and/or congregatory species.

Physical Hindrance by Underground Installations: The physical presence of underground installations, such as the solar panel mounting foundations and underground transmission cables, would occupy a large area of sub-soil habitats. This would lead to loss of habitat area for sub-soil species and hinder their access to resources.

This impact is of relatively minor significance owing to the Project Site representing a relatively insignificant percentage of the overall land surface in the area supporting the aforementioned organisms and ecosystem services.

Project Site Illumination: Use of artificial lighting to illuminate the project site in the night-time will lead to unnatural illumination in the area during the night. Interruption of the natural night period by light is known to disrupt the natural biological cycles of many floristic and faunal species.

This impact is of high significance owing to the Project Site being located in proximity to wildlife habitats, including habitats used by migratory and/or congregatory species.

Project-related Traffic: The movement of project-related vehicles and personnel to, from and around the Project Site would increase the ambient levels of vehicular emissions, dust, noise, vibrations and artificial illumination in and around the project site. This would lead to pollution of the natural environment. Also, disruption of the night- period by illumination is known to disturb natural floristic and faunal biological cycles.

This impact is of high significance owing to the Project Site being located in proximity to wildlife habitats.

Use of Herbicides: Herbicidal chemicals, if used to prevent or control the growth of plants which could cut off sunlight from the solar panelling, would be toxic to most organisms and may have a tendency to persist or bio- accumulate, contaminating the soil, surface water, groundwater and food-chains of the area.

This impact is of fairly high significance since the Project Site is connected by ecological flows to the ecosystems of the Little Rann of Kachchh, a designated area of high biodiversity value.

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This impact is of fairly high significance since the Project Site is connected by ecological flows to the ecosystems of the Little Rann of Kachchh, a designated area of high biodiversity value.

Spillage of Materials: Heat transfer fluids, belonging to chemical groups such as Glycols, Nitrates, Nitrites, Chromates, Sulphates and Sulphites, if used in the project systems, would be toxic to organisms. Spillage of these chemicals, either as part of routine operations, or accidentally, could lead to their leaching into the local environment, contaminating the natural soil and water resources of the area. This impact is of fairly high significance since the Project Site is connected by ecological flows to the ecosystems of the Little Rann of Kachchh, a designated area of high biodiversity value.

Mitigation Measures

 Restore the soil and natural vegetation of any construction-phase roads which are not necessary for carrying out operation or maintenance activities, and hence, are not required in the operation and maintenance phase.  Restrict maintenance-related activities to the daytime to avoid disturbance to adjacent habitats during the night-time period.  Ensure that vehicles and machinery used in the Project Site for operation and maintenance activities comply with the prescribed emission standards.  Restrict movement of vehicles used in the Project Site strictly to the minimum possible pre-designated routes.  Restrict operation or maintenance activities requiring high levels of illumination to daylight hours to prevent disruption of the natural night period by artificial lighting.  Avoid or minimize the use of artificial lighting in and around the Project Site to the extent possible.

 Opt for low-intensity artificial lighting, such as LED, to prevent attraction of insects.  Opt for solar panels with anti-reflective coating (ARC), preferably in conjunction with white, non- polarizing gridding, to reduce reflectiveness and light-polarization.  Ensure that lights in and around the Project Site are provided with downward-facing shades to limit the dispersion of the illumination into adjacent habitats.  Prohibit the use of herbicides in the facility.  Opt for manual weeding to control or regulate plant growth in the solar panel area.  Avoid the use of dust-settling chemicals in the facility.

 Opt for manual sprinkling of water to control dust in and around the solar panel area.  Institute effective training modules and operational systems to ensure prevention of spillages of toxic substances.  Install effective containment systems to prevent any accidental spillage from leaching into the local environment.

Aspect Scenario Extent Duration Intensity Type Significance

Degradation of Without Medium Long High Adverse Major Habitats Mitigation

With Mitigation Local Medium Moderate Adverse Moderate

Fragmentation of Without Medium Long High Adverse Moderate Habitats Mitigation

With Mitigation Local Long Moderate Adverse Minor

Loss of Ecosystem Without Medium Long Moderate Adverse Moderate Services Mitigation

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Aspect Scenario Extent Duration Intensity Type Significance

With Mitigation Medium Medium Low Adverse Minor

7.4.3 Impacts during the Decommissioning Phase Damage to Solar Panels: If any solar panel is damaged during dismantling of the facility, polluting materials are likely to be introduced into the air, soil and water in and around the project site, thereby degrading its natural resources.

This impact is of fairly high significance since the Project Site is situated in proximity and connected by ecological flows to the ecosystems of the Little Rann of Kachchh, a designated area of high biodiversity value.

Unsafe Disposal of Solar Panels: If the solar panels are not handled or disposed of appropriately during the decommissioning phase, any toxic substances contained within them are likely to be introduced into the air, water or soil of the disposal site, thereby degrading its natural resources. This impact is of fairly high significance since the Project Site is situated in proximity and connected by ecological flows to the ecosystems of the Little Rann of Kachchh, a designated area of high biodiversity value.

Mitigation Measures

 Institute suitable training modules for project-personnel and labour contractors involved in the dismantling process to ensure avoidance or minimization of solar panel damage and adherence to appropriate decontamination protocols in the event of any unavoidable damage.  Institute suitable training modules for project-personnel and labour contractors involved in the dismantling process to ensure adherence to appropriate safe disposal protocols.

Aspect Scenario Extent Duration Intensity Type Significance

Degradation of Without Medium Long High Adverse Moderate Habitats Mitigation

With Mitigation Local Medium Moderate Adverse Minor

Fragmentation of Without Medium Long High Adverse Moderate Habitats Mitigation

With Mitigation Local Long Moderate Adverse Minor

Loss of Ecosystem Without Medium Long Moderate Adverse Moderate Services Mitigation

With Mitigation Medium Medium Low Adverse Minor

7.4.4 Impacts of the External Transmission Line

The external transmission line, a shared facility of the Project, is expected to span a length of approximately 35 km, with over-head cabling installed at a height of approximately 25 m above the ground. Approximately 12 km of the transmission line, stretching from Radhanesda Village to Kareli Village, is oriented in a more or less west to east direction, while the remaining approximately 23 km, from Kareli Village to Khimanavas Village, is oriented in a more or less north to south direction. The transmission line corridor traverses through a swathe of modified habitats, predominantly cultivated farmlands or plantations, interspersed with a few natural habitats, mainly patches of slightly degraded scrub and seasonal or perennial wetlands.

One anticipated impact of the external transmission line will be the disruption of the aerial habitat of the Study Area. This may trigger avoidance action on part of aerially moving fauna, such as birds and bats, causing them to forfeit access to habitats on the far side of the transmission line or fly longer distances to access such habitats. The additional energy-expenditure associated with avoidance can be critical for long-distance migrant avifauna.

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However, most migratory flights are known to be at heights considerably greater than 25 m above ground-level. Hence, this impact is of relatively minor significance.

The other anticipated impact is faunal mortality through collision and/or electrocution of perching or aerially moving fauna.

Since the external transmission line is a shared facility of the Project, ESPL should work with GPCL, on a best effort basis, to encourage the adoption of the measures recommended below to minimize electrocution and collision risks to avifauna from the transmission lines.

A bird electrocuted in one of the existing transmission lines in the Study Area

Sources: AECOM Primary Survey

Mitigation Measures

Installation of Line Markers: Line markers are usually installed on the shield wire, which is associated with maximum collision risk to increase the visibility of the power lines. Commonly used line markers include the following:  Aerial spheres: Large spheres placed on the wires to increase visibility. For better reduction of risk – staggered placement, using different colors, using light with the spheres to increase visibility at night, anywhere between 5 to 30 m intervals, situated in the centre of the span (60% of the span, excluding 20% on the sides of each pole)  Spirals and bird flight diverters: Spiral Vibration dampers reduce the line vibration and increase visibility of the line, placed 3m apart on shield wires. Bird flight diverters are increasing radius spirals. Swan flight diverter is another spiral with a large diameter in the centre and the two ends gripping the line. The SFDs can be used on shield wires, but transmission lines of more 230 kV should be avoided.  Suspended Devices: The suspended devices can be swinging, flapping or fixed. They have a clamp that attached to the line so that the device dangles and based on its type, can move in the wind. They are glow in the dark designs that increase the visibility in the night as well. They can be placed 10-15m apart in a staggering position.  Tree wires: Insulated phase conductors that provide protection from momentary contact with tree branches and prevent collision-electrocution. As the diameter of an insulated wire is more, the visibility of the wire increases.

Management of the Surrounding Land: In agricultural lands near transmission lines, activities such as ploughing/clearing of field may coincide or precede the in-migration season, creating habitats suitable for migratory birds to roost/feed/nest. Such activities should be conducted after the birds have arrived in the region, in order to keep them away from the transmission line. Similarly, dumping grounds, waterbodies, etc. in industrial areas or residential areas should be covered during the migratory season or during high bird activity.

Changes to the Shield Wire: Shield wire is the highest wire on a transmission pole with the smallest wire diameter. Most bird collisions happen with the shield wire as it is the highest on the pole and has very less visibility. The purpose of a shield wire is to protect the phase conductors from lightning. Thus, to reduce the

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collision risk, lightning arresters can be used to replace the shield wires. However, lightning arresters may increase the risk of electrocution in case of bird hits. Therefore, it is also recommended to increase the diameter of the shield wire and place line markers to increase its visibility.

Line configuration: In cases of new transmission lines, changes in the line configuration can prevent bird collisions to a certain extent. Line configuration is of two types – horizontal and vertical. In a vertical lien configuration, the various power lines are placed one below the other. This increases the chance of collision as the wires occupy different heights in the aerial landscape. Counter to that, horizontal line configurations are less prone to bird collisions. Thus, when constructing a new transmission line, horizontal configuration should be preferred. It is also recommended that in places of multi-conductor transmission lines, the lines should be clustered so that all the power lines use the same ROW. Bundling or clustering of wires reduces collision risk as the resulting network of wires is confined to a small space and is more visible. In unavoidable circumstances, the vertical arrangement of a multi-conductor transmission line should be kept to a minimum.

Rerouting of lines: In places of high bird use or high collision risks, the transmission line should be rerouted in such a way that important habitats are avoided.

Undergrounding of lines: In places of high bird use or high collision risks, the transmission line can be buried underground. However, this is costly and comes with several more environmental threats such as water and soil contamination due to leakage/damage.

Monitoring of bird collision risk before/after establishing the transmission line: The population of migratory as well as resident birds should be monitored seasonally at the existing transmission line or once the line has been established. Any incidents or bird hits should be reported, and location-specific mitigation measures should be employed. Before establishing a transmission line, “high bird-use” areas should be identified to guide appropriate routing of the transmission line.

Other miscellaneous measures:  Using blinking lights instead of steady burning white or red lights can reduce the risk of collision. Steady burning lights disorient migrating birds and may attract them. Certain species are known to circle such stationary lights, which increases the risk of collision.  Reducing human activity and disturbances near the line’s ROW will reduce the collision risk from sudden flights. Especially in areas of high bird-use, activity should be kept minimum. Speed limit and honking on roads passing through or near to high bird use areas should be controlled.  Lowering the height of the lines below the tree level may reduce the collision risk. However, in open spaces or agricultural fields, this is difficult to achieve.  In case of existing lines, reducing the span of the line can help reduce the collision risk. Adding a pole mid-span will reduce the line span and increase the visibility of the transmission line.

Source - APLIC (Avian Power Line Interaction Committee) (2012) Reducing Avian Collisions with Power Lines: The state of the art in 2012. Edison Electric Institute and APLIC. Washington, D.C.

Aspect Scenario Extent Duration Intensity Type Significance

Degradation of Without Medium Long High Adverse Moderate Habitats Mitigation

With Mitigation Local Medium Moderate Adverse Minor

Fragmentation of Without Medium Long High Adverse Major Habitats Mitigation

With Mitigation Local Long Moderate Adverse Moderate

Loss of Ecosystem Without Medium Long Moderate Adverse Moderate Services Mitigation

With Mitigation Medium Medium Low Adverse Minor

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7.5 Socio- Economic Impacts and Mitigation Measures 7.5.1 Impacts during the pre-construction phase 7.5.1.1 Impact on animal grazing

Consultations were undertaken with key stakeholder groups engaged in grazing of animals in a plot of land measuring 68 hectares (167.96 acres) located adjacent to the two (2) land parcels allotted by GPCL to ESPL for setting up the solar power project within the Radhanesda Solar Power Park. Discussions with the communities engaged in animal rearing/ grazing on the said land parcel, the Sarpanch, Radhanesda and local communities indicated that designation of the plot of land as grazing land by the district administration has created goodwill among the local communities for the administration and the solar park authorities. In the absence of grazing land within the vicinity of the power park, the concerned grazing land has contributed towards increased domestication of animals in the villages of Radhanesda and Tharad. However, increasingly erratic monsoon and associated lack of water is serving as a major impediment in the domestication of animals. Consultations with GUVNL that is responsible for development of basic amenities and infrastructure in the solar power park revealed that efforts will be made by the agency to collaborate with the Radhanesda panchayat to improve the existing vegetation in the grazing land. This will help in enhancing the ability of the grazing land to cater to more animals in the locality.

Significance of Impact

Impact on animal grazing is assessed to be minor without any enhancement measures and moderate with enhancement measures.

Table 7-19: Impact Significance – Animal Grazing

Aspect Scenario Spread Duration Intensity Overall

Animal Grazing Without Enhancement Medium Short Moderate Minor measures

With Measures Medium Short Low Moderate

7.5.2 Impacts during the construction and operation phases 7.5.2.1 Impacts on Local Economy

During the construction and operational phase of the project, the impact the local economy is likely to be positive as the project will lead to increase in local employment opportunities and increased demand for materials and services through local contracting. Efforts should be made to ensure that maximum proportion of the demand for manpower and materials is met locally through contractors and vendors. The power generated from the project will reportedly be transmitted to the local grid and is likely to increase the power supply in the region.

Significance of Impact

Impact on local economy is assessed to be minor without any enhancement measures and moderate with enhancement measures.

Table 7-20: Impact Significance – Local Economy

Aspect Scenario Spread Duration Intensity Overall

Local Economy Without Enhancement Medium Short Moderate Minor measures

With Measures Medium Short Low Moderate

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7.5.2.2 Employment opportunities

During the peak construction phase spanning over a period of 2-3 months, the manpower requirement will be 600 – 700 (contractual workers). Consultations with the project proponent indicated that most of the manpower requirement in the unskilled and semi-skilled categories will be sourced from the local area and will comprise of youth from the neighbouring villages. Employment of local youths in the project-specific construction activities will positively contribute to the livelihood of the local villages. Specific clauses facilitating the employment of local youths should be incorporated into the EPC contract agreement between ESPL and the EPC contractor.

Significance of Impact Impact on employment opportunities is assessed to be minor without any enhancement measures and moderate with enhancement measures.

Table 7-21: Impact Significance – Employment Opportunities

Aspect Scenario Spread Duration Intensity Overall

Employment Without Opportunities Enhancement Medium Short Moderate Minor measures

With Measures Medium Short Low Moderate

7.5.2.3 Labour Rights and Welfare Approximately 30 % of the total manpower, especially in the skilled and highly skilled categories to be employed during the construction phase i.e. 180 – 200 will be sourced from outside the project. The site representative of ESPL during the site visit confirmed that a labour camp will be set up at a distance of 1 km from the site. The migrant workers will be provided accommodation in the labour camp. It was reported by ESPL that the labour camp will have a capacity to accommodate 400 labourers. It was further reported that only male workers will be accommodated in the labour camp. 40 numbers of toilets, 4 tanks of 500 litres drinking water with 2 taps each, 28 numbers of kitchen etc. will be provided as basic amenities in the proposed labour camp. The size of the rooms – 80 numbers will be 5 meters in length x 3.5 meters in breadth and 3.5 meters in height. Similarly, 2 numbers of electrical power points will be provided along with other switches for lights and fans in each room. The EPC Contract will also require providing the minimum wages to the labourers including overtime wage as per the Building and Others Construction Workers Act. In addition, benefits in terms of Employee State Insurance (ESI) should be provided to each worker engaged on site. The workers should be aware of their rights and benefits due to them so that no issues emerge. Toilet facilities and drinking water should be provided to all workers on site as well. Grievance Redressal Mechanism for workers should be developed and communicated to the workers so that the workers can approach the management if any concerns or issues are faced by them without any fear of retribution or intimidation.

Significance of Impact

Impact on Labour Rights and Welfare is assessed to be minor without any enhancement measures and moderate with enhancement measures.

Table 7-22: Impact Significance – Labour Rights and Welfare

Aspect Scenario Spread Duration Intensity Overall

Labour Rights and Without Welfare Enhancement Medium Short Moderate Minor measures

With Measures Medium Short Low Moderate

7.5.2.4 Labour Influx It is anticipated that during the construction phase there will be an influx of migrant workers. During the site visit, it was mentioned by the site representative that for specialized work activities, 180 – 200 migrant workers are envisaged to be engaged. Engagement of migrant labourers might lead to an increase of issues with the local population if proper orientation is not provided. The basic issues related with migrant labourers may include:

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 Conflict amongst workers and between workers and local community members based on behavioural/ cultural practices.  Discontent amongst local community members on engagement of outsiders as workforce.

 Mild outbreaks of infectious diseases due to interaction between the local population.  Safety and security issues for local women.  Use of community facilities such as temples, transport facilities, public spaces may lead to discontent between the local community and the migrant workforce.

7.5.3 Impacts during the decommissioning phase 7.5.3.1 Loss of employment opportunities The manpower requirement during the O&M phase was reported by the project proponent to be in the range of 6 – 8 workers who will be engaged on daily basis including 2 – 3 electricians, 1 site-in-charge and 1 site engineer. The workers will be engaged by the O&M contractor. Some of the key activities to be performed by workers engaged in O&M phase such as housekeeping, solar panel cleaning, bush cutting, security fall under the unskilled and semi-skilled categories for the purpose of which local youth from the neighbouring villages can be sourced. However, in an event of decommissioning, there is a high probability that the manpower engaged in O&M activities might lose employment. This will adversely impact the livelihood of the concerned people.

Significance of Impact

Impact value for employment opportunities is assessed to be moderate without mitigation measures, and minor with preventive measures.

Table 7-23: Impact Significance – Employment opportunities

Aspect Scenario Spread Duration Intensity Overall

Employment Without Mitigation Medium Short Moderate Moderate opportunities With Mitigation Medium Short Low Minor

Mitigation Measures for the identified social risks

 As part of its CSR programme, ESPL may collaborate with the Radhanesda Panchayat to improve the vegetation in the grazing land so that it can cater to a greater number of domestic animals in the local villages.  The project through the contractor agreement shall ensure that the construction contractors commit and adhere to social obligations including community relations, handling complaints and grievances, adherence to labour laws and international commitments etc. Similarly, water usage amongst the labourers shall be monitored and controlled to minimize generation of wastewater.  The EPC Contractor needs to ensure that all the required amenities – adequate washrooms, adequate lighting and ventilation in the rooms wherein the labourers will be accommodated, adequate quantities of clean and potable drinking water, access to appropriate medical services etc. is provided in the labour camp.  The project shall ensure that no child or forced labour is engaged by contractors and all wage payments are done without any discriminations or delays by the contractors. Similarly, adequate sanitation and waste disposal facility shall be ensured at the project site.  In order to ensure that the migrant workers engaged in project-specific construction activities have acceptability amongst the host population of the village, efforts should be made by the EPC Contractor to facilitate meetings between migrant workers or their representatives and members of the Panchayati Raj Institutions (PRI) and other elder members of the village. In such meetings, issues relating to the cultural practices of the people of the village and that of the migrant workers, dependence on community resources such as ponds and temples may be discussed. This is expected to reduce conflicts owing to competing use of community resources.

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 The project shall ensure that while engaging contractors and sub-contractors during the operation phase agreements on priority basis shall be made with local contractors and vendors.  ESPL should ensure that the rental accommodation proposed to be provided to the migrant workers during the construction phase should comply with the provisions of PS 5 of IFC’s Policy on Environment and Social Sustainability relating to worker accommodation. 7.6 Impact of Climate Change on Solar PV Power Plant Greenhouse gases are the gases generated from natural and anthropogenic activities, which absorb and emit infrared radiation in the wavelength range emitted by Earth eventually contributing to the global warming and broadly result in climate change. Some of the key greenhouse gases are Water vapor (H2O), Carbon dioxide (CO2), Methane (CH4), Nitrous oxide (N2O), Ozone (O3) and Chlorofluorocarbons (CFCs). Emission of CO2 is associated with this project which relates to global warming.

United Nations Framework Convention on Climate Change (UNFCC) defines climate change as the change resulting from long term direct and indirect activities that induces changes in the compared time which are much more than the natural change.

7.6.1 Anticipated Impacts 7.6.1.1 Construction Phase This ESIA has focused on the following aspects related to the climate change:

 The potential effects of the project on climate, in particular the magnitude of greenhouse gases (GHGs) emissions emitted during both construction and operation  The impact of climate change on the project over its lifetime;

 The impact of the project on the climate resilience of wider (social, environmental and economic) systems over time.

GHG Emissions from Solar Power Plant

The potential sources of GHG emissions during construction phase will be vehicular movement, DG set exhaust including unburnt hydrocarbon and carbon-monoxide, and exhaust emissions from construction equipment and machinery. The GHG emissions from construction activities cannot be determined at this stage as the design details, construction plan and details of the construction materials are still to be finalized, but the impact assessment and mitigation measures in this section will consider the likely impact of the project due to climate change during construction phase to ensure minimum impact. Hence the GHG emissions from the proposed solar power plant is not likely to have serious impact on the climate change during construction phase.

The impact of climate change on the project:

Some of the key impacts of climate change on the proposed project are:

i. Rise of atmospheric temperature and heat: The rise in atmospheric temperatures will likely reduce air quality with increase in particulate matter and ozone pollution in the atmosphere and impact the ambient air quality during the construction phase. ii. Increase in rainfall and flood: The region where the Solar Power Plant is proposed is highly susceptible to flood and the same has been shown in Figure 7-1 below.

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Site Location

Figure 7-1: Flood Scenario in Gujarat State

Source: ISRO Website (https://www.isro.gov.in/flood-monitoring-using-scatsat-1-satellite) iii. It is understood that during rainfall, water stands over ground at the site due to absence of natural drainage channels and also due to existence of several bunds in vicinity of Radhanesda village and Kundalia village. These bunds have been constructed to conserve rain water and to check the ingress of salt water from surrounding area. Thus, depth of flooding could be 310 mm (nearly one feet) for a 50-year return period storm rainfall of 24-hour duration at the site. The climate change across the region may further aggravate the current scenario through increased rainfall and increase in frequency and intensity of heavy rainfall events, which are likely to increase the water level and bank erosion of the River Banas and the risk of flooding in the area, both pluvial and fluvial. This will have potential to impact/hinder the construction activities during construction phase including damage/loss of materials and equipment. The increase in wind speed due to increased storms may also have potential to cause material loss of properties and loss of lives of the workers. However, the design has taken into consideration flood protection measures enhancement through site elevation above the maximum flood level and with adoption of flood protection/erosion protection measures during construction phase (which is a short-term temporary activities), the impact of climate change on project construction activities are not deemed significant. iv. Exhaust Emissions: There is likely to be significant CO2 emissions during construction phase arising from vehicular emissions, DG set emissions and exhaust emissions from heavy earth moving equipment and construction machineries. However, the quantum of emissions during the temporary construction phase will be of short duration and impact is not likely to be significant. The technology selected for power generation uses solar energy which is an environmentally friendly source.

Mitigation Measures:

Mitigation measures include:

 Earth filling in the solar power park to raise the ground level and thus protect the area from flooding. Raising the ground level by earth filling is also required to lay internal drainage channels with adequate slope for conveying stormwater safely to the outlets on boundary of the solar park.

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 Adopt recycling/reuse of water to minimize fresh water consumption. This could be achieved by adopting various initiatives e.g. recycling treated wastewater for toilet flushing, landscaping etc.  Construct flood protection system including site elevation and enhancement of Banas river bank.  Use of machines, DG, equipment and vehicles only with appropriate pollution fitness certificates. Also carry out periodic maintenance of equipment and vehicles.  Estimate, maintain and publish carbon footprint (month wise) during construction activities and operational phase and reduce vehicular movement where possible.  Avoid use of Ozone Depleting Substances during construction phase.

7.6.1.2 Operational Phase Solar Power Plant is an environmentally friendly power generation technology which has potential to significantly reduce green-house gases (GHG) emissions as it does not use any fossil fuel and thereby reduces the greenhouse gas emissions associated when compared with fossil fuel-based electricity generation system. However, the proposed 200 MW Solar PV Power Plant, like all other Solar Power Plants and their components is vulnerable to fluctuating weather conditions and climate change in broader perspective. The photovoltaic panels of the solar power plant are vulnerable to extreme weather conditions like hail, storm, extreme temperature, cyclones or floods. The climate change factors like extremely high or low temperatures, and high wind could reduce the yield of solar modules. Researches have shown that for each degree of global temperature rise, solar modules could lose around 0.45% of their rated output (Source: “Global warming will hit solar panel performance”, PV-magazine dated 16/08/2019). However, the design of solar panels will take into consideration the Solar Radiation Assessment Report, which is likely to minimize the impact of climate change on solar panels ’operating efficiency throughout the design life of 25 years. Considering the design of solar panels have taken into account the impact of climate change on the rated outputs, the impact is not likely to be significant.

GHG Emissions from Solar Power Plant

As per the estimation of International Atomic Energy Agency (IAEA) the grams of carbon equivalent (including CO2, CH4, N2O etc.) per kilowatt-hour of electricity (g Ceq/ kWh) for Solar energy project are low and scores better when compared with other forms of conventional and non-conventional sources of energy. The estimated average life cycle of GHG emissions from solar power plant is approximately 85 tonnes CO2e/ GWh as against 500-880 tonnes CO2e/ GWh for natural gas and coal respectively. Therefore, the proposed 200MW Solar Power Plant during operational phase (generating 4800000 Kilowatt-hour or 4.8 GWh of energy) is estimated to emit approx. 422 tonnes of CO2e, which is much lesser as compared to any conventional power plant.

The impact of climate change on the project over its lifetime

Some of the key impacts of climate change on the proposed project are:

 Rise of atmospheric temperature and heat: This climate change will likely increase the ambient temperature of the region and the country resulting in warmer winter and hotter summer. The increased risk of heat waves could impact the solar panels and deformation of Plant & accessories and road surfaces resulting in reduction in service life. Increased temperatures are likely to lead to issues with expansion of joints and cracking of internal plant and concrete pavements/structures exposed directly to atmosphere. Higher summer temperatures will likely reduce air quality with increase in particulate matter and ozone pollution in the atmosphere and impact the ambient air quality.  Increase in rainfall and flood: The climate change due to increase in rainfall and flood across the region may further aggravate the current scenario and increase in frequency and intensity of heavy rainfall events, which are likely to increase the water level and bank erosion of the River Banas and the risk of flooding in the area, both pluvial and fluvial resulting in material damage/loss of plant and equipment. The increase in wind speed due to increased storms may also have potential to cause material loss of properties and loss of lives of the workers. However, the design has taken into consideration flood protection measures enhancement through site elevation above the maximum flood level and with adoption of flood protection/erosion protection measures, hence the impacts of climate change on project production phase are not deemed significant.

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 Exhaust Emissions: The technology selected for power generation uses solar energy which is an environmentally friendly source. Although there will be vehicular movement to and from the power plant during operation phase, the incremental increase of GHG emissions in the ambient air quality will be negligible due to very low number of vehicular movements.

Mitigation Measures:

Mitigation measures include:

 Operation and periodic maintenance of flood protection structures constructed to prevent flooding of the plant.  Green belt development within the plant and its periphery;  Adopt recycling/reuse of water to minimize fresh water consumption. This could be achieved by adopting various initiatives e.g. recycling treated wastewater for toilet flushing, landscaping etc.  Construct flood monitoring system (e.g. telemetry) and set-up information sharing system with local disaster management team for taking appropriate preventive actions well before the occurrence of any natural disaster like cyclone, earthquake etc. Also consider the opportunities to enhance the embankment of Banas river bank.  Use of machines, DG, equipment and vehicles only with appropriate pollution fitness certificates. Also carry out periodic maintenance of equipment and vehicles.  Estimate, maintain and publish carbon footprint (month wise) during construction activities and operational phase and reduce vehicular movement where possible.  Avoid use of Ozone Depleting Substances during operation phase.

7.6.1.3 Climate Transition Risk. Government of India and State Government of Gujarat’s commitment towards building a sustainable and climate resilient future for its people, a State Action Plan on Climate Change (SAPCC) has been prepared following a consultative process to address any transitional climate risk for the prevailing environmental and socio-economic system. SAPCC aims in creating a roadmap that leads to the realization of a growing, low-emitting and sustainable economy with a more climate resilient population in Gujarat and the country. Due to the nature of the project (renewable energy or clean technology), no climate related transition risks are envisaged for this project.

Risk Rating:

The overall risk rating has been done following checklist of ADB has been referred for preliminary climate risk screening:

Screening Questions Score Remarks

Location and Design of Is siting and/or routing of the 0 Not likely Project project (or its components) likely to be affected by climate Solar modules likely to be conditions including extreme selected shall be compatible weather-related events such with the climatic condition of as floods, droughts, storms, the Radhanesda village landslides? (maximum temperature – 42 to 44-degree Celsius)

Would the project design 1 Likely need to consider any hydrometeorological parameters During rainfall, water just (e.g., sea-level, peak river stands over ground at the site flow, reliable water level, peak due to absence of natural wind speed etc.)? drainage channels and also due to existence of several bunds in vicinity of Radhanesda village and Kundalia village. These bunds have been constructed to conserve rain water and to

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check the ingress of salt water from surrounding area. Thus, depth of flooding could be 310 mm (nearly one feet) for a 50-year return period storm rainfall of 24-hour duration at the site. Therefore, project component and site design should consider the risk of local flooding

Materials and Maintenance Would weather, current and 1 Likely likely future climate conditions (e.g. prevailing humidity level, Project can be established temperature contrast between within a short time period of hot summer days and cold 11 months (approx..) winter days, exposure to wind therefore temporary impact of and humidity climate change on material hydrometeorological and maintenance may occur. parameters likely affect the selection of project inputs over the life of project outputs (e.g. construction material)?

Would weather, current and 0 Not likely likely future climate conditions, and related extreme events likely affect the maintenance (scheduling and cost) of project output(s)?

Performance of project Would weather/climate 1 Likely outputs conditions, and related extreme events likely affect Although project has been the performance (e.g. annual designed after consideration power production) of project of temperature variation output(s) (e.g. hydropower (annually), significant generation facilities) variation in temperature over throughout their design life the period of project life cycle time? may affect its performance.

Total Risk Score: 3

(Source: ESIA – 48 MW Solar Power Project in Adilabad District, Telangana, 2016)

Note:

Based on the above risk rating, the project is assessed to have medium risk with respect to impact of climate change.

Table 7-24: Impact Significance – Climate Change

Aspect Scenario Overall

Climate Change Without Mitigation Moderate

With Mitigation Minor

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7.7 Cumulative Impact Assessment Cumulative Impact Assessment (CIA) is the process of (a) analyzing the potential impacts and risks of proposed developments in the context of the potential effects of other human activities and natural environmental and social external drivers on the chosen Valued Environmental and Social Components (VECs) over time, and (b) proposing concrete measures to avoid, reduce, or mitigate such cumulative impacts and risk to the extent possible.

Cumulative impacts18 are a result of effects that act together (including those from concurrent or planned future third-party activities) to affect the same resources and/or receptors as project under consideration (e.g. the combined effect of other similar projects in the general area). An effect to a resource in itself may not be considered significant but may become significant when added to the existing and potential effects eventuating from similar or diverse developments in the area.

The Project Site is a part of the 700 MW Radhanesda Solar Park located near Radhanesa Village of Vav Taluka in Banaskantha district, Gujarat. This Solar Park will be developed by Gujarat Power Corporation Limited (GPCL) in collaboration with Union Ministry of New and Renewable Energy (MNRE). The other ESPL which are going to develop within Radhanesda Solar Park is given in Table 7-15 below:

Table 7-25: Details of proposed solar projects near project site

Name of the Project ESPL Distance from proposed project site

250 MW solar project SBG Cleantech Energy Within Radhanesda Solar Power Park

250 MW Solar Project Fortum Solar Plus Private Ltd (part of Finnish Within Radhanesda Solar Power Park developer Fortum).

200 MW Solar Project Electro Solaire Private Ltd (part of French group Within Radhanesda Solar Power Park Engie) Source: https://gpcl.gujarat.gov.in/showpage.aspx?contentid=15 There is no other solar power plant located within 10 km radius of the project boundary. However, there is one (1) Solar Power Park namely Charanka Solar Park located at an aerial distance of approximately 60 km towards waste of the project boundary. The Charanka Solar Power Park is also developed by the Government of Gujarat and has capacity of 250 MW.

In addition to above, there has been a substantial increase in renewable energy developments in India, and legislation is evolving to facilitate the introduction of Independent Power Producers (IPPs). Hence it is anticipated that additional renewable energy power plants will come within 50 km radius of the project area boundary.

Since renewable power projects do not require any resource consumption for its operation, no obstruction to common property resources are anticipated. The potential cumulative impacts identified for the project has been highlighted in the following sub sections.

7.7.1 Environmental Impacts Air Quality and Soil Characteristics

During operation of the project no fuel of any kind will be burnt. The baseline ambient air quality measured within 5 km radius of the project was noted to be well within the prescribes standards. The impact on air quality is not considered. However, as per the information shared by the client, the development of all the proposed power plants in the vicinity of the project site will be undertaken simultaneously. It will result in increased fugitive emissions during the construction activities and due to the vehicular movement. However, the construction activity will last for 6-8 months, the cumulative impact on ambient air quality can be considered moderate.

Ambient Noise

18 As per Good Practice Handbook on Cumulative Impact Assessment and Management: Guidance for the Private Sector in Emerging Markets by IFC (2013), cumulative impacts are those that result from the successive, incremental, and/or combined effects of an action, project, or activity (collectively referred to as “developments”) when added to other existing, planned, and/or reasonably anticipated future ones. For practical reasons, the identification and management of cumulative impacts are limited to those effects generally recognized as important on the basis of scientific concerns and/or concerns of affected communities.

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The noise from existing surrounding has been captured in the baseline recorded for the project. It was observed that the average day noise level ranges from 54.5 - 74.4 dB(A) and average night time noise level ranges between 45.4, 40.3 – 60.4 dB(A). The baseline noise levels in the area are exceed the prescribed CPCB standards of 75 dB(A) and 70 dB(A) during the day and night time respectively at the sampled locations.

It is to be noted that ambient noise levels depend on various factors such as the exact number of vehicles/equipment being used at the construction site, number of hours of operation etc. Since construction activities will be temporary in nature and will be carried out during the day time and will not last for more than 6-8 months, cumulative noise impact is considered low.

Soil and Water Quality

There will be wastewater generation from cleaning the solar panels. The domestic wastewater may be generated from site office of the operation team. Septic tanks with soak pits should be provided to treat sewage during operation stage. Due to the proposed 700 MW capacity solar park, more wastewater generates during operation phase and there is a potential to impact soil and water quality if wastewater generated is not handled properly.

In addition to this, substantial amount of solid and hazardous waste will be generated from the solar park hence cumulative impact on water quality can be considered moderate to high.

7.7.2 Impacts on Biodiversity and Ecosystem Services The chief Valued Ecological Components (VECs) with respect to the area under consideration include a potentially critical habitat, globally threatened species, specialized habitats, habitat-specialist species and priority provisioning and cultural ecosystem services, as described in the biodiversity baseline.

7.7.2.1 Impact on Biodiversity

The main cumulative impact on biodiversity is anticipated from clearing of the scrub forest in and around the solar park. The scrub forest constitutes the richest habitat in the Study Area and supports a large proportion of its floristic and faunal diversity. Thus, the construction of the Solar Park is likely to result in loss, degradation and fragmentation of the limited habitat available to these floristic and faunal communities. A second cumulative impact envisaged is the increased risk of collision and electrocution for migratory birds from the introduction of new transmission lines into the Study Area. A third cumulative impact would result from the generation of a large, reflective, water-mimicking surface by the collective, near-contiguous solar panelling of the Solar Park, which would increase risk of false landings and the resulting injury and entrapment for water-birds.

7.7.2.2 Impact on Ecosystem Services

The natural scrublands and grasslands in and around the Solar Park provide a priority provisioning ecosystem service in the form of fodder for livestock from Radhanesda village. The loss of this natural habitat will lead to the a significant reduction in the pasture available to the local livestock, thereby increasing the grazing pressure in comparable alternative habitats around the Solar Park. Another anticipated cumulative impact is that on the soil and water quality in the Study Area. The large-scale change in land-use, through clearing of vegetation and construction of the solar park and shared facilities, will increase the vulnerability of the soil to erosion by wind and water. The largescale land-levelling will impact the natural drainage of the region and may cause influx of saltwater into hitherto freshwater habitats, thus reducing the freshwater resources currently available to the local community. Any changes in the local soil salinity levels, resulting from the salinization of hitherto freshwater ecosystems, is also likely to impact the local agricultural yields.

7.7.3 Socio-economic Impacts 7.7.3.1 Impact on land

On average 4 acres of land is required per one (01) MW of solar power. For 200 MW solar power plant, around 380 hectares (~ 938.06 acres) of land is required for installation of solar modules, intermediate control stations, invertor room and shared facilities. Additional land is not required for transmission line as only RoW from private land owners and NOC from relevant departments for government land parcels will be required. The land identified for the proposed project as well as the land allotted to other players in the solar power park is sandy,

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saline, barren and uncultivable in nature and it is devoid of any residential dwellings/ archaeological sites. The project of ESPL as well as other players in the solar will have no economic impacts as no farming activities or other livelihood pursuits are being undertaken on it. The land is being procured through lease basis.

7.7.3.2 Migrant Workers

During the O&M phase, all the projects proposed to be set up in the solar power park will not involve any migrant labor. Only skilled personnel will be hired from outside the project area, who will be accommodated in rented accommodation complying with the relevant provisions of PS 5 of the IFC policy on environmental and social sustainability. Most of the civil works being small in nature should be handled by the local contractors from the nearby regions. This would ensure that the workers are from local area. Only skilled workers for erection of solar modules and operation of cranes should be sources from outside and their numbers should be relatively less. As a strategic principle, all the proponents should decide to engage local people during construction to avoid migration of labor from far off places. This will not have any stress on the local and moreover provide job opportunities to the local population. 7.7.3.3 Impact on Infrastructure

The road connectivity in the area is good therefore transportation of solar modules and other construction materials/ machineries will not lead to any disturbances to the habitations. There will be no disturbance to habitations as the erection activities will be undertaken at a considerable distance from human settlements.

7.7.4 Conclusion The Project will have minor as well as short term impact during construction phase. Minor impact due to generation of dust and fugitive emissions are expected during construction phase only. Minor impact is expected to resource utilization like land, water and socio-economic conditions of the Project area villages. Land for the proposed Project is uncultivated and owned by the government of Gujarat. Impact analysis reveals that minor impact is anticipated on livelihood of local community. The impacts on environment and social parameters is assessed to be minor during operation phase of the proposed project.

The Project would change overall character of the region and would contribute to the conversion of rural dry waste land to landscapes with industrial character. However, no existing highly scenic view or aesthetically unique or distinctive landscape would be forfeited by the introduction of these types of Projects. The Project represents conversion from a natural environment of dry agricultural fields to build environment with an industrial character. The area is unpopulated, and no residents would be subject to alteration of view in association with proposed Projects. Therefore, a week cumulative impact may be expected due to the Project and other Projects which may come in future in the area.

The Project would change the landscape pattern of the area and likely to have significant impact on biological diversity through habitat loss, degradation and fragmentation.

The Project also has a positive impact in terms of employment generation for the local people during entire Project lifecycle. The impacts identified both during construction and operation phase can be minimized and mitigated by adopting suitable mitigation measures as suggested in the ESIA report. Based on the conclusion drawn from the ESIA study the proposed Project can be categorized as Category B (as per categorization of Projects), which specifies that this Project is expected to have limited adverse environment and social impacts which can be mitigated by adopting suitable mitigating measures.

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8. Environment and Social Management Plan 8.1 Introduction The purpose of an Environmental and Social Management Plan is to ensure that social and environmental impacts, risks and liabilities identified during the ESIA process are effectively managed during the operation and closure of the proposed project. An Environmental and Social Management Plan (ESMP) is an important component of an ESIA as it provides an important tool that can be used to measure and check, in a continuous mode, the efficacy of the mitigation measures and project commitments incorporated in the ESIA to minimize or eliminate identified negative impacts. The ESMP also aligns the schedule for implementation of management plans.

The key objectives of the ESMP are to:

 Formalize and disclose the program for environmental and social management;  Provide a framework for the implementation of environmental and social management initiatives;

 Monitor the ESPL’s compliance with all the mitigation measures and commitments in the ESIA report;  Monitor the ESPL’s compliance with legal standards and limits for waste discharge and emissions;  Provide early warning signals on potential environmental changes, so that appropriate actions can be taken to prevent or minimize environmental and social impacts;  Put in place a sound and cost-effective contingency plan that can be activated for prompt response to any accidental occurrence;  Encourage and achieve the highest environmental and socio-economic performance and response from individual employees and contractors throughout the duration of the project; and  Routinely check all measures/devices put in place for effective monitoring of project functions and activities. The ESMP delineates the monitoring and management measures to avoid and/or minimize such impacts by allocating management responsibility and suggesting skill requirement for implementation of these measures. Also, the ESMP shall ensure a continuous communication process between ESPL, project developer, workers (including sub-contractors), local community and other stakeholders.

In addition, the ESMP may also be used to ensure compliance with statutory requirements, and corporate safety & environmental and social management policies.

An ESMP is, therefore, a tool which ensures continuous assessment of the environmental and social impact of a project operation as well as proactive response to the impacts to reduce their overall effect on the identified environmental and social parameters. It makes an organization to do the right thing at the right time rather than responding to situations borne out of statutory or legal compulsion.

In this section, an ESMP is presented to be used throughout the life span of the proposed project. This ESMP will facilitate environmental and social management of the proposed project and procedures are provided to help prevent, avoid or minimize negative environmental impacts that may occur during project operations and decommissioning phase. 8.2 Organizational Structure (Environment, Social, Health and Safety) The enforcement and implementation of the project specific ESMP requires a robust manpower network working towards the common goal of ensuring compliance to the commitments towards ESHS standards for the project. Organization structure of ESPL with project level responsibilities is given in Figure 8-1.

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Figure 8-1: Project organization structure The overall management and coordination of the project with respect to EHS will be managed through the Head, EHS at the corporate level. Also, a designated EHS professional/EHS Project (by ESPL) will be assigned at the project level to manage the EHS functions and activities during the construction stage (including supervising the day to day activities of the Sub-contractor and his team). The designated EHS staff of the Sub-contractor will report to the Site level EHS person of ESPL. The Site level EHS Project will in turn report to ESPL Corporate.

ESPL will be responsible for the O&M of the project. 8.3 Roles and Responsibilities This section describes the roles and responsibilities of the key persons responsible for management of the project activities:

Head-EHS

 Overseeing successful EHSS screening, audit and impact assessment of assets either internally or through external agencies as the case maybe in coordination with EHS Project;  Overseeing the implementation of the systems, protocols and checklists of the ESMS at the corporate level and where necessary, transferring information and expertise to EHS Project;  Interaction with other teams such as project team, land, procurement, HR etc. for handling and resolution of EHSS issues and risks;  Ensuring implementation of training and capacity building exercises at the corporate levels and project level;  Documentation and control of ESMS related documents; and

 Development of processes with respect to EHSS. Also includes internal updating of existing systems pertaining to EHSS wherever feasibly and technically possible.

EHS Project

The EHS Project (at project level) is responsible for overall management of the project and ESMP implementation on site during operation phase of the project. The following tasks will fall within his/her responsibilities:

 Monitor site activities on weekly basis for compliance;  Keeping a check on operation and maintenance services required during operation phase.

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Apart from the project related aspects, Site In-charge will also have additional responsibilities of community liasioning such as:

 Managing all grievances of the project and their outcomes;  Implementing, monitoring and updating the ESMP;  Keep record of the CSR activities being undertaken for the project, if any;  Keep the Regional Project Manager informed on the progress of CSR activities undertaken at project site;  Conduct periodic (formal and informal) meetings with local community for understanding their grievances and inform them about the Grievance Redressal Mechanism and ensure effective implementation.

EHS Engineer

Roles and responsibilities of EHS Engineer include the following:

 Implementation of on-ground tools, checklists and processes;  Overseeing overall EHSS compliance at the ground level;  Responsible for all interactions with contractors pertaining to EHSS in coordination with EHS Project;

 Carrying out compliance audits and safety checks during operation phase with assistance from EHS Project;  Generate and reporting back of site-level audit reports and key performance indicators to the corporate level; and  Vigilance and enforcement agency for investigation of EHSS non-compliance, investigation of incidents and accidents and imposition of fines and penalty measures.

EPC Contractor (during construction phase)

The HSE officer of the EPC contractor will be overall responsible for management of environmental and social aspects, labour management during the construction phase. The detailed roles and responsibilities of the EPC Contractor have been provided in the table below:

Aspect Roles and responsibilities

Air Quality Management  Ensure the reduction and control of air emissions from construction activities by minimizing dust from material handling sources, loading and unloading of materials and stockpiles.  Sprinkling of water to be carried out to suppress dust from construction activities.  Ensure that the vehicles engaged for project have a valid “Pollution under Control” (PUC) certificate and the speed of vehicles shall be limited on village roads to reduce fugitive dust emissions.  Provide sufficient stack height to D.G. sets as per the CPCB norms.

Soil Quality  Provide appropriate storage of top soil in an isolated and covered area to prevent its loss during high wind and runoff.  Use top soil at the time of plantation  Reuse Construction debris in paving on site approach road to prevent dust generation due to vehicular movement.  Re-vegetation to be done in the area after the completion of construction, in order to reduce the risk of soil erosion.

Surface and Ground Water  Construction of dedicated storm water drains considering natural topography for Quality reduction any contamination to runoff due to project activities. Storm water drains shall be designed to avoid any obstruction to natural flow and final outlet shall be connected to propose storm water drains by Solar Power Park Developer;  Proper drainage to be provided for wastewater generated from the Porta Cabins and labour camps and shall be treated on Site septic tanks and soak pits as per the specifications in IS 2470:1995 (Part I and Part II);  Provide separate toilets for male and female workers (if any) in the ratio of 1:15 and 1:10 (toilet to workers) at the project site in order to maintain hygienic and clean surroundings. Washing and bathing areas should be provided with proper drainage system so that wastewater is not accumulated in the project site.

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 Conduct Periodic monitoring to ensure that the waste water is not finding its way into surface and groundwater;  All solid wastes such as construction debris, used or waste oil, paint cans, etc. will be stored on impervious surface in secure location to avoid soil and groundwater contamination;  Paved impervious surface and secondary containment to be used for fuel storage tanks;  Loading and unloading protocols should be prepared and followed for diesel oil and used oil;  Leak proof holding tanks for sanitary waste water to protect the shallow ground water level.  Conservation of water to be undertaken at all project locations and ancillary facilities and if possible, recycling and reuse of water to be taken utilising every opportunity.

Noise Level  Mobile noise sources such as cranes, earth moving equipment and HGVs shall be routed in such a way that there is minimum disturbance to receptors.  EPC Contractor shall instruct their safety officers to arrange for inherently quiet construction equipment and machines to maintain the noise level to minimum.  Only manual construction activities shall be carried out during night-time (i.e. no use of machinery). It is also to be ensured that no village road will be utilized for movement of equipment during the night-time. All loud and sudden noises will be avoided wherever possible and fixed noise sources shall be located at least 50 m away from the site boundary.  Rubber padding/noise isolators will be used for construction equipment or machinery.  Temporary noise barriers shall be provided surrounding the high noise generating construction equipment.  The personnel involved in high noise generating activities shall be provided with adequate PPEs to minimize their exposure to high noise levels.  Construction vehicles and machinery will be well maintained and not kept idling when not in use.

Solid and Hazardous waste  Distribute appropriate number of properly contained litter bins and containers properly management marked as "Municipal Waste" and ensure that the waste is disposed at a regular interval.  Ensure that the waste is  Domestic and construction waste like recyclables viz. paper, plastic, glass, scrap metal waste etc. will be properly segregated and stored in designated waste bins/containers and periodically sold to local recyclers.  Any wastage/damaged part of solar panel will be sent back to panel vendor for disposal.  Used oil, oil-soaked rags, empty oil lined containers and other hazardous waste should be stored in leak proof containers at designated locations in enclosed structures over impermeable surface with adequate labelling as per the provisions of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. Hazardous wastes shall be disposed within ninety days of generation to GPCB approved vendors.  Maintain a register of all hazardous materials used and accompanying MSDS must present at all times.  Spilled material should be tracked and accounted for.

Traffic and Transport  Only trained drivers with valid license shall be recruited by the EPC Contractor for transfer of material;  Ensure that all the traffic rules are obeyed at all the times and driving under the influence of any drug or alcohol shall be strictly prohibited;  Mitigation measures such as emphasizing on safety amongst drivers, adopting limits for trip duration and arranging driver roster to avoid overtiredness and avoiding dangerous routes and times of day to reduce risk of accident shall also be implemented;  Regular maintenance of vehicles and use of manufacturer approved parts should be adopted to minimize potentially serious accidents caused by equipment malfunction or premature failure;  The villagers shall be made aware about the schedule prior to the movement of trucks and transportation in the Project area.

Occupational Health and  Implement the H&S plan provided by the project proponent at the site; Safety  Provide occupation health and safety orientation training to all employees and workers consisting of basic hazard awareness, incident management, site-specific hazards, safe working practices, and emergency procedures;  Ensure all Health and Safety measures are in place to prevent accidents and reduce the consequences of non-conformance events;  Provide training, awareness and supervision to ensure all of its construction workers comply with the OHS procedures;  Provide appropriate resources i.e. PPE to workers on Site; and  An emergency response procedure and infrastructure will be available on Site to ensure provision of first aid for personnel in case of emergency.

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Heat related Stress  Increase air velocity for indoor workers by using natural cross-ventilation from windows management and doors or mobile or ceiling fans.  Operate effective general and local exhaust ventilation and air conditioning;  Avoid non-essential sources of hot ventilation (e.g. air conditioner outlets adjacent to working areas);  Install a shield between employees and a source of radiant heat such as curtains on windows or other insulating barrier, enclose the heat source, or move the heat source away from employees;  Provide cooled drinking water as close as possible to the work site;  Arrange shade for outdoor workers where practicable;  Provide a cool rest area in which workers can take their meal breaks and tea breaks;  Modify the work schedule or shift times so that outdoor and physiologically demanding work is done in the early morning or late afternoon;  Allow workers to self-regulate their pace of work.  Workers should be encouraged to present to work in a well hydrated state, and take frequent small drinks throughout each shift to replace fluid lost through sweating;  Diuretic Fluids such as tea, coffee, alcohol and some soft drinks should not be used to replenish fluid lost due to heat;  Use PPE that reduces exposure to ultra violet radiation and heat (such as reflective masks or aprons, large brimmed hat, sunscreen); and  Workers returning from periods away from hot environments should be given the opportunity to acclimatise before being expected to undertake work in very hot conditions at full capacity.

Labour Management  Ensure that no bonded labour, child labour or forced labour are engaged for project- specific construction activities;  Comply with all the applicable regulations concerning labour and working conditions;  Regularly report on issues relating to labour and working conditions to the project proponent;  Provide a platform for raising, processing and redressing grievances of all the contractual workers;  Undertake regular engagements with internal stakeholders with special reference to contractual workers;  Ensure non-discrimination in matters of terms of employment and payment of wages to all contractual workers including migrant workers;  Ensure usage of PPEs by all contractual workers while performing duty at site; and  Ensure that all facilities and basic amenities as required by relevant national legislations and international best practice are provide din the Labour Camp/ Worker Accommodation facilities.

Community Liaison Officer (CLO)

The CLO would be expected to undertake the following roles:

 Manager, review and develop the Social Program to ensure that it fulfils Project requirements, including measures observed in this ESMP and monitor the implementation;  Co-ordinate and evaluate the effectiveness of all program elements;  Manage the implementation of community health program, including coordination with HSE team on OHS measures associated with management of impact to community health;  Coordinating the HSE team on implementation of the Project vehicle safety measures associated with management of impact to community safety;  Coordinating with Human Resource (HR) team person to ensure implementation of labour related measures required in this ESMP;  Consultation with community and liaison with relevant stakeholders in implementing the required stakeholder and grievance management measures, including liaison with related government bodies as necessary;  Leading collaboration to establish and implement the Project grievance mechanism during construction phase, and supervise contractor’s social performance as required in this ESMP; and  Managing social monitoring and reporting the results to the Project Manager.

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8.4 Inspection, Monitoring and Audit Training is one common method of supplying individuals with additional skills and knowledge. In order to be successful in EHSS management, training programs need to be thought out carefully and systematically. A robust social and environmental, health and safety training plan is important for effective implementation of ESMS.

The EHS Engineer along with recommendations from EHS Projects and EHS Head (at corporate) will ensure that the job specific training and EHS induction training needs are identified based on the specific requirements of the ESMS and existing capacity of site and project personnel (including the Contractors and Sub-contractors) to undertake the required actions and monitoring activities. Some of the specific trainings that will be carried out routine basis are as follows:

 ESMS Checklists and procedural guidance;

 Occupational Health & Safety;  Fire Safety and Prevention;  Emergency Response Preparedness;  Operational Training;

 HR Induction Training;  PPE Training;  Driver Safety; and  Implementation of Environmental and Social Management/Action plans

The above listed trainings are the preliminary trainings which will be undertaken at the inception stage once the employee/worker joins the company and/or Project. Post that, monthly refresher trainings will be undertaken, especially for the workers. Other training will be identified and implemented during the project lifecycle as per the need assessment, as part of mitigation measure and also capacity building of the staffs.

An environmental and social management training programme will be conducted to ensure effective implementation of the management and control measures during construction and operation of the project. The training programme will ensure that all concerned members of the team understand the following aspects:

 Purpose of action plan for the project activities;  Requirements of the specific Action Plans;

 Understanding of the sensitive environmental and social features within and surrounding the project areas; and  Aware of the potential risks from the project activities. In case of contractors or turnkey contractors having sufficiently well-developed standards on EHS management, the training can be sub-let to the same for their respective employees and ESPL will monitor the completion and sufficiency status of these programs. In case of subcontractors, the training and capacity building will be done by the HSE Manager with site responsibilities, along with the contractor’s EHS manager to ensure such trainings of the contracted staffs either directly or through trainers of ESPL. Subsequently the responsibility can be passed on to the sub-contractors for all future training programs. 8.5 Documentation and Record Keeping Documentation and record keeping system has to be established to ensure updating and recording of requirements specified in ESMP. Responsibilities have to be assigned to relevant personnel for ensuring that the ESMP documentation system is maintained and that document control is ensured. The following records shall be maintained at site:

 Documented Environment Management System;  Legal Register;  Operation control procedures;

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 Work instructions;  Incident reports;

 Emergency preparedness and response procedures;  Resource consumption Records;  Training records;  Monitoring reports;

 Auditing reports; and  Complaints register, and issues attended/closed. 8.6 Training Training is one common method of supplying individuals with additional skills and knowledge. In order to be successful in EHSS management, training programs need to be thought out carefully and systematically. A robust social and environmental, health and safety training plan is important for effective implementation of ESMS.

The Assistant HSE Manager along with recommendations from Regional HSE Manager, Regional Project Manager and Site Manager will ensure that the job specific training and EHS induction training needs are identified based on the specific requirements of the ESMS and existing capacity of site and Project personnel (including the Contractors and Sub-contractors) to undertake the required actions and monitoring activities. Some of the specific trainings that will be carried out routine basis are as follows:

 ESMS Checklists and procedural guidance;  Occupational Health & Safety;  Fire Safety and Prevention;  Emergency Response Preparedness;

 Operational Training;  HR Induction Training;  PPE Training;  Driver Safety; and

 Implementation of Environmental and Social Management/Action plans The above listed trainings are the preliminary trainings which will be undertaken at the inception stage once the employee/worker joins the company and/or Project. Post that, monthly refresher trainings will be undertaken, especially for the workers. Other training will be identified and implemented during the Project lifecycle as per the need assessment, as part of mitigation measure and also capacity building of the staffs.

An environmental and social management training program will be conducted to ensure effective implementation of the management and control measures during construction and operation of the Project. The training program will ensure that all concerned members of the team understand the following aspects:

 Purpose of action plan for the Project activities;  Requirements of the specific Action Plans;

 Understanding of the sensitive environmental and social features within and surrounding the Project areas; and  Aware of the potential risks from the Project activities. In case of contractors or turnkey contractors having sufficiently well-developed standards on EHS management, the training can be sub-let to the same for their respective employees and ESPL will monitor the completion and sufficiency status of these programs. In case of subcontractors, the training and capacity building will be done by the HSE Manager with site responsibilities, along with the contractor’s EHS manager to ensure such trainings of the contracted staffs either directly or through trainers of ESPL. Subsequently the responsibility can be passed on to the sub-contractors for all future training programs.

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8.7 Environment and Social Management Plan and Procedures At the project level, ESPL need to develop and implement following plans for management of environmental and social aspects of the project during operation and decommissioning phase:

 Environment and Social Management Plan  Waste Management Plan  Storm Water Management Plan

 Occupational Health and safety Plan  Traffic Management Plan  Emergency Preparedness and Response Plan  Climate Change Vulnerability Adaptability Measures

 Grievance Redressal Mechanism  Stakeholder Engagement Plan  Community Development Plan under CSR  Budgetary provisions for ESMP Implementation

8.7.1 Environment and Social Management Plan The environmental and social management plan proposed during planning and designing phase mainly focuses on the aspects related to land procurement and resettlement, permit compliances, procurement of materials and landscaping. Detailed ESMP proposed for the planning and designing phase is given in the Error! Reference source not found.. 8.7.1.1 ESMP during Construction Phase Major environmental, social and biological aspects considered during the Construction phase are:  Water resources (ground and surface water) and their quality  Ambient Air and Noise quality  Soil quality

 Noise levels  Solid and hazardous waste generation  Ecology and biodiversity  Local Economy of the area

Detailed ESMP proposed during the construction phase is given in Table 8-2.. 8.7.1.2 ESMP during Operation Phase The environmental and social management plan proposed during the operation phase has been prepared considering the impacts this project may have on the surround environment and human beings’ due operational activities.

The major aspects covered during the operation phase are ambient temperature, solid and hazardous waste generation, waste water management, ecology and biodiversity.

Detailed ESMP proposed during the operation phase is given in Table 8-3.. 8.7.1.3 ESMP during Decommissioning Phase During decommissioning phase, all the environmental, social and biologicals aspects that were considered for the construction phase have been taken into consideration. The major aspects covered in the ESMP proposed during

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decommissioning phase are land use, air quality, water quality, soil quality, noise levels and solid and hazardous waste generation. Detailed ESMP proposed during decommissioning phase is presented in Table 8-4.

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Table 8-1: ESMP during Pre-Construction Phase

S. N. Aspects Impacts Impact Mitigation/ Control Measures Impact Intensity Monitoring/ Training Responsibility Intensity with Mitigation Requirements 1. Permit Non-compliance to various  Site has to send an intimation letter to GPCB prior to  ESPL should ensure ESPL Compliance Environmental Permits required and construction listing various project details and obtain Periodic EHS audits pertaining to the proposed Solar other permits related to workers and living conditions. should be conducted Power project or there could be legal Major Minor to verify permit Implications to ESPL requirements and associated compliances

2. ESMP Inadequate implication of ESMP by  Site Specific Environment management system and  ESPL should ensure ESPL Implementation Developer/Contractor procedures should be prepared before construction periodic audits should work commences; be conducted to verify  Social, Environment, Health and Safety Organization the implementation Chart shall be prepared at Corporate level and Site- and effectiveness of the management Moderate specific level; Minor systems.  Proper procedure shall be developed for training of personnel & contractor, ESMP monitoring and  ESPL to ensure that reporting (externally & internally); EPC Contractor complies with the  ESMP shall be part of the tender and bid documents applicable so that contractor can include cost related to ESMP requirements.

3. Procurement of Inadequate implication of ESMP by  The contractor shall follow all stipulated conditions for  Development of EMS ESPL Machineries and Developer/Contractor pollution control as suggested in ESMP and as per the management system Construction regulatory requirements and procedures before Equipment (such  No such installation by the Contractor shall be allowed construction work. as Diesel till all the required legal clearances are obtained from  ESPL to ensure that Moderate Minor Generators, the competent authority EPC Contractor Batching Plant,  Equipment’s conforming to the latest noise and complies with the Concrete mixing emission control measures shall be used. applicable plant etc.) requirements.  PUC certificates for all vehicles and machinery shall be made available for verification whenever required.

4. Biodiversity and Impacts arising from land-clearance,  Enable or facilitate the conservation of the  Training of site ESPL approximately 0.75 square km of natural scrubland personnel, contractors Ecosystem land levelling / grading, installation of Services (Project) habitat in and around the Project Site, to the extent and labour to sensitize fencing and laying of internal access possible. towards biodiversity roads -  Conserve the 0.50 square km of slightly modified and ecosystem  Loss of approximately 0.75 Moderate grassland habitat in and around the Project Site to the Minor services conservation square km of natural scrubland extent possible.  Monitoring of site and approximately 0.5 square  Conservation of the natural topography and drainage clearance process for km of slightly modified in and around the Project Site qualitative and grassland at Project Site quantitative  Minimization of number, length and width of internal documentation of access roads

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

S. N. Aspects Impacts Impact Mitigation/ Control Measures Impact Intensity Monitoring/ Training Responsibility Intensity with Mitigation Requirements  Degradation and fragmentation  Plantation of diverse native vegetation to compensate natural vegetation loss of existing natural scrub forest for that lost to unavoidable land-clearance at the to inform contiguous with natural Project Site compensatory scrubland of Project Site. plantations.  Loss of or loss of access to  ESPL to ensure that priority provisioning EPC Contractor (pasture/fodder) ecosystem complies with the services for the local pastoral applicable community. requirements.

5. Biodiversity and Impacts arising from land-clearance  Conservation of traditional land-use in and around the  Training of site ESPL corridor personnel to sensitize Ecosystem and land levelling/grading - towards biodiversity Services (External   Conservation of comparable alternative habitats away Loss, degradation and and ecosystem Transmission fragmentation of potential from the corridor services conservation Line) wintering habitat of Critically Moderate Minor Endangered Vanellus gregarius  ESPL to ensure that (Sociable Lapwing) EPC Contractor complies with the applicable requirements.

6. Livestock Grazing  Designation of the plot of land  Efforts should be made by ESPL to collaborate with  ESPL should ensure ESPL within the Radhanesda as GUVNL and the Radhanesda Gram Panchayat to that effective grazing land by the district improve the existing vegetation in the designated communication with administration has created grazing land and around the Solar Park. This will help GUVNL, the goodwill among the local in maintaining availability and quality of fodder for the Radhanesda Gram communities for the livestock of Radhanesda. Panchayat and other administration and the solar park regulatory authorities authorities. is done concerning the need for enhancing the  Owing to loss or loss of access Moderate Minor vegetation in the to the ground cover of the Grazing Land. Project Site and rest of the Solar Park, traditionally used as pasture for the livestock of Radhanesda, the grazing pressure on the designated grazing land is likely to increase leading to degradation of fodder quality.

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

Table 8-2: ESMP during Construction Phase S. N. Aspects Impacts Impact Mitigation/ Control Measures Impact Monitoring/ Training Responsibility Intensity Intensity with Requirements Mitigation

Ambient Air  Fugitive Dust due to  The ESPL and contractors shall ensure the reduction and  ESPL /Contractor to ensure all ESPL Quality movement of project control of air emissions from construction activities by vehicles used for vehicles and site minimizing dust from material handling sources. transportation must have a clearance; and  Loading and unloading of raw materials should be carried PUC certificate.  Emission from Diesel out in the most optimum way to avoid fugitive emissions.  ESPL to ensure that EPC Generators.  Sprinkling of water to be carried out by the respective Contractor complies with the contractors to suppress dust from construction activities. applicable requirements.  Best practices such as halting of activity during sustained strong winds should be opted for. It shall be ensured that all stockpiles are covered, and storage areas provided with enclosures to minimize dust from open area source.  Stock piling and storage of construction material will be oriented after considering the predominant wind direction. Moderate  Vehicles engaged for the project will be required to obtain Minor “Pollution under Control” (PUC) certificates.  Sufficient stack height needs to be provided to D.G. sets as per the CPCB norms.  Exhaust emissions of construction equipment to be adhered to emission norms as set out by MoEF&CC/ CPCB.  Speed of vehicles on the village road and on the internal roads shall be limited to 10-15 km/hr in order to reduce fugitive dust emissions.  Cease or phase down work if excess fugitive dust is observed, or there are any community grievance related to dust. Investigate the source of dust and ensure proper dust suppression.

Soil Quality  Top Soil Loss  Allow only covered transportation of top soil within project  Procedure to be developed for ESPL site. utilization of top soil which  Use top soil at the time of plantation. may include isolated storage of top soil and its utilization for  Re-vegetation to be done in the area after the completion Moderate Minor cover the surface or for of construction, in order to reduce the risk of soil erosion. gardening;  Records to be maintain for generation and utilization of top soil.

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

S. N. Aspects Impacts Impact Mitigation/ Control Measures Impact Monitoring/ Training Responsibility Intensity Intensity with Requirements Mitigation  ESPL to ensure that EPC Contractor complies with the applicable requirements.

Surface and  Possibility of contaminated  Construction of dedicated storm water drains for reduction  Regular monitoring of storm ESPL Ground runoff from the site any contamination to runoff due to project activities. water drains to check any Water Quality entering ground; Storm water drains shall be designed considering natural contamination into drains;  Domestic water runoff from topography to avoid any obstruction to natural flow and  Regular monitoring of the portable toilets into the final outlet shall be connected to propose storm water wastewater drains, septic tank ground water can lead to drains by Solar Power Park Developer; and soak pit to check any degradation of water  Proper drainage to be provided for wastewater generated waste findings its way to quality. from the Porta Cabins and labour camps and shall be surface and ground water; treated on Site by constructing temporary septic tanks  Regular monitoring or and soak pits as per the specifications in IS 2470:1995 inspection of fuel storage (Part I and Part II); area, fuel loading/unloading  Periodic monitoring shall be carried out to ensure that the area and hazardous waste waste water is not finding its way into surface and storage area for any spillages Moderate groundwater; Minor or leakages into storage areas  All solid wastes such as construction debris, used or  ESPL to ensure that EPC waste oil, paint cans, etc. will be stored on impervious Contractor complies with the surface in secure location to avoid soil and groundwater applicable requirements. contamination;  Paved impervious surface and secondary containment to be used for fuel storage tanks;  Loading and unloading protocols should be prepared and followed for diesel oil and used oil;  Drip paned provided to vehicles with leaks to prevent water contamination;  Leak proof holding tanks for sanitary waste water to protect the shallow ground water level.

Impact on  Depletion on Ground and  Conservation of water to be undertaken at all project  Water Consumption Records ESPL Water Surface water resources locations and ancillary facilities where possible, create on daily basis; due to project water awareness for water conservation. Availability  Water recycling and reuse demand Moderate Minor plan on yearly basis.

 ESPL to ensure that EPC Contractor complies with the applicable requirements. Noise Level  Disturbance to habitants  In case of complaints of uncomforting noise received from  Periodic monitoring of noise ESPL  Vehicular noise from heavy Moderate the inhabitants of nearby settlements through Grievance Minor level should be conducted and vehicles utilized to deliver compared with the ambient

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

S. N. Aspects Impacts Impact Mitigation/ Control Measures Impact Monitoring/ Training Responsibility Intensity Intensity with Requirements Mitigation construction materials and Redressal Mechanism (GRM) there should be considered noise standard. It should also solar plant parts possibility of putting noise barriers near to the receptor. be made sure that the levels  Noise from DG sets  Mobile noise sources such as cranes, earth moving do not exceeded the national ambient air quality standard  Construction noise from equipment and HGVs shall be routed in such a way that (NAAQS) level; using mobile equipment, there is minimum disturbance to receptors. and concrete mixing  Contractor shall instruct their safety officers to arrange for  Training to drivers of inherently quiet construction equipment and machines to construction equipment maintain the noise level to minimum.  ESPL to ensure that EPC  Only manual construction activities shall be carried out Contractor complies with the during night-time (i.e. no use of machinery). The hours of applicable requirements. operation for specified pieces of equipment or operations, especially mobile sources operating through community areas should be limited. It is also to be ensured that no village road will be utilized for movement of equipment during the night-time. All loud and sudden noises will be avoided wherever possible and fixed noise sources shall be located at least 50 m away from the site boundary.  Rubber padding/noise isolators will be used for construction equipment or machinery.  Temporary noise barriers shall be provided surrounding the high noise generating construction equipment.  The personnel involved in high noise generating activities shall be provided with personal protective devices to minimize their exposure to high noise levels.  Construction vehicles and machinery will be well maintained and not kept idling when not in use.

Solid and Contamination of Land and  Distribute appropriate number of properly contained litter  Periodic EHS audits should be ESPL Hazardous water resources, bins and containers properly marked as "Municipal conducted by ESPL; waste Waste".  Training to Solid and  Domestic and construction waste like recyclables viz. Hazardous Waste Handlers paper, plastic, glass, scrap metal waste etc. will be  ESPL to ensure that EPC properly segregated and stored in designated waste Contractor complies with the bins/containers and periodically sold to local recyclers. applicable requirements. Moderate Minor  Any wastage/damaged part of solar panel will be sent back to panel vendor for disposal.  Used oil should be stored at designated locations in enclosed structures over impermeable surface.  Maintain a register of all hazardous materials used and accompanying MSDS must present at all times.  Spilled material should be tracked and accounted for.

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

S. N. Aspects Impacts Impact Mitigation/ Control Measures Impact Monitoring/ Training Responsibility Intensity Intensity with Requirements Mitigation  Hazardous wastes shall be stored in leak-proof containers and dispose, to disposal facilities registered with the Central Pollution Board.

Traffic and  Community Health and  Only trained drivers with valid license shall be recruited by  Traffic management plan; ESPL Transport Safety Contractor for transfer of material;  Maintain records of driving  Traffic related accidents  Training program for all the drivers, regarding awareness licenses; and injuries; about road safety and adopting best transport and traffic  Training to drivers; safety procedures shall be provided before initiation of the  Increased pollution  Grievance Redressal of any decommissioning activities; complaint received related to  Mitigation measures such as emphasizing on safety traffic amongst drivers, adopting limits for trip duration and  ESPL to ensure that EPC arranging driver roster to avoid overtiredness and Moderate Minor Contractor complies with the avoiding dangerous routes and times of day to reduce applicable requirements. risk of accident shall also be implemented;  Regular maintenance of vehicles and use of manufacturer approved parts should be adopted to minimize potentially serious accidents caused by equipment malfunction or premature failure;  The villagers shall be made aware about the schedule prior to the movement of trucks and transportation in the Project area.

Occupational  Material handling and  Develop and implement a Health and Safety (H&S) plan  Labour engaged for working at ESPL Health and storage to follow throughout the construction phase. Also, ensue height should be trained for Safety  Possible injuries that the H&S plan is provided to the EPC contactor for temporary fall associated with working implementation at the site;  All the workers should be with transmission line  Provide occupation health and safety orientation training made aware of the possible laying to all employees and workers consisting of basic hazard occupational risks/hazards by  Other occupational awareness, site-specific hazards, safe working practices, the way of an OHS hazards and emergency procedures; training/awareness program  Accidents during cutting,  The contractors will be committed to ensure all Health  An accident reporting, and chipping and piling Moderate and Safety measures are in place to prevent accidents Minor monitoring record should be and reduce the consequences of non-conformance maintained  Physical injuries when events; workers involved in  Proper hygienic and scientific loading/unloading activities  The contractors will provide training, awareness and sanitation facilities for all the and don’t adhere to proper supervision to ensure all of its construction workers labourer’s working in the site ergonomics discipline. comply with the OHS procedures; with spate exclusive arrangements for men &  Trip and fall hazards  The contractor will provide appropriate resources i.e. PPE to workers on Site; and women to ensure the privacy  Violation of the privacy and and dignity of all individuals dignity of women involved in the work force.

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

S. N. Aspects Impacts Impact Mitigation/ Control Measures Impact Monitoring/ Training Responsibility Intensity Intensity with Requirements Mitigation  Other occupational  An emergency response procedure and infrastructure will  GRM is properly maintained hazards be available on Site to ensure provision of first aid for and followed on site.  Diseases due to personnel in case of emergency.  Contractor should inform the unhygienic condition labour about Emergency Preparedness Plan (EMP) and communication system to be followed during emergency situation.  ESPL to ensure that EPC Contractor complies with the applicable requirements.

Biodiversity  Loss, degradation or  Restore the soil and natural vegetation of any  Trainings for site personnel, ESPL and fragmentation of construction-phase roads which are not necessary for contractors and labour to Ecosystem habitat for habitat- carrying out operation or maintenance activities, and sensitize towards biodiversity Services specialist species, hence, are not required in the operation and maintenance and ecosystem services (Project) possibly including phase. conservation. globally threatened  Restrict maintenance-related activities to the daytime to  ESPL to ensure that EPC resident and avoid disturbance to adjacent habitats during the night- Contractor complies with the migratory avifaunal time period. applicable requirements. species  Ensure that vehicles and machinery used in the Project  Increase in risk of Site for operation and maintenance activities comply with injury or death the prescribed emission standards. through diversion,  Restrict movement of vehicles used in the Project Site entrapment, collision strictly to the minimum possible pre-designated routes. or electrocution with  respect to globally Restrict operation or maintenance activities requiring high threatened resident Moderate levels of illumination to daylight hours to prevent Minor and migratory and/or disruption of the natural night period by artificial lighting. congregatory  Avoid or minimize the use of artificial lighting in and avifaunal species around the Project Site to the extent possible.  Loss of or hindrance  Opt for low-intensity artificial lighting, such as LED, to in access to priority prevent attraction of insects. provisioning  Ensure that lights in and around the Project Site are (pasture/fodder) provided with downward-facing shades to limit the ecosystem services dispersion of the illumination into adjacent habitats. for the local pastoral  Prohibit the use of herbicides in the facility. community  Opt for manual weeding to control or regulate plant  Loss or degradation growth in the solar panel area. of cultural ecosystem services with respect  Avoid the use of dust-settling chemicals in the facility. to the local community

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

S. N. Aspects Impacts Impact Mitigation/ Control Measures Impact Monitoring/ Training Responsibility Intensity Intensity with Requirements Mitigation  Opt for manual sprinkling of water to control dust in and around the solar panel area.  Institute effective training modules and operational systems to ensure prevention of spillages of toxic substances.  Install effective containment systems to prevent any accidental spillage from leaching into the local environment.

Biodiversity  Fragmentation of Since the external transmission line is a shared facility of the  Trainings for site ESPL and aerial habitat space Project, ESPL should work with GPCL, on a best effort basis, personnel, contractors Ecosystem potentially used by to encourage the adoption of the measures recommended and labour to sensitize Services globally threatened below to minimize electrocution and collision risks to avifauna towards biodiversity and (External resident, migratory from the transmission lines. ecosystem services Transmissio and/or congregatory  Monitoring for estimating bird collision risk and conservation n Line) avifaunal species. identifying high bird use sites or critical avian  ESPL to ensure that  Increase in risk of habitats before and after establishment of the EPC Contractor injury or death by transmission line complies with the collision or  Opting for undergrounding of the transmission line applicable requirements. electrocution with in areas of critical avian habitats respect to globally  Re-routing of the transmission line to avoid critical threatened resident, avian habitats migratory and/or  Minimization of the span of the transmission line to congregatory increase visibility avifaunal species Major Moderate  Insulation of phase conductors to avoid electrocution risk  Installation of line markers on power lines to increase visibility  Opting for horizontal configuration of power lines  Minimization of vertical configuration of power lines  Opting for bundling/clustering of multiconductor transmission lines  Installation of line-markers on power lines to increase visibility  Increasing diameter of shield wires to increase visibility  Opting for blinking lights instead of steady-burning lights where required

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

S. N. Aspects Impacts Impact Mitigation/ Control Measures Impact Monitoring/ Training Responsibility Intensity Intensity with Requirements Mitigation  Restriction of human activity around the transmission line corridor to avoid sudden avian flights in high bird use areas

Local  The project will lead to  Efforts should be made to ensure that maximum  Informal training to EPC ESPL Economy increase in local proportion of the demand for manpower and materials is Contractor on the need for (EPC employment opportunities met locally through contractors and vendors. local sourcing of manpower Contractor) and increased demand for Minor Moderate and materials. materials and services  ESPL to ensure that EPC through local contracting. Contractor complies with the applicable requirements.

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

Table 8-3: ESMP during Operation Phase S. Aspects Impacts Impact Mitigation/ Control Measures Impact Monitoring/ Responsibility N. Intensity Intensity Training with Requirements Mitigation

1. Aesthetics and  Visual and landscape impacts due to  The solar panels to be installed at a low height and to be kept closer to  Visual inspection ESPL Visual presence of Solar Panels the ground so that it does not pop out of the general landscape of the of solar panels area. and ensure that Minor Minor  The panels to be arranged in a systematic manner which will give an panels are not pop aesthetic sense to it. out of the general landscape of the area

2. Impact on Soil  Contamination of land and soil;  Disturbance to soil from repair and maintenance activity will be limited  Periodic checking ESPL and Water  Impacts due to improper waste and will ensure proper restoration of soil wherever excavation is of solid and Quality handling undertaken. hazardous waste  Options of buyback agreements for defunct panels and for replacement storage areas, fuel and disposal of transformer oil by the supplier are to be explored, storage areas, otherwise arrangements for disposal of defunct panels and waste oil to chemical storage authorized recyclers are to be made. areas for checking in spillage or  Fuel and used oil will be stored in demarcated storage areas with Moderate Minor leakages from adequate secondary containment and appropriate capacity. Spill control these areas and prevention mechanism will be developed, and all the staff will be trained.  If the solar panels are washed with chemicals, it should be ensured that the chemicals are non-hazardous and biodegradable;  Storage of oil/chemicals shall be undertaken on paved impervious surface and secondary containment shall be provided for fuel storage tanks;

3. Water  Depletion of water resources due to  The site office shall be provided with sewage line and the collected  Maintaining water ESPL Availability project water demand sewage shall be channelized to a septic tank with soak pit arrangement. consumption  If the solar panels are washed with chemicals, it should be ensured that records on daily the chemicals are non-hazardous in nature. basis; Major  Fuel and used oil will be stored in demarcated storage areas with Moderate  Prepare adequate secondary containment and appropriate capacity. Spill control programme for and prevention mechanism will be developed, and all the staff will be water recycling trained. and reuse and minimize Narmada Canal Water

4. Occupational  Electrocution  Regular electrical safety training to workers with safety procedures and  Labour engaged ESPL other safety requirements that pertain to their respective job for working at Health and  Fire due to short-circuit Moderate Minor Safety of assignments; height should be Workers  Implement Lock out/ Tag Out (LOTO) system;

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

S. Aspects Impacts Impact Mitigation/ Control Measures Impact Monitoring/ Responsibility N. Intensity Intensity Training with Requirements Mitigation  Possible injuries associated with  Use work equipment or other methods to prevent a fall from occurring. trained for working at height Collective protection systems, such as edge protection or guardrails, temporary fall  Diseases due to unhygienic should be implemented before resorting to individual fall arrest  All the workers condition equipment. In addition, safety nets or airbags can be used to minimize should be made the consequences of a fall should it occur. aware of the  Loading and unloading operation of equipment should be done under possible the supervision of a trained professional. occupational  All materials will be arranged in a systematic manner with proper risks/hazards by labelling and without protrusion or extension onto the access corridor. the way of an OHS training/awareness  Personal Protective Equipment (PPEs) e.g., shock resistant rubber program gloves, shoes, other protective gear etc. should be provided to workers handling electricity and related components and monitored that they are  An accident used by the employees reporting, and monitoring record  The transformer yard should be provided with fire extinguishers and should be sand buckets at all strategic locations to deal with any incident of fire; maintained and  Proper hygienic  There should be arrangement for hygienic and scientific sanitation and scientific facilities for all the labourers working in the site. sanitation facilities  An accident reporting, and monitoring record shall be maintained. for all the  Ensure proper sanitation facilities. labourer’s working in the site with spate exclusive arrangements for men & women to ensure the privacy and dignity of all individuals  GRM is properly maintained and followed on site.  Contractor should inform the labour about Emergency Preparedness Plan (EMP) and communication system to be followed during emergency situation.

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

S. Aspects Impacts Impact Mitigation/ Control Measures Impact Monitoring/ Responsibility N. Intensity Intensity Training with Requirements Mitigation 5. Biodiversity  Loss, degradation or  Trainings for site ESPL and Ecosystem fragmentation of habitat for personnel, Services habitat-specialist species,  Restriction of movement of vehicles to pre-designated routes contractors and labour to (Project) possibly including globally  Restriction of maintenance activities to daytime hours threatened resident and sensitize towards  migratory avifaunal species Avoidance of artificial illumination during night-time biodiversity and  ecosystem  Increase in risk of injury or Institution of efficient systems for containment and disposal of waste or services death through diversion, spillage conservation entrapment, collision or  Prohibition of harvesting of water, fuelwood or wild foods (including  Monitoring in and electrocution with respect to fauna) by site employees around the Project globally threatened resident  Moderate Seasonal orientation of solar panelling to minimize albedo with respect Minor Site to document and migratory and/or to wildlife habitats (including any corridors) in the vicinity effectiveness of congregatory avifaunal  Maintenance of bird-deflectors on any overhead internal transmission mitigation species cables to reduce collision-risk to aerially moving fauna measures,  Loss of or hindrance in access  Maintenance of insulation on electrical components to minimize including set- to priority provisioning electrocution risk to fauna asides and offset (pasture/fodder) ecosystem plantations services for the local pastoral  Opt for solar panels with anti-reflective coating (ARC), preferably in community conjunction with white, non-polarizing gridding, to reduce reflectiveness and light-polarization.  Loss or degradation of cultural ecosystem services with respect to the local community 6. Biodiversity  Fragmentation of aerial habitat Since the external transmission line is a shared facility of the Project, ESPL  Trainings for site ESPL and Ecosystem integrity for habitat-specialist should work with GPCL, on a best effort basis, to encourage the adoption of personnel, Services species, possibly including globally the measures recommended below to minimize electrocution and collision contractors and (Transmission threatened resident, migratory risks to avifauna from the transmission lines. labour to Line) and/or congregatory avifaunal sensitize towards species  Maintenance of line-markers or insulation installed on power lines to biodiversity and  Increase in risk of injury or death by minimize electrocution risk to fauna ecosystem collision or electrocution with  Restriction of human activity around the transmission line corridor to services respect to globally threatened Major avoid sudden avian flights in high bird use areas Moderate conservation resident, migratory and/or  Monitoring in the congregatory avifaunal species Transmission Line Corridor to document effectiveness of collision and electrocution mitigation measures

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

S. Aspects Impacts Impact Mitigation/ Control Measures Impact Monitoring/ Responsibility N. Intensity Intensity Training with Requirements Mitigation 7. Employment  Most of the manpower requirement  Specific clauses facilitating the employment of local youths should be  Review of a ESPL Opportunities in the unskilled and semi-skilled incorporated into the EPC contract agreement between ESPL and the monthly statement categories will be sourced from the EPC contractor. prepared by the local area and will comprise of EPC/ O&M youth from the neighbouring Contractor villages; and Minor Moderate highlighting the  Employment of local youths in the details of the project-specific construction/ manpower operation activities will positively employed – contribute to the livelihood of the location-wise, skill- local villages. wise

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

Table 8-4: ESMP during Decommissioning Phase S. Aspects Impacts Impact Mitigation/ Control Measures Impact Monitoring/ Training Responsibility N. Intensity Intensity Requirements with Mitigation 1. Environment  Issue of loss of job when the workers  The proponent shall inform the workers and local  Waste Management Plan for ESPL and will be asked to leave; community about the duration of work; Decommissioning activities; Occupational  Improper disposal of demolition waste  The workers shall be clearly informed about the  Training records to workers; Health and and obsolete machineries will lead to expected schedule and completion of each activity;  Waste Disposal Records; Safety contamination of soil and discontent of  All waste generated from decommissioning phase  OHS programmes and procedures community; shall be collected and disposed off at the nearest confirming IFC PS-2  Demolition activity is anticipated to municipal disposal site; generate dust and exhaust emissions  Sprinkling of water is being carried out to suppress which can be carried downwind to dust from decommissioning activities and transport habitations; movement;  Risks associated with health and  All necessary PPEs shall be used by the workers safety issues such as trip and fall, during demolition work; electrical hazard etc.;  ESPL will be committed to ensure all health and  The decommissioning activities of safety measures are in place to prevent accidents dismantling the solar power plant and and/or reduce the consequences of non-conformance removing the ancillary facilities can events; lead to increased noise levels;  Institution of suitable training modules for project  During the dismantling of the solar personnel and labour contractors involved in the power plant, visual intrusions will be Moderate dismantling process to ensure avoidance or Minor likely by removal of ancillary facilities, minimization of solar panel damage as far as possible but their consequence will be and adherence to appropriate decontamination negligible due to fact that such impact protocols in the event of any unavoidable damage and would be temporary (over a short adhere to proper safe disposal methods. period); Appropriate OHS programme and procedures are also  Depending on the type used, photovoltaic cells may contain toxic expected to be in place to align with the local regulations, substances such as gallium arsenide, as well as IFC PS-2. The procedure will include, at copper-indium-gallium-selenide and minimum, the following measures: cadmium telluride. If any solar panel is damaged during dismantling of the  Develop and implement a health and safety plan to facility, these toxins are likely to spill follow throughout all phases of a project; and leach into the soil and water of the area, posing threat to environmental  Provide occupation health and safety orientation and public health; training to all employees consisting of basic hazard awareness, site-specific hazards, safe working  If the solar panels are not handled or practices, and emergency procedures; disposed of appropriately during the decommissioning phase, any toxic  The contractors will be committed to ensure that all substances contained within them are Health and Safety measures are in place to prevent likely to escape into the surrounding

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

S. Aspects Impacts Impact Mitigation/ Control Measures Impact Monitoring/ Training Responsibility N. Intensity Intensity Requirements with Mitigation air, water or soil, creating serious accidents and reduce the consequences of non- environmental and public health risks. conformance events;  The contractors will provide training, awareness and supervision to ensure all of its construction workers comply with the OHS procedures;  The contractor will provide appropriate resources i.e. PPE to workers on Site; and  An emergency response procedure and infrastructure will be available on Site to ensure provision of first aid for personnel in case of emergency.

2. Improper  Top Soil Loss  Provide appropriate storage of top soil in an isolated  The workforce shall be sensitized ESPL Waste  Contamination of land and soil by and covered area to prevent its loss in high wind and to handling and storage of Disposal hazardous waste runoff. hazardous substances viz. fuel oil, machine oil/fluid etc.  Soil Contamination  Demolition debris would be properly transported in trucks outside the site with cover to prevent spillage  The workers engaged in handling and contamination of local soil hazardous substances shall be  Re-vegetation done in the area after the completion of briefed about the possible hazards demolition and dismantling work in order to reduce the and the need to prevent risk of soil erosion. contamination.  In case of any accidental spill, the soil will be cut and stored securely for disposal with hazardous waste. Major  Store hazardous material (like used oil) in isolated Moderate room with impervious surface. Filling and transfer of oil to and from the container shall be on impervious surface.  Hazardous wastes, when accumulated, be disposed to facilities registered with the GPCB.  Mini Spill Kit shall be provided at site to counter any spill incident.  Cleared or disturbed areas would be rehabilitated as soon as possible to prevent erosion.  Used and broken Solar panels shall be collected at a designated place and sent back to the manufacture.

3. Biodiversity  Loss, degradation or  Restoration of the natural vegetation of the Project  Trainings for site managers, ESPL and Ecosystem fragmentation of habitat for Site contractors and labour to Services habitat-specialist species, Moderate  Conservation of the natural topography and drainage Minor sensitize towards biodiversity (Project) possibly including globally in and around the Project Site and ecosystem services conservation

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S. Aspects Impacts Impact Mitigation/ Control Measures Impact Monitoring/ Training Responsibility N. Intensity Intensity Requirements with Mitigation threatened resident and  Minimization of number, length and width of access migratory avifaunal species roads, followed by restoration of land under the  Increase in risk of injury or death footprint of access roads through diversion, entrapment,  Restriction of movement of vehicles and operation of collision or electrocution with heavy machinery to pre-designated routes respect to globally threatened  Restriction of decommissioning activities to daytime resident and migratory and/or hours congregatory avifaunal species  Avoidance of artificial illumination during night-time  Loss of or hindrance in access  to priority provisioning Avoidance or damping of construction noise and (pasture/fodder) ecosystem vibrations to the maximum extent possible services for the local pastoral  Institution of efficient systems for containment and community disposal of waste or spillage  Loss or degradation of cultural  Prohibition of harvesting of water, fuelwood or wild ecosystem services with respect foods (including fauna) by labour to the local community  Meticulous removal and sensitive disposal of solar panels and other waste, following the best prescribed practices

4. Biodiversity  Fragmentation of aerial habitat  Restoration of the land-use in the Transmission Line  Trainings for site managers, ESPL and Ecosystem integrity for habitat-specialist species, Corridor contractors and labour to sensitize Services possibly including globally threatened  Restriction of movement of vehicles and operation of towards biodiversity and ecosystem (Transmission resident, migratory and/or heavy machinery to pre-designated routes services conservation congregatory avifaunal species Line)  Restriction of decommissioning activities to daytime  Increase in risk of injury or death by hours collision with respect to globally  Avoidance of artificial illumination during night-time threatened resident, migratory and/or Moderate Minor congregatory avifaunal species  Avoidance or damping of noise and vibrations to the maximum extent possible  Prohibition of harvesting of water, fuelwood or wild foods (including fauna) by labour  Meticulous removal and sensitive disposal of transmission line components and other waste, following the best prescribed practices

5. Labour Rights  Approximately 30 % of the total  The workers should be aware of their rights and  Periodic/ surprise audits and ESPL and Welfare manpower, especially in the skilled benefits due to them so that no issues emerge; checks and highly skilled categories to be Minor  Adequate sanitation, drinking water and waste Moderate employed during the construction disposal facilities should be provided to all workers on phase i.e. 180 – 200 will be sourced site as well; from outside the project.

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S. Aspects Impacts Impact Mitigation/ Control Measures Impact Monitoring/ Training Responsibility N. Intensity Intensity Requirements with Mitigation  The project shall ensure that no child or forced labour is engaged by contractors and all wage payments are done without any discriminations or delays by the contractors; and  Grievance Redressal Mechanism for workers should be developed and communicated to the workers so that the workers can approach the management if any concerns or issues are faced by them without any fear of retribution or intimidation.

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8.7.2 Waste Management Plan All project generated wastes will need to be managed and disposed of in a manner to prevent potential impacts on the environment and risks to human health. A Waste Management Plan (WMP) for the proposed project has been developed.

The construction, operation and decommissioning phase of the proposed project will generate various type of waste which will need appropriate collection, transportation, primary treatment and disposal. Hence, to serve the purpose, a Waste Management Plan has been formulated to demonstrate:

 Inventorization of waste in different type of categories like garbage, rubbish, hazardous waste etc.;  Maintain the site in a clean and tidy state to reduce the attraction of pest species, impacts on the local environment and negative impacts on visual amenity; and  Suggestion of options for waste handling and disposal during construction and operation phase of the project. The plan shall be applicable to the ESPL and O&M Contractor engaged by ESPL for the proposed project. The elements of the plan will be directly implemented by the O&M staff deployed on site while overall management and responsibility will lie with ESPL. 8.7.2.1 Waste Type and Quantity Generated All wastes generated from the project will be categorised as either non-hazardous or hazardous following an assessment of the hazard potentials of the material, in line with local and national requirements.

Construction Phase

The waste will generate from construction activities like site clearing, levelling etc. Other categories of waste will be produced daily and comprise of the following:

 Scrap metal;  Soil waste;

 Food waste from kitchen premises of labour accommodation;  Construction debris;  Broken or damaged solar panels; and  Sewage from temporary toilets.

The operation phase will require the use of hazardous materials such as diesel or petrol to cater the fuel equipment and vehicles and maintain equipment. The following hazardous wastes will also be produced from construction activities.

 Oily rags;  Used oil and oil filters - from generators or vehicle maintenance; and

 Scrap and packaging material.

Operation Phase

Operations and maintenance of the PV power facility is not expected to generate any significant amount of waste. PV panels, array enclosures and inverter/transformer enclosures will not produce waste during operation except the following:

 Defunct solar panels;

 Broken solar panels generated during cleaning and other maintenance activities;  Fuel requirements like greasing, transformer oil, and  Oily rags

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Decommissioning Phase

Waste generated during decommissioning phase of the project will generate:

 Demolition waste; and  Obsolete Machinery 8.7.2.2 Waste Management, Handling and Disposal Damaged panels would need to be characterized and managed as hazardous waste. Following measures to be taken for management of waste:

 A buy back agreement for defunct solar panels is required by ESPL / O&M contractor;  A designated area needs to be demarcated within the module premises for storage of defunct and broken solar panels with restricted access and on impervious surface;  All fuel storage should be equipped with secondary containment and spillage trays;  It is to be ensured that hazardous waste (defunct/broken solar panels, used oil, oily rags etc.) is disposed of through GPCB authorized vendor/ recycler;  Transportation of defunct solar panels is required to be undertaken as per the procedures specified by the Manufacture of Solar Panels.  Proper PPEs are to be provided to the workers handling the broken solar panels;  The workers at site are also on regular basis appraised about the potential health risks associated with handling of solar panels.

8.7.3 Storm Water Management Plan The purpose of Storm Water Management Plan (SWMP) is to ensure prevention and control of any adverse impact caused by un-regulated storm water runoff from the main plant to the nearby natural drainage channels, surface water bodies, public and private properties.

Following measures will be taken as part of the Storm Water Management Plan:

 The peripheral drains will be provided outside the plant boundary during construction phase, which will prevent the silt contaminated surface run-off from site to enter into the adjoining lands.  No surface run-off from within the solar power plant site will be directly discharged into any nallah/water body.  Avoidance of disturbance of flows into natural watercourses i.e. provision should be made for temporary or permanent measures that allow for attenuation, control of velocities and capturing of sediment upstream of natural watercourses.

8.7.4 Occupational Health and Safety Plan OHSP provides a guidance document for identifying the potential risks involved in a project operation. This section provides the OHSP applicable to the proposed project, during operation phase of the proposed project. This section also covers the training requirements and safe work practices to be followed onsite to manage various risks involved during the operation phase of the project.

The occupational health and safety plan (OHSP) will address the following:  Evaluation and Identification of hazards;  Defining responsibilities to prevent risks;

 Elimination and removal of hazards;  Control of Hazards which cannot be eliminated; and  Recovery from accidents.

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8.7.4.1 Risk Assessment Risk assessment is an important step in protecting workers. ESPL / O&M Contractor shall ensure a risk assessment to be performed by a competent person before commencement of operations on site. Such an assessment shall as a minimum:

 identify the risks and hazards to which persons may be exposed to;

 analyze and evaluate the identified risks and hazards;  document a plan of safe work procedures, including the use of any personal protective equipment or clothing and the undertaking of periodic “tool box talks” or inductions before undertaking hazardous work, to mitigate, reduce or control the risks and hazards that have been identified;  provide a monitoring plan; and

 provide a review plan.

Risk assessment includes:

 Identification of hazards, discuss with workers and employees actually working at site, check manufacturer’s instructions or data sheets for chemicals and equipment, review accident and ill-health records, long-term hazards to health (e.g. high levels of noise or exposure to harmful substances) as well as safety hazards etc.;  Identify who may be harmed and what type of injury or ill health might occur;  Evaluate the risks and decide on precautions to protect people from harm. Consider if the hazard can be eliminated and controlled so that harm is unlikely. 8.7.4.2 Control Measures Operation of a solar power project involves many on job hazards which need to be identified and eliminated or minimized to an expectable level in order to achieve a safe and healthy work environment. Following control measures can be implemented to prevent risks identified on project site:

 Organize work to reduce exposure to the hazard;  Identification of unsafe working conditions, e.g., falls, electrical hazards, heat/cold stress.  Provide personal protective equipment (e.g. clothing, footwear, goggles etc.);  Provide welfare facilities (e.g. First aid and washing facilities for removal of contamination);

 Implementation of LOTO; and  Record the findings by writing down the findings of the risk assessment. 8.7.4.3 Training Requirements ESPL to ensure that every employee / worker (direct or contractual) is aware of the EHS risks associated with the work being carried out at the site and is trained and competent in the relevant work practices and maintenance procedures. ESPL shall also establish procedures to identify training needs and provide adequate safety training for all levels of employees including contractors. The safety training should provide staff with the knowledge and skills necessary for organising and managing occupational safety and health programmes; team leaders with leadership skills and knowledge to lead, implement and apply occupational safety and health activities; and workers with the knowledge, skills and right attitudes to enable them to work safely. Training proposed for the project includes but not limited to:

 Induction Training on Health and Safety covering  HSE policy;

 Hazards and risks associated with operation and workplace;  Control measure to eliminate or minimize HSE risks, including safe working systems and procedures; use of personal protective equipment; action to be carried out during emergency;  Emergency response procedures, such as firefighting and evacuation procedure;

 Tool Box Training or pre-task briefings, highlighting hazards and the method of dealing with them;

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 Special Job Hazard Training including entry into confined space and another hazardous environment; and  Training on first aid 8.7.4.4 Documentation and Record Keeping ESPL should maintain data and records concerning the identification of hazards, assessment and control of risks of the ongoing activities. The document should establish and maintain procedures for controlling all relevant EHS documents and data. Such documents can include but not limited to:

 EHS Policy;  Hazard Identification Records;  Risk Register;

 Licenses, Certificates, Permits;  Control Methods including process control and machine design, safe work procedures, in-house work rules;  Design Drawings;

 Organization Structure;  HSE group meeting records;  Training Records;  Drill Reports;

 Inspection and Audit Records;  Incident/ Accident Records; and  Medical and Health Surveillance Records

ESPL should communicate and inform any person affected by risks about:

 The nature of risks involved; and  The control measures or safe work procedures to be taken to address the risks involved. The risk assessment should be reviewed and revised upon the occurrence of any injuries to any person as a result of exposure to a hazard in the workplace; or where there is a significant change in work practices or procedures.

8.7.5 Contract Worker Accommodation Plan As indicated earlier, approximately 600 – 700 workers will be engaged during the peak construction phase of the project estimated to span between 2 – 3 months. Out of the total workers engaged during the construction phase, approximately 30 % i.e. 180 – 200 will be migrant workers from neighbouring states. The migrant workers will be hired specifically for skilled and highly skilled activities for which availability of local labour is limited. Discussions with the site representative, the project team of ESPL and review of documents shared by ESPL indicate that the migrant workers will be provided accommodation in a Labour camp proposed to be set up at a distance of approximately 1 km from the project site. The total capacity of the labour camp will be to accommodation approximately 400 workers in 80 rooms i.e. 4-5 workers per room. The basic amenities to be provided in the labour camp such as drinking water, toilets, electrical fittings etc. have been illustrated by ESPL in the form of dedicated documents that were shared for review by the AECOM team. It is to be noted that the Labour camps along with their operation and maintenance will be the responsibility of the EPC Contractor. However, the principal employer i.e. ESPL will be responsible for periodic auditing and review of the labour camp in order to ensure compliance with national laws and the ADB reference framework pertaining to labour camps.

The guidelines/ principles to be followed while undertaking the various key activities during the construction and operations of the labour camp by the EPC Contractor are as follows: -

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8.7.5.1 Designed/ Construction standard

 The height of the rooms should at least be 10 feet;

 The floor should be constructed from PCC Brick work in cement mortar and cement pointing with truss supporting roof or Prefabricated Insulated plastic-coated sheets;

 The minimum area of each room should be 22.5 square mtrs and the minimum area per person should be 3.5 square mtrs;

 Maximum 6 numbers of people should be provided accommodation in one room and all of them should belong to the same gender;

 Separate room should be provided to family members;

 There should be separate entry for bachelor’s and workers living with their family members in order to ensure privacy of the family members of the workers;

 All rooms should be provided with at least one window for ventilation and adequate illumination;

 External lighting should be provided in the camp area to allow persons to move safely during the night time;

 Toilets/ drains should be connected to the septic tank and cleaning of the septic tank should be ensured regularly;

 Before construction of the Labour Camp, fire safety assessment should be done of the proposed site by qualified Fire Safety Personnel and all the suggests proposed therein should be incorporated while construction of the Labour Camp;

 Electrical safety norms should be adhered to ensure electrical safety in the Labour Camp e.g. earthing, MCBs, wiring as per electrical load etc.;

 Adequate drinking water should be provided as per generic standards and the same should be monitored on a monthly basis; and

 Sanitation and drainage should be ensured in order to maintain proper hygiene in the Labour Camp.

8.7.5.2 Drinking water

 All containers used for distribution of water shall be clearly marked ‘Drinking Water Only’ or equivalent and are not to be used for any other purpose;

 Portable containers used for dispensing of drinking water shall have right fitting lids and equipped with a tap. These containers should be kept clean and free from contamination;

 Tanker trucks used for transporting portable water shall be clearly identified and shall not be used for any other purpose;

 Outlets dispensing non-drinking water – for washing, bathing and toilets shall be marked ‘caution – water unfit for drinking and cooking’; and

 Drinking water should meet national/ local drinking water standards.

8.7.5.3 Toilet/ Washing/ Showering Facilities

 Adequate toilet/ washing/ showering facilities should be provided in the Labour Camp. The number of toilets and showering facilities will depend on the size of the Labour Camp and the number of workers being accommodated therein;

 Toilet/ Washing facilities should be provided as required to maintain healthy and sanitary conditions in the Labour Camp. Such facilities should be properly maintained and provided with potable water and drainage to prevent pooling of water; and

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 The areas shall be checked and cleaned daily by a crew comprising of Sanitation workers. Disinfection of floors, sinks and toilet bowls should be carried out by the EPC Contractor.

8.7.5.4 Hygiene and housekeeping

 High standard of hygiene and housekeeping shall always be maintained in the Labour Camp;

 The disposal of waste shall be done regularly as required and disposed of in accordance with the applicable local and national regulations;

 Containers for waste materials shall be placed in all areas and cleaned on a regular basis;

 Rubbish should not be dumped or disposed of indiscriminately but shall be stored in sealed rubbish bags at designated collection points for removal by the sanitary crew for disposal;

 No open fires shall be allowed within the Labour Camp; and

 Pest control measures should be in place to control insects and this should include flogging and spraying during the mosquito breeding season.

8.7.5.5 First aid/ Medical facilities

Access to adequate medical facilities is important to maintain workers’ health and to provide adequate responses in case of health emergency situations. The availability or level of medical facilities provided in the Labour Camp/ Worker’s accommodation is likely to depend on the number of workers living on site, the medical facilities already existing in the neighbouring communities and the availability of transport. However, first aid must always be available in the Labour Camp.

8.7.5.6 Audit and Inspection

EPC Contractor and the caretaker of the Labour Camp shall make a weekly inspection and record the observations along with any required corrective actions.

The EPC Contractor Site-in-Charge will inspect the Camp on a monthly basis along with the Site representative and the Project HR representative of ESPL. The proposed inspection should use the points illustrated in this document as a guiding tool.

Non-conformances identified must be corrected within the agreed timeline.

Non compliances observed during the audit will attract penalty which will be decided by the Project Manager in line with the terms and conditions of the EPC Contract.

8.7.6 Traffic Management Plan

Traffic of more than daily average is anticipated during project decommissioning phase. A Traffic Management Plan is however, required for the management of traffic due to movement of vehicles for transport of equipment and material. Additional traffic on the village road can be managed by measures mentioned below.

8.7.6.1 Management Measures

 Only trained drivers with valid license shall be recruited by ESPL/ Contractor for transfer of material during decommission phase;  Training program for all the drivers, regarding awareness about road safety and adopting best transport and traffic safety procedures shall be provided before initiation of the decommissioning activities;  Mitigation measures such as emphasizing on safety amongst drivers, adopting limits for trip duration and arranging driver roster to avoid overtiredness and avoiding dangerous routes and times of day to reduce risk of accident shall also be implemented;  Regular maintenance of vehicles and use of manufacturer approved parts should be adopted to minimize potentially serious accidents caused by equipment malfunction or premature failure;

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 The villagers shall be made aware about the schedule prior to the movement of trucks and transportation in the project area. 8.7.7 Grievance Redressal Mechanism Grievance Redressal Mechanism (GRM) is an important component of a development project. This is because when developmental projects are initiated, it involves the participation of numerous stakeholders and in the process, the impacts to existing environment and social scenarios are anticipated. Certain changes are expected on the initiation and establishment of development projects. These changes on the one hand may be opportunistic for some individual/ groups while on the other, it may put certain individual/ groups at risk despite attempts to maintain environmental and social accountability. Introduction and formulation of GRM assist in reducing and mitigating the anticipated risks that may arise with the project development. It is understood that effective grievance mechanisms are a part of broader perspective of addressing human and social rights, especially of local communities and neighbourhoods. An effective mechanism would be one which is transparent and approachable and would address the concerns promptly in a culturally appropriate manner. The grievance mechanism should be able to inform and complement the existing stakeholder engagement process. 8.7.7.1 Importance of Grievance Redressal Mechanism

For successful construction and operation of projects, Grievance Redressal Mechanism is an important tool. The primary objective of a Grievance Redressal Mechanism is to develop and promote practices which would ensure creation and sustenance of healthy stakeholder relationships and redressal and expeditious settlement of genuine grievances of affected communities, local communities and NGOs and of internal stakeholder groups such as workers and the management staff. Grievance Redressal Mechanism is a tool which enables risk mitigation as well as a barometer for stakeholder engagement process. Its aim is to be gender inclusive, social class inclusive and a continuous and transparent stakeholder engagement process. It would enable building of trust between the project proponent and the stakeholders thereby bringing about inclusiveness in the entire project cycle. The Grievance Redressal Mechanism is developed with the prime intention of being a primary apparatus for identification of complaints, its subsequent assessment and thereafter the resolution of the complaints. 8.7.7.2 Stages of Grievance Redressal Mechanism As the Grievance Redressal Mechanism for ESIPL is currently not in place, the following section will provide certain recommendations which could be considered while developing a Grievance Redressal Mechanism for the project:

 Development of Procedures: ESIPL should ensure that there is a procedure in place at the site level to lodge and register complaints. Identification of a Community Liaison Officer/ CSR Officer is the foremost step to develop a Grievance Redressal Mechanism. It should be followed by developing formal and documents procedures for receiving complaints, assessment of complaints, procedure to identify the appropriate resolution path and decision making on the final resolution process. These procedures are to be given appropriate time frames to ensure effective and suitable redressal.

 Development of Responses and Suitable Options: The second step would be to develop appropriate responses for the received/ anticipated grievances. Procedures to reach an appropriate resolution should be in place. It could include formal or informal procedures to reach a resolution such as discussions and negotiations. Resolutions can be reached through mediation with the intervention of a third-party, generally a community leader or prominent member of the community.

 Publicise the Grievance Redressal Mechanism: There is a requirement to publicise the grievance redressal mechanism as enhancing awareness regarding the mechanism will increase its usage by stakeholders. Information dissemination to the local community comprises of the next step. The publicising of the GRM can be done through stakeholder engagement activities such as FGDs, local community meetings, and development of communicative methods such as printing of pamphlets with the telephone number of the Grievance officer, installation of grievance boxes at suitable locations, updating of websites etc. The GRM should be documented both in the native language (Tamil) and English for wider outreach.

 Training on Grievance Redressal Mechanism: As the GRM is now in place, it is a prerequisite that the community members and the workers are informed on the procedures involved in the mechanism. For the workers, at the time of recruitment and formal induction programme, they can also be trained on the workings of the GRM. During these trainings the whole process of the GRM should be discussed. It

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includes the identification and appointment of a local point of contact, process of registering a grievance, timelines for redressal of the complaints and information on the personnel involved in the redressal process.

 Recording of Grievances: After the dissemination of the provision of the Grievance Redressal Mechanism, it is a prerequisite that ESIPL should start receiving and addressing the grievances. Required grievances boxes, record books and tracking forms should be developed to address and record the grievances.

 Resolution and Follow up Action: On receiving the complaints and grievances, the corrective action to be taken should be discussed and implemented within stipulated time frames in each level. Record of follow up action in the form of photographs, agreements between the project proponent and the complainant should be documented for reference purposes.

 Appeals: In an event of the complainant not being satisfied with the follow up action, the individual should be offered an appeal process. Involvement of ESIPL in the appeal process is encouraged to maintain transparency and accountability. 8.7.7.3 Proposed Grievance Redressal Mechanism for ESIPL

 Formation of a Grievance Redressal Committee: For the successful implementation of the GRM, it is a prerequisite that ESIPL forms a Grievance Redressal Committee. The formation of the GRC would provide a stipulated framework for the receipt and redressal of grievances.

 Representatives of Grievance Redressal Committee: Representatives in the Grievance Redressal Committee at the project level will include the Community Liaison Officer, Project Manager and Site-in- charge and for the corporate level will include the CSR Head of CSDC and Assistant HSE Manager. 8.7.7.4 Functions of the Grievance Redressal Committee The functions of the Grievance Redressal Committee are the following:

 To record grievances brought up by external stakeholders such as the community members and internal stakeholders such as the workers/ management staff.  To assess and prioritize the grievances and redressal of the grievances within a stipulated time-frame.  To inform the aggrieved community members and workers/ management staff on the progress of the grievance redressal and the outcome or decisions taken by the committee.  In an event of escalation of a grievances, the same should be communicated at the corporate level.

 The Grievance Redressal Committee should proactively analyse the received grievance and accordingly act towards redressing it.  To continually review the existing existent Grievance Redressal Mechanism and its applicability based on local customary tradition and culture. Thereafter, ESIPL should initiate systemic reforms/ modifications, if required for better connectivity and implementation of the GRM. 8.7.7.5 Stages of Grievance Redressal

As Grievance Redressal would involve a multitude of individuals, information and action responses, it is imperative to develop a formal structure which would assist in effective information gathering, recording and addressal of the grievances received. The steps for developing a Grievance Redressal process have been provided below.

Receive and Register a Complaint

 Installation of secured Grievance boxes at relevant sites (such as site office, substation) within the project area.  Dissemination of the mobile-phone number of the Community Liaison Officer as a point of contact for grievances to community members/ workers through display at strategic locations in the site and in neighbouring villages such as the panchayat office.

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 A stakeholder with a concern/ grievance regarding onsite safety, community health and safety, compensation related grievance may register a written complaint to the appointed grievance officer and drop the written complaint at the grievance boxes installed at different locations.  The complainant may have the option of lodging complaints verbally as many may not have the ability to write.  The complainant should have the option to remain anonymous while registering the complaint.  Once received, a database in the form of a manual or computerised Grievance Register should be maintained.

Assessment and Addressal of the Complaint

 The Community Liaison Officer is advised to check and open the grievance boxes every fifteen (15) days.  The grievances will be assessed by the grievance officer in a stipulated time frame of two (02) working days to determine if the issues raised by the complainant falls within the mandate of the grievance mechanism or not.  During the assessment phase, the Grievance Redressal Committee (Level I) team will assess the complaints and discuss the key issues and methods to address the issue. The complainant should be made aware of the results within fifteen (15) working days.  If the grievance cannot be resolved at Site (Level I), then the case will be referred/forwarded to the (Level II) for redressal.  The solution for the grievance shall be devised in five (05) working days by the committee at Level II. On the event of no resolution at Level II, the complainant will have the option to approach the appropriate court of law for redressal.  The complainant will have the opportunity to present and discuss the grievance at all levels of the GRC.

Documentation and Reporting

Documentation and Reporting are important components of Grievance Redressal Mechanism. They help to keep track of the grievances and can be used as a databank for future responses/ mitigation measures to similar grievances.

 Grievance Tracking Form: A Grievance Tracking Form should be prepared. It will enable the GRC to trace the grievances and develop responses that can be communicated to the aggrieved regarding the grievance status.  Grievance Record Book: GRC will maintain a grievance record book containing all the received complaints and actions taken. The grievances record book should include the following details: ─ Name of Complainant (optional in case anonymity is asked to be maintained) ─ Date of the complaint ─ Nature of the complaint

─ Follow-up Action/ Redressal of the complaint ─ Date of communication to the complainant of the result ─ Implementation of the decision. ─ Appeals to higher levels (if any).

 Maintenance of Minutes of Meetings: The Grievance officer shall be responsible to maintain the Minutes of Meetings with stakeholders, complainants and grievance redressal committee 8.7.7.6 Engagement of Third Party

To maintain ultimate transparency and accountability of the grievance mechanism process, third parties such as NGOS, local community etc. can at times be involved. They can in turn serve as process organisers, mediums through which a complaint can be passed on to the company or they can act as facilitators, witnesses, advisors

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or mediators. Third parties can assist in enhancing trust level amongst communities as well as assist in overcoming limitation, if any of the existing project-level mechanism. The engagement of third parties can hence be contemplated upon by the company. 8.7.7.7 Monitoring and Reporting Monitoring and Reporting are requisite tools for measuring the effectiveness of the grievance mechanism. The implementation and execution of the grievance mechanism is to be regularly monitored and reviewed in order to increase its effectiveness. The efficient use of resources, determining broad trends and acknowledging recurring problems before they reach a higher level of contention is extremely necessary to ensure the effectiveness of the grievance redressal mechanism on a whole. They also create a base-level of information that can be used by the project proponent to report back to the stakeholders.19

Monitoring

Depending on the extent of the project impacts and the volume of grievances, monitoring measures like internal (identified corporate level staff) and external audits (third party consultants) can be adopted by ESIPL. The frequency of the audits can be jointly decided by the corporate and the site teams. Through the review of each grievance and its analysis of effectiveness and efficiency, ESIPL can even evaluate systemic deficiencies. Additionally, monitoring of the grievance mechanism helps ensure that the design and implementation of the mechanism in adequately responding to stakeholders’ concerns/ grievances in a timely and cost-effective manner.

Reporting

The grievances that have been received and registered are required to be recorded and regularly updated. The Community Liaison Officer at the site level is responsible for recording and updating the grievances. Minutes of meetings with all stakeholders, complainants and the Grievance Redressal Committee (GRC) should be documented for reference purposes. The monitoring (audit) reports may also be used as a system to report back to the community members on the action/ resolution taken in relation to the grievances and the modification/ changes proposed to make it more user-friendly.

8.7.8 Environment and Social Monitoring Plan 8.7.8.1 Environmental Monitoring Plan Regular monitoring of environmental aspects during the project operations phase is important to assess the status of environment with respect to baseline conditions. The monitored data can serve as an indicator for any change in environmental quality due to the project activities, and further to take adequate mitigation measures to safeguard the environment.

Monitoring indicators have been developed for each of the activity considering the mitigation measures proposed. Monitoring results would be documented, analysed and reported internally. Monitoring requirements (including monitoring frequency) have been presented in Table 8-5.

Table 8-5 Environmental Monitoring Plan

S. No. Environmental Monitoring Parameters Frequency of Responsibility Attribute Monitoring

1. Ambient Air Every Six Months Site Manager Measurement of PM , PM , SO , NO , CO Quality 10 2.5 x x

2. Ambient Noise Every Six Months Site Manager Measurement of Noise Pressure Level in dB(A) quality

3. Soil Quality Physico-chemical parameters monitored for Every Six Months Site Manager baseline data collection

4. Water Physico-chemical parameters monitored for Surface Every Six Months Site Manager Resources and Ground water baseline data collection

Water meter readings to be maintained on daily Monthly Site Manager basis

19 IFC’s Good Practice note on Addressing Grievances from Project-Affected Communities

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S. No. Environmental Monitoring Parameters Frequency of Responsibility Attribute Monitoring

5. Waste Waste inventory for both hazardous and non- Weekly Site Manager hazardous waste, Waste Labelling, storage and disposal records Visual inspection for spilling/ leakages in the waste storage area

Agreements with vendors for waste collection and Every Six Months Site Manager storage for both hazardous and non- hazardous waste

6. Ecological Visual inspection of the site area for death or injury Weekly Site Manager of any higher faunal species due to electrocution,

habitat disturbances due to project activities. Inspection of site area for any spillage of waste materials and possibility of their mixing into natural Monthly water resources.

8.7.8.2 Social and Health and Safety Monitoring Plan Working conditions on site with respect to health and safety of the workers and concerns from the communities are required to be monitored regularly to ensure the positive impacts of the mitigation and management measures taken for the anticipated impacts.

Table 8-6 Social and Health and Safety Monitoring Plan

S. No. Attribute Monitoring Parameter Monitoring Responsibility Frequency

8. Health and Safety  Sanitation status of onsite office building Monthly Site Manager Risks  Potable nature of drinking water with respect to BIS drinking water standards 10500:2012;  Usage of adequate PPEs;  Electromagnetic field  Adequate Health and Safety Training to workers  Fire Safety measures on site  Incident/ Accident Records  Permit to Work Records  LOTO records

8.7.8.3 Monitoring Plan during Decommissioning Phase Following aspects are required to be monitored throughout during the decommission phase, regularly by the Site Manager.

 Local community and workers shall be informed for the duration of works;

 All waste generated from decommissioning phase shall be collected and disposed of to the authorized vendor;  All necessary PPEs shall be used by the workers during demolition work;  Vehicle maintenance records, accident records  Visual inspection of waste storage area;

 Broken/defunct solar panels shall be disposed of to authorized vendor through buy back agreements;  It is to be ensured that dismantling is carried out during non-monsoon season and all the drainage channels will keep intact by creating bunds around them;  ESPL should ensure that retrenchment packages are provided for all staff who stand to lose their jobs when the plant is decommissioned.

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8.7.9 Emergency Preparedness and Response Plan The primary objective of formulating Emergency Preparedness and Response Plan (EPRP) is to undertake immediate rescue and relief operations and stabilize the mitigation process as quickly as possible. The main parameters of a response plan based on such mechanism include:

 Identification and declaration of potential emergencies;  Signal/warning mechanism;  Activities and their Levels;

 Command and control structure;  Individual roles and responsibilities of each specified authority to achieve the activation as per response time;  Emergency procedures;

 Alternate plans & contingency measures; and  Co-ordination with external parties 8.7.9.1 Responsibilities The Site EHS Coordinator will be responsible for implementing this procedure, which includes

 Ensuring that the emergency preparedness measures are in place;  Providing training to the personnel at site regarding reporting of the emergencies, and to site office personnel regarding response to emergency calls from the site personnel,  Direct action-and co-ordination at the time of an emergency 8.7.9.2 Identification of Emergencies All the anticipated hazards and risks associated with each project activity, which may lead to an emergency are identified in the section, along with the required actions to be taken before or after the emergency arises. This section identifies the hazardous areas and activities in the operation phases. Probable emergencies that might arise due to these hazards for the duration of the project have been listed below.

Hazardous Areas

Following potentially hazardous areas and activities hav e been identified at the construction site:  Fuel storage areas  Electrical installations – improper laying of cabl es

 Switch Yard  Transformer Area  Hazardous waste storage area  Broken/ defunct panel storage area Emergency Situations

The possible emergency situations identified for the operation phases of the Project are as listed below:

Fire and Explosion

 Leakage of fuel from storage areas; and  Short-circuit at project site.

Mechanical and Electrical Hazards

 Accidentally dropped object;  Electrocution.

Occupational Hazards

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 Handling of chemicals;  Electrocution;

 Accidents due to vehicle movement; and  Vandalism. 8.7.9.3 Declaration of Emergencies Level 1 (Minor Emergency) All events with no escalation potential and which can be controlled and contained by the action of Safety Officer at the site will be considered as Level 1. In such cases of local alert, Site EHS Manager will be notified. Some typical incidents are:

 Vehicle collision (involving no loss of life);  Equipment damage;

 Medical Evacuation (not very serious cases);  Minor fires.

Level 2 (Serious Emergency)

All events with escalation potential, depending on the effectiveness of the local response will be considered as Level 2. These incidents may impact the entire project operations or have cascading effect. For such type of incidents Site Manager will take the lead. Some typical incidents are:

 Substantial security incident / Vandalism;  Structural collapse;

 Minor Flooding;  Serious damage to structures;  Substantial fire; and  Cultural conflict.

Level 3 (Major Emergency)

The crisis that requires assistance from external resources in order to save lives, minimize damage and to bring the abnormal situation back under control are Level 3 emergencies. These incidents have the potential to impact beyond the project footprints and affect the community. In such cases appropriate government / regulatory authorities will be informed and involved. Some typical Level 3 incidents are:

 Major fire/explosion;  Fatality;  Severe flooding. Personnel on site will know that a Major Emergency has been declared if the site fire alarm siren and /or the local fire alarm systems are activated. The Emergency Siren Modes will be demonstrated and shared with all workers to identify with them.

Level 2 and level 3 will be declared using emergency siren and evacuation shall be done.

8.7.9.4 Emergency Equipment The following points should be implemented to tackle emergency situations:

 Onsite emergency equipment such as first aid boxes, firefighting equipment, PPEs etc. shall be maintained at project site;  The adequacy and availability of emergency equipment shall be assessed at periodic intervals by the EHS Manager;

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 Inventory and locations of respective emergency equipment shall be displayed at project office building and other work areas;  It is to be ensured that the site staff is trained on usage of each type of emergency equipment.

First Aid Boxes

First aid boxes shall be provided at identified locations within the plant premises. A first aid box shall contain, but not limited to the following articles:

 Cotton wool  Sterile gauze  Antiseptic lotion  Box of adhesive dressing (Plasters) for small wounds

 Blunt-ended scissors  Tweezers for removing splinters  Triangular bandages (for making a sling or emergency bandage)  Safety pins

 Sterile eye dressings  Crepe bandages  Aspirin/ Paracetamol tablets  Skin creams for treating burns

 Anti-histamine cream for insect bites and stings

Fire Fighting Equipment

During operation phase, fire extinguishers and sand buckets shall be provided at critical areas such as fuel storage area, waste storage area, areas with electrical installations and project office.

Other firefighting systems to be installed should include:

 Heavy-duty ABC powder type fire extinguishers kept at important electrical equipment areas;  Portable CO2 extinguishers provided throughout the plant

Provision of Personal Protective Equipment (PPE)

Onsite workers and site staff should be provided with adequate number of personal protective equipment (PPEs) to deal with emergency situations. The PPEs shall be stored at the designated Emergency Control Centre (ECC) in the plant premises and will be easily accessible during times of emergency. Training of proper use of PPEs shall be provided to all working personnel on periodic basis.

Assembly Area

Safe assembly area shall be identified and marked and employees to be instructed to gather at the assembly area during emergencies.

Codification of Sirens

The following codes of siren will be following during emergencies:

Table 8-7 Codification of Siren S. No. Siren Indicate Authority

1. 120 seconds Continuous Whelming ON SITE EMERGENCY (ALERT) for Plant Head/ EHS Manager Sound evacuation

2. 30 + 30 + 30 seconds EMERGENCY CONTROLLED Site Manager/ Site EHS Sound with an interval of 5 seconds Manager each

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S. No. Siren Indicate Authority

Below points shall be noted during prevalence of emergency situation:

 Emergency siren to be sounded only if required.

 All staff shall be prior informed of use of emergency sirens during mock drills.  No worker will leave the emergency spot unless ‘all clear’ siren blown. 8.7.9.5 Coordination with External Agencies During emergency situations, Site Manager and Site EHS Manager shall form the Emergency Control Centre (ECC). Site EHS Manager shall coordinate with the following departments:

 Fire brigade;  Police department;

 Hospitals/ Ambulance Services;  Utility departments (electricity and water);  Technical departments such as GPCB, Factory Inspectorate etc.  Local Authorities and District Administration

 District Disaster Control Room, Tharad 8.7.9.6 Emergency Response Team  The Emergency Response Team (ERT) shall be set up immediately for the project;

 Each personnel identified as part of the ERT shall be designated specific roles and responsibilities for handling emergency situations.  The ERT at the operating site under its control will have following role:  Control the emergency and render the facility premises safe by the application of local resources; and

 Support the local response effort by coordinating additional equipment, personnel, and other external resources for the direct response effort.  The ERT will comprise of the following personnel: ─ Site Manager; ─ Site EHS Manager;

─ Safety Officer(s); ─ Evacuation Officer; ─ Employee/Workers 8.7.9.7 Emergency Response Procedure Effective command and control start with a clear definition of the overall command and control structure, and description of the duties of key personnel with specific responsibilities for emergency response. The control of emergencies will consider the minimum number of persons required to provide an adequate response to emergencies.

All emergencies occurring as a result of project activities shall be managed according to the following order of priorities:  Preservation of Life (self, team, community);

 Protection of the Environment;  Protection or Property/assets; and,  Preservation of Evidence.

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8.7.9.8 Reporting and Documentation

The following aspects need to be communicated for the emergency reporting:  While witnessing or receiving notification of an emergency, as much information as possible should be taken and/or conveyed to the relevant emergency activation authority;  Where possible, all information should be logged in written form with time and date included and provided to EHS Manager;  Personnel working on the site may, at any time, be exposed to an emergency which could take many forms, for example (but not limited to): ─ Injuries and/or fatalities ─ Fires and/or explosions ─ Extreme weather

 When an emergency occurs, an appropriate and prompt response is required, providing precise action to control, correct and return the site to a safe condition. Timely action will also be required to protect people, the environment and property from damage; and  All near misses and unsafe acts will be written in logbooks / reported in the ‘near miss, unsafe acts, hazards and sub-standard conditions report’ and verbally communicated to the concerned Site Supervisor within a reasonable time.

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9. Conclusions and Recommendations

The Environmental and Social Assessment study for the proposed 200 MW solar power project to be developed by ESPL in Banaskantha District of Gujarat has been undertaken in accordance with International Finance Corporation (IFC) Sustainability Framework (Policy and Performance Standards on Environmental and Social Sustainability) 2012 and the associated World Bank Group Environmental Health and Safety Guidelines, ADB’s 2009 Safeguard Policy Statement (SPS) and FMO's Social Sustainability Policy.

The ESIA study aimed to identify and evaluate potential environmental and social impacts associated with all aspects of the proposed project. The conclusion and recommendations of this study are result of on-site inspections, evaluation of impacts identified, and the process of stakeholder consultation. The proposed project is an opportunity to utilize the solar potential of the state for power generation. There are no fuel requirements or large quantities of water required for the operation of the plant. GHG emissions and other environmental pollution (stack emissions, ash management etc.) issues are also limited.

Categorisation of Project as per IFC Environment and Social Sustainability Standards:

Additional rationale for the above categorization is as below:

 Solar power project is a clean technology project using solar energy for generation of electricity;  No harmful emissions are expected from the project operations;

 The Project Site does not coincide or overlap with any Designated Area; and  Available data suggests that the construction, operation and decommissioning of the proposed solar project are likely to have limited environmental and social impacts which can be readily addressed with mitigation measures.

Categorisation of Project as per ADB Safeguard Policy Statement (2009):

 Solar power project is a clean technology project using solar energy for generation of electricity;  No harmful emissions are expected from the project operations;  The Project Site does not coincide or overlap with any Designated Area;  Available data suggests that the construction, operation and decommissioning of the proposed solar project are likely to have limited environmental and social impacts which can be readily addressed with mitigation measures. On the backdrop of the understanding of the categorisation of ADB Projects and based on Involuntary Resettlement impacts and based on the following facts, the proposed Project can be classified as Category C with respect to SPS 2 – Involuntary Resettlement. The rationale for categorisation is as follows:

 The proposed Project is being set up on land owned by the Government of Gujarat (GoG) and has been leased to the proponent for a period of 25 years;

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 The land has not been procured from any private land owners and has been in continuous possession of the GoG for at least a period of more than 60 years i.e. since 1960s;  No livelihood activities apart from some grazing was reported or observed on the proposed Project land parcel; and  No housing structures, habitations or settlements were reported or observed at site during the site visit. The same was confirmed through community consultations and discussions with institutional stakeholders. On the backdrop of the understanding of the categorisation of ADB Projects and based on impacts of IPs and based on the following facts, the proposed Project can be classified as Category C with respect to SPS 3 – IPs. The rationale for categorisation is as follows:

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Appendix A Participant list of Stakeholder Consultations

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Appendix B Mammals of the Study Area

SN Scientific Name Common Name IUCN Status * WPA Schedule**

1 Equus hemionus khur Asiatic Wild Ass NT I

2 Boselaphus tragocamelus Blue Bull LC III

3 Gazella bennettii Indian Gazelle LC I

4 Antilope cervicapra Blackbuck LC I

5 Caracal Caracal LC I

6 Felis silvestris Asiatic Wild Cat LC I

7 Felis chaus prateri Jungle Cat LC II

8 Prionailurus rubiginosus Rusty Spotted Cat NT I

9 Viverricula indica Small Indian Civet LC II

10 Herpestes edwardsii Grey Mongoose LC II

11 Herpestes auropunctatus Small Indian Mongoose LC IV

12 Hyaena Striped Hyaena NT III

13 Canis lupus Grey Wolf LC I

14 Canis aureus Golden Jackal LC II

15 Vulpes bengalensis Indian Fox LC II

16 Vulpes pusilla Red Fox LC II

17 Mellivora capensis Honey Badger LC I

18 Lutrogale perspicillata Smooth-coated Otter VU I

19 Lepus nigricollis dayanus Indian Hare LC IV

20 Manis crassicaudata Indian Pangolin EN I

21 Suncus murinus House Shrew LC -

22 Suncus etruscus Pygmy White-toothed Shrew LC -

23 Paraechinus micropus Indian Hedgehog LC IV

24 Hemiechinus collaris Desert Hedgehog LC -

25 Hystrix indica Indian Crested Porcupine LC IV

26 Funambulus pennantii Northern Palm Squirrel LC IV

27 Tatera indica Indian Gerbil LC -

28 Meriones hurrianae Indian Desert Jird LC -

29 Gerbillus gleadowi Little Indian Hairy-footed Gerbil LC -

30 Mus musculus House Mouse LC V

31 Mus booduga Little Indian Field Mouse LC V

32 Millardia meltada Soft-furred Field Rat LC V

33 Golunda ellioti Indian Bush Rat LC V

34 Bandicota indica Large Bandicoot Rat LC V

35 Rattus House Rat LC V

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*Status assigned by the International Union for Conservation of Nature and Natural Resources, where –CR – Critically Endangered; EN – Endangered; LC – Least Concern, NA – Not Assessed; NT – Near Threatened; and VU - Vulnerable.

**Schedules I to VI: Indian Wildlife (Protection) Act, 1972.

Sources: Vivek Menon (2014), Indian Mammals: A Field Guide. Hachette Book Publishing India Pvt. Ltd., Gurgaon, India, pp 1- 522; The IUCN Red List of Threatened Species. Version 2019-3; Schedules I to VI: Indian Wildlife (Protection) Act, 1972.

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Appendix C Resident Birds of the Study Area

SN Scientific Name Common Name IUCN Status* WPA Schedule**

1 Francolinus pondecerianus Grey Francolin LC IV

2 Pavo cristatus Indian Peafowl LC I

3 Sarkidiornis melanotos Knob-billed Duck LC IV

4 Nettapus coromandelianus Cotton Pygmy Goose LC IV

5 Anas poecilorhyncha Indian Spot-billed Duck LC IV

6 Tachybaptus ruficollis Little Grebe LC IV

7 Mycteria leucocephala Painted Stork LC IV

8 Anastomus oscitans Asian Openbill LC IV

9 Phoenicopterus roseus Greater Flamingo LC IV

10 Phoenicopterus minor Lesser Flamingo NT IV

11 Threskiornis melanocephala Black-headed Ibis LC IV

12 Pseudibis papillosa Red-naped Ibis LC IV

13 Platalea leucorodia Eurasian Spoonbill LC I

14 Ardeola grayii Indian Pond Heron LC IV

15 Ardea purpurea Purple Heron LC IV

16 Bubulcus ibis Cattle Egret LC IV

17 Egretta garzetta Little Egret LC IV

18 Falco chicquera Red-necked Falcon NT I

19 Falco jugger Laggar Falcon NT I

20 Elanus caeruleus Black-winged Kite LC IV

21 Milvus migrans Black Kite LC IV

22 Haliastur indus Brahminy Kite LC IV

23 Ichthyophaga ichthyaetus Grey-headed Fish Eagle NT IV

24 Pernis ptilorhynchus Oriental Honey Buzzard LC IV

25 Neophrons percnopterus Egyptian Vulture EN IV

26 Gyps bengalensis White-rumped Vulture CR I

27 Gyps indicus Indian Vulture CR I

28 Sarcogyps calvus Red-headed Vulture CR IV

29 Circaetus gallicus Short-toed Snake Eagle LC IV

30 Spilornis cheela Crested Serpent Eagle LC IV

31 Accipiter badius Shikra LC I

32 Butastur teesa White-eyed Buzzard LC IV

33 Aquila rapax Tawny Eagle LC IV

34 Aquila fasciata Bonelli’s Eagle LC IV

35 Amaurornis phoenicurus White-breasted Waterhen LC IV

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36 Turnix suscitator Barred Buttonquail LC -

37 Porphyrio Purple Swamphen LC IV

38 Gallinula chloropus Common Moorhen LC IV

39 Fulica atra Eurasian Coot LC IV

40 Grus antigone Sarus Crane VU I

41 Burhinus (oedicnemus) indicus Indian Thick-knee LC IV

42 Hydrophasianus chirurgus Pheasant-tailed Jacana LC IV

43 Himantopus Black-winged Stilt LC IV

44 Vanellus indicus Red-wattled Lapwing LC IV

45 Charadris dubius Little Ringed Plover LC IV

46 Charadrius alexandrinus Kentish Plover LC IV

47 Rostratula bengalensis Greater Painted-snipe NA IV

48 Cursorius coromandelicus Indian Courser LC -

49 Glareola maldivarum Oriental Pratincole LC -

50 Glareola lactea Small Pratincole LC -

51 Sterna aurantia River Tern LC -

52 Sterna acuticauda Black-bellied Tern LC -

53 Pterocles exustus Chestnut-bellied Sandgrouse LC IV

54 Pterocles indicus Painted Sandgrouse LC IV

55 Columba livia Common Pigeon LC -

56 Streptopelia decaocto Eurasian Collared Dove LC IV

57 Streptopelia tranquebarica Red Collared Dove LC IV

58 Stigmatopelia senegalensis Laughing Dove LC IV

59 Psittacula krameri Rose-ringed Parakeet LC IV

60 Eudynamis scolopaceus Asian Koel LC IV

61 Taccocua leschenaultii Sirkeer Malkoha LC IV

62 Centropus sinensis parroti Southern Coucal LC IV

63 Tyto alba Barn Owl LC IV

64 Athene brama Spotted Owlet LC IV

65 Bubo bubo Eurasian Eagle Owl LC IV

66 Ketupa zeylonensis Brown Fish Owl LC IV

67 Caprimulgus mahrattensis Sykes’s Nightjar LC IV

68 Caprimulgus asiaticus Indian Nightjar LC IV

69 Caprimulgus affinis Savanna Nightjar LC IV

70 Apus affinis Little Swift LC -

71 Coracias benghalensis Indian Roller LC IV

72 Halcyon smyrnensis White-throated Kingfisher LC IV

73 Alcedo atthis Common Kingfisher LC IV

74 Ceryle rudis Pied Kingfisher LC IV

75 Merops orientalis Green Bee-eater LC -

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76 Megalaima haemocephala Coppersmith Barbet LC IV

77 Dendrocopos mahrattensis Yellow-crowned Woodpecker LC IV

78 Tephrodornis pondicerianus Common Woodshrike LC IV

79 Coracina macei Large Cuckooshrike LC IV

80 Aegithinia nigrolutea Marshall’s Iora LC IV

81 Pericrocotus erythropygius White-bellied Minivet LC IV

82 Pericrocotus cinnamomeus Small Minivet LC IV

83 Lanius vittatus Bay-backed Shrike LC -

84 Lanius schach Long-tailed Shrike LC -

85 Lanius meridionalis Southern Grey Shrike LC -

86 Dicrurus macrocercus Black Drongo LC -

87 Rhipidura aureola White-browed Fantail LC IV

88 Dendrocitta vagabunda Rufous Treepie LC IV

89 Corvus (corax) subcorax Punjab Raven LC IV

90 Corvus splendens House Crow LC V

91 Ptyonoprogne concolor Dusky Crag Martin LC -

92 Hirundo smithii Wire-tailed Swallow LC IV

93 Alaemon alaudipes Greater Hoopoe Lark LC IV

94 Melanocorypha bimaculata Bimaculated Lark LC IV

95 Ammomanes phoenicurus Rufous-tailed Lark LC IV

96 Ammomanes deserti Desert Lark LC IV

97 Calandrella raytal Sand Lark LC IV

98 Eremopterix nigriceps Black-crowned Sparrow Lark LC IV

99 Galerida cristata Crested Lark LC IV

100 Alauda gulgula Oriental Skylark LC IV

101 Pycnonotus leucotis White-eared Bulbul LC IV

102 Pycnonotus cafer Red-vented Bulbul LC IV

103 Prinia hodgsonii Grey-breasted Prinia LC -

104 Prinia gracilis Graceful Prinia LC -

105 Prinia inornata Plain Prinia LC -

106 Prinia buchanani Rufous-fronted Prinia LC -

107 Orthotomus sutorius Common Tailorbird LC IV

108 Chaetornis striata Bristled Grassbird VU IV

109 Turdoides caudata Common Babbler LC IV

110 Turdoides malcolmi Large Grey Babbler LC IV

111 Chrysomma sinense Yellow-eyed Babbler LC IV

112 Acridotheres ginginianus Bank Myna LC IV

113 Acridotheres tristis Common Myna LC IV

114 Sturnia pagodarum Brahminy Starling LC IV

115 Saxicoloides fulicatus Indian Robin LC IV

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116 Saxicola macrorhynchus Stoliczka’s Bushchat VU IV

117 Cinnyris asiaticus Purple Sunbird LC IV

118 Passer domesticus House Sparrow LC -

119 Gymnoris xanthocollis Chestnut-shouldered Petronia LC -

120 Ploceus philippinus Baya Weaver LC IV

121 Euodice malabarica Indian Silverbill LC -

122 Anthus rufulus Paddyfield Pipit LC IV *Status assigned by the International Union for Conservation of Nature and Natural Resources, where –CR – Critically Endangered; EN – Endangered; LC – Least Concern, NA – Not Assessed; NT – Near Threatened; and VU - Vulnerable.

**Schedules I to VI: Indian Wildlife (Protection) Act, 1972.

Sources: R. Grimmett, C. Inskipp & T. Inskipp (2011). Birds of the Indian Subcontinent. Oxford University Press, pp 1-528; IUCN (2019). The IUCN Red List of Threatened Species. Version 2019-3.; Schedules I to VI: Indian Wildlife (Protection) Act, 1972.

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Appendix D Migratory Birds of the Study Area

SN Scientific Name Common Name IUCN Status* WPA Schedule** Type of Migrant

1 Coturnix coturnix Common Quail LC IV Winter

2 Coturnix coromandelica Rain Quail LC IV Summer

3 Tadorna ferruginea Ruddy Shelduck LC IV Winter

4 Marmaronetta angustirostris Marbled Duck LC IV Winter

5 Anas strepera Gadwall LC IV Winter

6 Anas penelope Eurasian Wigeon LC IV Winter

7 Anas platyrhynchos Mallard LC IV Winter

8 Anas clypeata Northern Shoveler LC IV Winter

9 Anas acuta Northern Pintail LC IV Winter

10 Anas querquedula Garganey LC IV Winter

11 Anas crecca Common Teal LC IV Winter

12 Netta rufina Red-crested Pochard LC IV Winter

13 Aythya ferina Common Pochard VU IV Winter

14 Aythya fuligula Tufted Duck LC IV Winter

15 Mergellus albellus Smew LC IV Winter

16 Podiceps cristatus Great Crested Grebe LC IV Winter

17 Ciconia nigra Black Stork LC IV Winter

18 Ciconia ciconia White Stork LC IV Winter

19 Phoenicopterus roseus Greater Flamingo LC IV Winter

20 Ardea cinerea Grey Heron LC IV Winter

21 Pelecanus onocrotalus Great White Pelican LC IV Winter

22 Pelecanus crispus Dalmatian Pelican NT IV Winter

23 Microcarbo niger Little Cormorant LC IV Winter

24 Phalacrocorax fuscicollis Indian Cormorant LC IV Winter

25 Phalacrocorax carbo Great Cormorant LC IV Winter

26 Falco tinnunculus Common Kestrel LC IV Winter

27 Falco subbuteo Eurasian Hobby LC IV Winter

28 Falco cherrug Saker Falcon LC IV Winter

29 Falco peregrinus Peregrine Falcon LC IV Winter

30 Falco (peregrinus) pelegrinoides Barbary Falcon NA IV Winter

31 Milvus (migrans) lineatus Black-eared Kite NA IV Winter

32 Pandion haliaetus Osprey LC I Winter

33 Gyps fulvus Griffon Vulture LC IV Winter

34 Aegypius monachus Cinereous Vulture NT IV Winter

35 Circus aeruginosus Eurasian Marsh Harrier LC IV Winter

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36 Circus macrourus Pallid Harrier NT IV Winter

37 Circus pygargus Montagu’s Harrier LC IV Winter

38 Buteo rufinus Long-legged Buzzard LC IV Winter

39 Aquila clanga Greater Spotted Eagle VU IV Winter

40 Aquila nipalensis Steppe Eagle EN IV Winter

41 Aquila heliaca Eastern Imperial Eagle VU IV Winter

42 Hieraaetus pennatus Booted Eagle LC IV Winter

43 Chlamydotis macqueenii Macqueen’s Bustard VU I Winter

44 Turnix sylvaticus Small Buttonquail LC - Summer

45 Turnix tanki Yellow-legged Buttonquail LC - Summer

46 Grus virgo Demoiselle Crane LC IV Winter

47 Grus grus Common Crane LC IV Winter

48 Recurvirostra avosetta Pied Avocet LC IV Winter

49 Vanellus gregarius Sociable Lapwing CR IV Winter

50 Calidris pugnax Ruff LC IV Winter

51 Gallinago gallinago Common Snipe LC IV Winter

52 Limosa limosa Black-tailed Godwit NT IV Winter

53 Numenius arquata Eurasian Curlew NT IV Winter

54 Tringa erythropus Spotted Redshank LC IV Winter

55 Tringa totanus Common Redshank LC IV Winter

56 Tringa nebularia Common Greenshank LC IV Winter

57 Tringa ochropus Green Sandpiper LC IV Winter

58 Tringa glareola Wood Sandpiper LC IV Winter

59 Actitis hypoleucos Common Sandpiper LC IV Winter

60 Calidris minuta Little Stint LC IV Winter

61 Cursorius cursor Cream-coloured Courser LC IV Winter

62 Chroicocephalus brunnicephalus Brown-headed Gull LC IV Winter

63 Gelochelidon nilotica Gull-billed Tern LC IV Winter

64 Hydroprogne caspia Caspian Tern LC IV Winter

65 Chlidonias hybrida Whiskered Tern LC IV Winter

66 Chlidonias leucopterus White-winged Tern LC IV Winter

67 Pterocles alchata Pin-tailed Sandgrouse LC IV Winter

68 Pterocles senegallus Spotted Sandgrouse LC IV Winter

69 Pterocles orientalis Black-bellied Sandgrouse LC IV Winter

70 Streptopelia orientalis Oriental Turtle Dove LC IV Winter

71 Clamator jacobinus Jacobin Cuckoo LC IV Winter

72 Asio flammeus Short-eared Owl LC IV Winter

73 Caprimulgus europaeus European Nightjar LC IV Winter

74 Tachymarptis melba Alpine Swift LC IV Winter

75 Upupa epops Common Hoopoe LC - Winter

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76 Coracias garrulus Eurasian Roller LC IV Passage

77 Merops persicus Blue-cheeked Bee-eater LC - Summer

78 Jynx torquilla Eurasian Wryneck LC IV Winter

79 Lanius isabellinus Isabelline Shrike LC - Winter

80 Lanius phoenicuroides Red-tailed Shrike LC - Passage

81 Hirundo rustica Barn Swallow LC - Winter

82 Calandrella brachydactyla Greater Short-toed Lark LC IV Winter

83 Acrocephalus stentoreus Clamorous Reed Warbler LC IV Winter

84 Phylloscopus collybita Common Chiffchaff LC - Winter

85 Phylloscopus neglectus Plain Leaf Warbler LC - Winter

86 Sylvia curruca Lesser Whitethroat LC - Winter

87 Sylvia (curruca) minula Desert Whitethroat LC - Winter

88 Sylvia althaea Hume’s Whitethroat LC - Passage

89 Sylvia hortensis Orphean Warbler LC - Winter

90 Sylvia nana Asian Desert Warbler LC - Winter

91 Pastor roseus Rosy Starling LC IV Winter

92 Luscinia svecica Bluethroat LC IV Winter

93 Cercotrichas galactotes Rufous-tailed Scrub Robin LC IV Winter

94 Phoenicurus ochruros Black Redstart LC IV Winter

95 Saxicola torquatus Common Stonechat LC IV Winter

96 Saxicola caprata Pied Bushchat LC IV Winter

97 Oenanthe isabellina Isabelline Wheatear LC IV Winter

98 Oenanthe chrysopygia Red-tailed Wheatear LC IV Winter

99 Oenanthe deserti Desert Wheatear LC IV Winter

100 Oenanthe picta Variable Wheatear LC IV Winter

101 Monticola solitarius Blue Rock Thrush LC IV Winter

102 Ficedula parva Red-breasted Flycatcher LC IV Winter

103 Passer hispaniolensis Spanish Sparrow LC IV Winter

104 Motacilla flava Yellow Wagtail LC - Winter

105 Motacilla citreola Citrine Wagtail LC - Winter

106 Motacilla cinerea Grey Wagtail LC - Winter

107 Motacilla alba White Wagtail LC - Winter

108 Anthus campestris Tawny Pipit LC IV Winter

109 Anthus hodgsoni Olive-backed Pipit LC IV Winter

110 Emberiza melanocephala Black-headed Bunting LC IV Winter *Status assigned by the International Union for Conservation of Nature and Natural Resources, where –CR – Critically Endangered, EN – Endangered, LC – Least Concern, NA – Not Assessed; NT – Near Threatened; and VU - Vulnerable.

**Schedules I to VI: Indian Wildlife (Protection) Act, 1972.

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Appendix E Reptiles of the Study Area

SN Scientific Name Common Name IUCN Status* WPA Schedule**

1 Indotyphlops braminus Brahminy Blind Snake LC ‐

2 Python molurus Indian Rock Python LC I

3 Eryx conicus Russel's Boa LC -

4 Eryx johnii Indian Sand Boa LC -

5 Boiga trigonata Common Cat Snake LC -

6 Coelognathus helena Common Trinket Snake LC -

7 Fowlea piscator Checkered Keelback LC II

8 Lycodon aulicus Indian Wolf Snake LC -

9 Lycodon striatus Barred Wolf Snake LC -

10 Oligodon arnensis Banded Kukri Snake LC -

11 Oligodon taeniolatus Variegated Kukri Snake LC -

12 Platyceps ventromaculatus Glossy-bellied Racer LC -

13 Ptyas mucosa Indian Rat Snake LC II

14 Spalerosophis atriceps Black-headed Royal Snake NE -

15 Psammophis leithii Leith's Sand Snake LC -

16 Bungarus caeruleus Common Krait LC -

17 Bungarus sindanus Sind Krait NE -

18 Naja naja Indian Cobra LC II

19 Echis carinatus Saw-scaled Viper LC -

20 Cyrtopodion kachhense Kutch Bent-toed Gecko NE -

21 Calotes minor Dwarf Ground Lizard DD -

22 Calotes versicolor Indian Garden Lizard LC -

23 Hemidactylus frenatus Asian House Gecko LC -

24 Saara hardwickii Indian Spiny-tailed Lizard NE II

25 Sitana spinaecephalus Fan-throated Lizard LC -

26 Trapelus agilis Brilliant Ground Agama NE -

27 Chamaeleo zeylanicus Indian Chameleon LC II

28 Cyrtopodion scabrum Rough Bent-toed Gecko LC -

29 Hemidactylus flaviviridis Northern House Gecko LC -

30 Hemidactylus leschenaultii Leschenault's Leaf-toed Gecko LC -

31 Hemidactylus sahgali Sahgal's Termite Hill Gecko LC -

32 Eublepharis fuscus West Indian Leopard Gecko LC -

33 Acanthodactylus cantoris Indian Fringe-fingered Lizard NE -

34 Ophisops jerdonii Jerdon's Snake-eyed Lacerta LC -

35 Ophisops kutchensis Kutch Small-scaled Snake-eye NE -

36 Ablepharus grayanus Minor Snake-eyed Skink NE -

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37 Eurylepis taeniolatus Alpine Punjab Skink NE -

38 Eutropis carinata Keeled Indian Mabuya LC -

39 Eutropis macularia Bronze Grass Skink LC -

40 Ophiomorus raithmai Three-fingered Sandfish LC -

41 Varanus bengalensis Bengal Monitor LC I

42 Varanus griseus Desert Monitor NE -

43 Geochelone elegans Indian Star Tortoise VU IV

44 Lissemys punctata Indian Flapshell Turtle LC I *Status assigned by the International Union for Conservation of Nature and Natural Resources, where – DD – Data Deficient; LC – Least Concern; NE – Not Evaluated and VU - Vulnerable.

**Schedules I to VI: Indian Wildlife (Protection) Act, 1972.

Sources: Patel, H., Vyas, R. (2019) Reptiles of Gujarat, India: Updated Checklist, Distribution, and Conservation Status. Herpetology Notes, Vol. 12 pp. 765-777.; The IUCN Red List of Threatened Species. Version 2019-3.; Schedules I to VI: Indian Wildlife (Protection) Act, 1972.

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Appendix F Amphibians of the Study Area

SN Scientific Name Common Name IUCN Status* WPA Schedule**

1 Duttaphrynus melanostictus Asian Common Toad LC IV

2 Duttaphrynus stomaticus Indian Marbled Toad LC IV

3 Bufotes viridis European Green Toad LC IV

4 Microhyla ornata Ant Frog LC IV

5 Euphlyctis cyanophlyctis Skittering Frog LC IV

6 Euphlyctis hexadactylus Indian Green Frog LC IV

7 Hoplobatrachus tigerinus Indian Bullfrog LC IV

8 Fejevarya limnocheris Asian Grass Frog LC IV

9 Sphaerotheca breviceps Indian Burrowing Frog LC IV *Status assigned by the International Union for Conservation of Nature and Natural Resources, where –CR – Critically Endangered and EN - Endangered.

**Schedules I to VI: Indian Wildlife (Protection) Act, 1972.

Sources: Vyas, R. (2008) Review of the current diversity and richness of amphibians of Gujarat, India. Indian Forester Vol 134 (10) pp 1381-1392.; The IUCN Red List of Threatened Species. Version 2019-3.; Schedules I to VI: Indian Wildlife (Protection) Act, 1972.

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Appendix G Fishes of the Study Area

S. No. Scientific Name Common Name IUCN WPA Status* Schedule** 1 Pethia ticto Ticto Barb LC -

2 Labeo boggut Boggut Labeo LC -

3 Labeo calbasu Orange-fin Labeo LC -

4 Systomus sarana Olive Barb LC -

5 Osteobrama cotio - DD -

6 Notopterus notopterus Bronze Featherback LC -

7 Chanda nama Elongate Glass Perchlet LC -

8 Mystus gulio Long Whiskers Catfish LC - Sources: Harinder Singh Banyal, Sanjeev Kumar and R. H. Raina, (2019). Rec. zool. Surv. India: Vol. 119(3)/ 282-288; IUCN (2019). The IUCN Red List of Threatened Species. Version 2019-2; Schedules I to VI: Indian Wildlife (Protection) Act, 1972.

References Barron-Gafford, G. A. et al. “The Photovoltaic Heat Island Effect: Larger solar power plants increase local temperatures.” Sci. Rep. 6, 35070; doi: 10.1038/srep35070 (2016) BirdLife International (2020) Important Bird Areas factsheet: Rann of Kutch Wildlife Sanctuary. Downloaded from http://www.birdlife.org on 21/01/2020. URL: http://datazone.birdlife.org/site/factsheet/rann-of-kutch-wildlife- sanctuary-iba-pakistan BirdLife International (2020) Important Bird Areas factsheet: Wild Ass Wildlife Sanctuary. Downloaded from http://www.birdlife.org on 21/01/2020. URL: http://datazone.birdlife.org/site/factsheet/18144 Birdlife International (2020). Birdlife Data Zone: Central Asia/South Asia. Downloaded from http://datazone.birdlife.org/ on 21/01/2020 BirdLife International 2019. Vanellus gregarius (amended version of 2018 assessment)

CABI Invasive Species Compendium. URL: https://www.cabi.org/ISC

Champion, H. G., Seth, S. K. (1968) Revised Survey of the Forest Types of India. Manager of Publications, Government of India, Delhi. Gábor Horváth, György Kriska, Péter Malik and Bruce Robertson (2009). Polarized light pollution: a new kind of ecological photo-pollution. Front Ecol Environ 2009; 7(6): 317–325 Global Invasive Species Database. URL: http://www.iucngisd.org/gisd/ Harinder Singh Banyal, Sanjeev Kumar and R. H. Raina, (2019). Rec. zool. Surv. India: Vol. 119(3)/ 282-288

Invasive Alien Species of India, National Biodiversity Authority, Ministry of Environment, Forests and Climate Change, Government of India. Downloaded from http://nbaindia.org/

Invasive Species Specialist Group, IUCN. URL: http://www.issg.org/

Kaczensky, P., Lkhagvasuren, B., Pereladova, O., Hemami, M. & Bouskila, A. 2016. Equus hemionus ssp. khur. The IUCN Red List of Threatened Species 2016: e.T7963A3144616.Downloaded on 21 January 2020. URL: https://www.iucnredlist.org/species/7963/3144616#population Nicolas Barth, Benjamin W. Figgis, Ahmed Ennaoui, Said Ahzi, "Field-scale Computational Fluid Dynamics applied to wind velocity profiles of photovoltaic plant: Case of the QEERI solar test facility Doha Qatar", Renewable and Sustainable Energy Conference (IRSEC) 2016 International, pp. 613-618, 2016; Patel, H., Vyas, R. (2019) Reptiles of Gujarat, India: Updated Checklist, Distribution, and Conservation Status. Herpetology Notes, Vol. 12 pp. 765-777 R. (2008) Review of the current diversity and richness of amphibians of Gujarat, India. Indian Forester Vol 134 (10) pp 1381-1392 R. Grimmett, C. Inskipp & T. Inskipp (2011). Birds of the Indian Subcontinent. Oxford University Press, pp 1-528

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ESIA of 200 MW Solar Power Project

Ramsar Sites Information Service (2002). Runn of Kutch. Downloaded from https://rsis.ramsar.org/ris/ on 21/01/2020. URL: https://rsis.ramsar.org/ris/1285 Schedules I to VI: Indian Wildlife (Protection) Act, 1972. Taylor, R., Conway, J., Gabb, O. and Gillespie, J. (2019). Potential ecological impacts of ground-mounted photovoltaic solar panels: An introduction and literature review. Report for BSG Ecology. The IUCN Red List of Threatened Species 2019: e.T22694053A155545788. Downloaded on 21 January 2020. URL: https://www.iucnredlist.org/species/22694053/155545788 The IUCN Red List of Threatened Species. Version 2019-2. URL: https://www.iucnredlist.org/ Vivek Menon (2014), Indian Mammals: A Field Guide. Hachette Book Publishing India Pvt. Ltd., Gurgaon, India, pp 1-522

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Appendix H Performance with respect to Equator Principles IV

Electro Solaire Private Limited (hereinafter referred as ‘Client’/ESPL’) has been selected for developing 200 MW solar power project after bidding by Gujarat Urja Vikas Nigam Limited (GUVNL) for 700 MW grid connected Solar Photovoltaic Power Projects to be set up at Radhanesda Solar Park in Radhanesda village, Vav Taluka, Banaskantha district in the state of Gujarat (Phase III – R). The 200 MW solar power plant is proposed to be set up on 380 hectares (~938.06 acres) of land (two [02] land parcels of 190 hectares each) that has been leased by GUVNL for a period of 25 years to ESPL.

AECOM India Private Limited (hereinafter referred to as ‘AECOM’) has been appointed by ESPL to undertake an Environment and Social Impact Assessment (ESIA) study to evaluate environment and social risks and impacts associated with the Project as per requirements of International Finance Corporation (IFC) Sustainability Framework (Policy and Performance Standards on Environmental and Social Sustainability) 2012 and the associated World Bank Group Environmental Health and Safety Guidelines, ADB’s 2009 Safeguard Policy Statement (SPS) and FMO's Social Sustainability Policy.

Additionally, AECOM has undertaken the gap analysis of the project against the Equator Principles IV (2020). For the performance assessment, the following approach and methodology has been undertaken:

 Review of project site and corporate related documents such as (but not limited to): ─ Latest corporate level organizational structure and site level organizational structure; ─ Existing environment and social management system established at corporate level and associated documents; ─ Existing Environment, Social and Health and Safety and Human Resources related policies;

─ Stakeholder engagement plan/ procedure established for the company; ─ Grievance redress mechanism plan/ procedure established for the company– formats for receiving, assigning and redressing grievances.  Site reconnaissance survey to understand site specific environment and social aspects of the project;  Regulatory review was undertaken to understand the applicable, local and national legislation and regulatory frameworks;

Compliance Assessment against Equator Principles IV: On the basis of on-site observations and review of the documents received from the Client, following observations were made for the project against the Equator Principles as presented in the Table 1 below:

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Table 8: Gap Assessment for the Project against EP IV:

Equator Principle Specific Requirements Observations Gaps/ Remarks

Principle 1: Review and The project will be categorised based on the magnitude of potential For the compliance of the Principle 1, ESPL has appointed No gaps identified. Categorisation environmental and social risks and impacts, including those related AECOM to review and categorization of the project as part of to Human Rights, Climate Change and Biodiversity. Such the Environmental and Social Impact Assessment (ESIA) as categorisation is based on the International Finance Corporation’s per requirements set in International Finance Corporation (IFC) environmental and social categorization process. The (IFC) Sustainability Framework (Policy and Performance categories are: Standards on Environmental and Social Sustainability) 2012 and the associated World Bank Group Environmental Health  Category A: Projects with significant adverse E&S risks and/ or and Safety Guidelines, ADB’s 2009 Safeguard Policy impacts that are diverse, irreversible or unprecedented; Statement (SPS), FMO's Social Sustainability Policy and  Category B: Projects with few, site-specific largely reversible E&S risks and/ or impacts. (Notes: There can be a range in the Equator Principles IV (2020). scale of potential environmental and social risks and impacts within Projects classified as Category B. In general terms, Based on the Environment and Social (E & S) Screening and higher risk Category B Projects will be treated similarly to Scoping Study and the current ESIA study conducted and as Category A Projects, and lower risk Category B Projects could be treated in a lighter regime); and per the EP 1 requirements, the proposed project can be  Category C: Projects with minimal or no adverse E&S risks categorized as Category B which specifies that the risks and and/ or impacts. impacts from the project are limited in adversity, reversible and mitigated through a proper Environmental and Social Management Plan (ESMP) and its mitigation measures. Principle 2: Environmental The EPFI will require the client to conduct an appropriate To comply with Principle 2 of the EPFI 4, detailed ESIA study No gaps identified. and Social Assessment Assessment process to address, to the EPFI’s satisfaction, the has been undertaken by the Project proponent through third relevant environmental and social risks and scale of impacts of the party consultant i.e. M/s AECOM India Private Limited. The proposed Project (which may include the illustrative list of issues ESIA documentation includes assessment of baseline found in Exhibit II). The Assessment Documentation should propose environment, ecology and social conditions, stakeholder measures to minimise, mitigate, and where residual impacts remain, engagement and consultation process, analysis of to compensate/offset/remedy for risks and impacts to Workers, alternatives, impact assessment including cumulative impact Affected Communities, and the environment, in a manner relevant assessment, Environment and Social Management and and appropriate to the nature and scale of the proposed project. Monitoring Plan and the ESIA documentation observed to be aligned with Exhibit II: Illustrative list of Potential Environmental and Social Issues to be addressed in the Environmental and Social Assessment Documentation. The Assessment Documentation will be an adequate, accurate and Based on review of the ESIA documentation, it was No gaps identified. objective evaluation and presentation of the environmental and understood that the impact evaluation criteria have been social risks and impacts, whether prepared by the client, consultants appraised considering the spread, duration, intensity and

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Equator Principle Specific Requirements Observations Gaps/ Remarks

or external experts. For Category A and, as appropriate, Category B nature of impacts. Further, each appraisal criterion is classified Projects, the Assessment Documentation includes an on the level or type of its spread, duration, intensity or nature. Environmental and Social Impact Assessment (ESIA). One or more Based on these two-level criterion, significance of each specialised studies may also need to be undertaken. impacts has been defined as Low, Medium and High.

The client is expected to include assessments of potential adverse Impacts area identified based on the project stage such as Human Rights impacts and climate change risks as part of the ESIA pre-construction, construction, operation and decommissioning or other Assessment, with these included in the Assessment stage and appropriate mitigation measures are provided for Documentation. The client should refer to the UNGPs3 when each impact. assessing Human Rights risks and impacts, and the Climate Change Risk Assessment should be aligned with Climate Physical The ESIA documentation includes the assessment related to Risk and Climate Transition Risk categories of the TCFD. Human Rights Impacts and Climate Change Risk due to the Project activities.

A specialised study such as Critical Habitat Assessment also conducted and part of the ESIA documentation.

Based on E & S screening and scoping study and the current ESIA study, the project has been designated as a Category B Project as per the IFC Performance Standards. Principle 3: Applicable The Assessment Process should at least address compliance of the The current ESIA study has provided a statement of No gaps identified Environmental and Social project with relevant host country laws, regulations and permits compliance of the project via-a-vis the applicable regulatory Standards relating to E&S issues. permits, licencing and legislations of the host country India being a Non-Designated Country, the Assessment process pertaining to E&S. The key EHS aspects that have been evaluates compliance with the applicable IFC Performance covered as part of the regulatory permitting and licencing Standards on Environmental and Social Sustainability (Performance include: - Standards).  Environmental protection (The Environment (protection) Act, 1936)

 Prevention and control of water pollution (The water (prevention and control of pollution) Act, 1974)  Prevention and control of air pollution (The Air (prevention and control of pollution) Act, 1981  Noise emissions (The Noise (Regulation and Control) Rules), 2000  Hazardous wastes management (Hazardous and other wastes (Management and Transboundary Movement) Rules, 2016)

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Equator Principle Specific Requirements Observations Gaps/ Remarks  Construction and Demolition Waste (Construction and Demolition Waste Management Rules, 2016)  Storage of Petroleum products (The Petroleum Act, 1934 as amended in August 1976)  Surface Transportation (The Motor Vehicles Act, 1988 as amended in 2000)  Forest Protection (The Indian Forest Act, 1927)  Wildlife conservation (The Wildlife (Protection) Act, 1972)  Forest Conservation (The Forest (Conservation) Act, 1980)  Labour (The Factories Act, 1948)  Contract workers (The contract labour (Regulation and Abolition) Act, 1970  Child labour (The child labour (Prohibition and Regulation) Act, 1986)  Bonded labour (Bonded labour (Abolition) Act, 1976)  Migrant workmen (The inter-state migrant workmen (Regulation of Employment and conditions of service) Act, 1979) Apart from the above-mentioned regulations, the list of enforcement agencies relevant to the project for management of EHS and social issues has also been shared. Principle 4: Environmental For all Category A and Category B Projects, ESMS will be Following documents were provided during the gap analysis ESPL has to implement the framework E&S and Social Management developed/ maintained for the project. Furthermore, an ESMP will assessment: management plan provided in the ESIA study System and Equator be prepared to address the issues raised in the Assessment as indicated in Table 2 and implement it Principles Action Plan Process. Where the applicable standards are not met, an Equator  Environment Policy Statement published on February 02, before construction work commence, 2018; Principles Action Plan (EPAP) will be developed outlining the gaps including by developing/completing  Environmental and Social Management Framework on and commitments to meet the EPFI requirements. December 21, 2018; and outstanding site-specific Management plans.  Group Health and Safety Policy on April 30, 2015 ESPL to ensure that the EPC Contractor complies with the applicable requirements. Review of the above documents indicated that no project specific ESMS is in place. The requirement has been provided as an action to be taken by ESPL in the ESAP provided in Table 2. Principle 5: Stakeholder For all Category A and Category B Projects, an effective  At the time of the site visit, project-specific construction The periodic stakeholder consultations activities were yet to commence. Engagement Stakeholder Engagement, as an ongoing process in a structured undertaken with the various key stakeholder  The key stakeholder groups that the project was catering and culturally appropriate manner, with the Affected Communities, to include the local communities, elected members of the groups needs to be documented by ESPL

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Workers and other Stakeholders needs to be implemented. For PRIs, members of the local communities engaged in and corresponding follow-up measures taken animal grazing etc. No formal identification, mapping and Projects with significant adverse impacts, Informed Consultation and documentation of the stakeholder engagements were if any should be updated Participation (ICP) needs to be undertaken. For Projects that affect being maintained. Indigenous Peoples, Free, Prior and Informed Consent (FPIC) as  The stakeholder engagement process was being per paragraphs 13-17 of IFC Performance Standard 7 needs to be undertaken in an informal manner without any documentation. However, the kay stakeholder groups, followed. their influence on and potential impact of the project on them, key mechanisms for the Project to engage with them etc. has been highlighted in a dedicated section of the current ESIA Report. The proponent is expected to follow the same throughout the project lifecycle.  It was reported that prior to the commencement of any project-specific construction activities, the key affected communities – local communities engaged in grazing of livestock, access road users, representatives of the PRI will be consulted and engaged with by the project proponent as well as the EPC contractor wherein a generic overview of the projects – its purpose, capacity etc. with potential engagement opportunities will be provided. During the consultations, efforts will be made to identify the concerns of the stakeholder groups about the project – its potential impacts on the surrounding areas/ villages so that the same can be factored in the project execution planning.  With respect to Informed Consultation and Participation (ICP), the same is not necessary as a tool for community consultations as no major adverse implications of the project are envisaged. Similarly, concerning Free, Prior and Informed Consent (FPIC), the same is not necessary for the project to obtain rightful consent of IPs as there are no impacts envisaged from the project on Indigenous Peoples. Moreover, the region – village and district wherein the project is located does not have any significant presence of IPs/ Tribal people.

Principle 6: Grievance For all Category A and, as appropriate, Category B Projects, an  As indicated earlier, the Project has been categorised as No gaps or remarks a Category B Project for which an effective grievance Mechanism effective grievance mechanism designed for use by Affected mechanism needs to be designed for use by Affected Communities and Workers facilitating receipt and resolution of Communities and Workers. concerns and grievances about the Project’s E&S performance  At the time of the site visit, project-specific construction need to be implemented. activities were yet to commence. External grievances were reported to be addressed in an informal manner by the site representatives of Engie.  It was reported by the proponent that a structured and documented grievance redressal mechanism will be

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Equator Principle Specific Requirements Observations Gaps/ Remarks implemented once the construction activities commence. It was further stated that the EPC contractor will be responsible for managing external grievances, however, the overall responsibility of grievance management will be with the proponent.  Dedicated forms for receiving, recording and acknowledging grievances will be used.  Similarly, an SOP clearly highlighting the roles and responsibilities of the various personnel responsible for grievance redressal and the escalation matrix will be developed.  It was also reported by the site representative of ESPL that prior to the commencement of project-specific construction activities, the grievance mechanism will be advertised in the neighbouring villages so that the local communities can avail the system for redressing their grievances.  With respect to internal stakeholders such as contractual workers, vendors and suppliers, they will be sensitized regarding the mechanism at the time of induction.  All the sensitization material – posters, reading materials as well as forms, grievance register, and acknowledgement receipts will be in the local language (Gujarati) as well as Hindi. While the materials in the local language (Gujarati) will cater to the local workforce/ workforce sourced from the neighbouring villages, the same in Hindi can be used by the migrant workers. Principle 7: Independent For all Category A and, as appropriate, Category B Projects, an ESPL has appointed AECOM, a third-party E&S consultant to No Gaps observed. Review Independent E&S Consultant, will carry out an Independent Review undertake the ESIA for the project as per the IFC Performance of the Assessment process including the ESMPs, the ESMS, and Standards requirements and to develop the ESMP for the Stakeholder Engagement process documentation in order to construction and operation phases. AECOM has also assist the EPFI’s due diligence and determination of Equator performed a gap analysis of the E&S documentation set Principles compliance. (ESIA, ESMP, Stakeholder Management process etc.) against the Equator Principles IV, as reflected in this document. Principle 8: Covenants The client will covenant in the financing documentation to comply ESPL to covenant in the financing documentation to comply ESPL to comply. with all relevant host country environmental and social laws, with all relevant host country environmental and social laws, regulations and permits in all material respects. regulations and permits in all material respects with the ESMP For all Category A and Category B Projects, Equator Principles and the ESAP presented in Table 2. requires that the covenants cover the commitment of the client to comply with the ESMPs, EPAP during construction and operation

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Equator Principle Specific Requirements Observations Gaps/ Remarks

phase and report on this compliance to the Lenders in an agreed format. Principle 9: Independent For all Category A and, as appropriate, Category B Projects, in ESPL has appointed AECOM to undertake ESIA for the Conduct an independent audit of E&S Monitoring and Reporting order to assess Project compliance with the Equator Principles after project as per the IFC Performance Standards requirements practices and compliance to the ESAP and Financial Close and over the life of the loan, the EPFI will require and World Bank EHS Guidelines. ESIA / CHA requirements. independent monitoring and reporting. Monitoring and reporting should be provided by an Independent Environmental and Social Since there is no construction works started, no independent Consultant; alternatively, the EPFI will require that the client retain consultant has been appointed. qualified and experienced external experts to verify its monitoring information. Principle 10: Reporting  The client will ensure that, at a minimum, a summary of the ESIA is underway. Once ESIA completed, summary of the ESIA ESIA is accessible and available online and that it includes a and Transparency shall be uploaded online; summary of Human Rights and climate change risks and impacts when relevant;  The client will report publicly, on an annual basis, GHG As the 200 MW project is a renewable energy, therefore it is emission levels during the operational phase for Projects not envisaged that project will reach the eligible threshold (100 emitting over 100,000 tonnes of CO equivalent annually; and 2 kT CO2 eq/year) for public reporting of GHG emissions during

the operational phase. Thus, the requirement is not applicable  The EPFI will encourage the client to share commercially non- sensitive Project-specific biodiversity data with the Global to the project. Biodiversity Information Facility (GBIF) and relevant national During ESIA, it was noted that no ecological sensitive area and global data repositories. identified within the Project Site area. Hence this requirement is not applicable.

Environment and Social Action Plan (ESAP): Based on the above assessment, an Environment and Social Action Plan (ESAP) is presented in the Table 2 below. The ESAP delineates the list of actions required to be undertaken by the management to ensure closure of the gaps as identified in the compliance assessment. The Environment and Social Action Plan is provided below with timelines, responsibilities and specific action items.

Table 9: Environment and Social Action Plan (ESAP)

Action Description Completion Indicator Timeline Responsibility Environment and Social ESPL to implement the framework ESMP provided in the ESIA study and  Site-specific ESMP for Prior to construction activities ESPL Management Plan (ESMP) implement it before construction work commences, including by Construction and Operation developing/completing outstanding site-specific Management plans. Phase ESPL to ensure that EPC contractor complies with the applicable  Monitoring Reports requirements.

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

Stakeholder Engagement ESPL to document the periodic stakeholder consultations undertaken with Records of stakeholder consultations Throughout the project lifecycle ESPL the various key stakeholder groups and corresponding follow-up measures taken if any should be updated. Covenants ESPL to covenant in the financing documentation to comply with all Finance Documentation Prior to signing ESPL relevant host country environmental and social laws, regulations and permits in all material respects also with the ESMP and ESAP and report to the lenders at a periodic basis. Independent Monitoring and ESPL shall appoint independent consultant on behalf of lenders for audit Monitoring reports During construction phase (in ESPL Reporting of E&S practices and compliance to the ESAP and ESIA / CHA summer time) requirements. Reporting and Transparency ESPL to upload the summary of ESIA online. Online ESIA summary Prior to financial closure ESPL

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

Appendix I Environment and Social Action Plan (ESAP) prepared for ADB:

The Environment and Social Action Plan (ESAP) prepared for ADB is provided below with timelines, responsibilities and specific action items:

Action Description Completion Indicator Timeline Responsibility Minimization of potential 1. Engage the services of an independent and qualified expert to conduct autumn 1. Field survey reports 1. Tentatively scheduled for late ESPL and spring surveys (for a minimum of 2 weeks per survey and including lands October / early November impacts to avifauna 2. Habitat immediately adjacent to the project site) to ascertain impacts, if any, on Management Plan, if 2020 and late February / early avifauna (particularly noting the potential usage of the site as a staging area by required March 2021 (depending on the sociable lapwing). The survey should be conducted at the appropriate times 3. Evidence of the migration activity). to observe the in-migration and out-migration of the species in the area. discussions with 2. The development of the plan 2. Should the surveys indicate that the site and its adjacent areas are used as a GPCL including, but should be conducted after the staging site for the sociable lapwing, develop and implement measures to not limited to, observation of the target mitigate the impacts of the project on the species (satisfactory to ADB). This correspondence and species during the survey. will most likely include supporting and enabling the establishment of managed meeting minutes 3. Prior to construction habitats outside the site. 3. Work with GPCL, on a best effort basis, to encourage the adoption of the measures recommended in the CHA and ESIA to minimize electrocution and collision risks to avifauna from the transmission lines. ESMP implementation Based on the ESMPs presented in the ESIA and in collaboration with the EPC, 1. Site-specific 1. Prior to the commencement of ESPL and EPC develop and implement site-specific construction and operation phase ESMPs construction phase construction (satisfactory to ADB). The ESMPs should include the management of impacts ESMP 2. Prior to commencement of linked to (but not limited to): 2. Site-specific operation operations phase ESMP 3. Continuous throughout 1. Environment covering air, water, traffic, waste, etc; 3. Monitoring Reports construction and operations 2. Health & Safety management including working conditions (especially during summer months), incident management, emergency response, maintenance of records (e.g. training, drills, field audits), training programs, first aid facilities and personnel; 3. Sub-contractor management and compliance; 4. Labour and working conditions including management of labour camps (in accordance with IFC Guidance Note on Workers Accommodation: processes and standards); 5. Stakeholder Engagement and Grievance Management including systems for documenting and resolving stakeholder concerns and grievances; and 6. Influx management and community security and safety aspects.

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

Increase site-based E&S Employ a qualified and dedicated environmental and social specialist to manage CV of proposed E&S Prior to signing ESPL EHS aspects of the project (including contractors) during construction and specialist along with resources operation. appointment letter and reporting lines E&S Audit during Conduct an independent audit of E&S practices and compliance to the ESAP and Audit report During construction phase (in ESPL ESIA / CHA requirements summer time) construction Gender Action Plan Work towards implementing the Gender actions agreed between ESPL and Monitoring report Continuous throughout ESPL and EPC

ADB construction and operations

Electro Solaire Private Limited AECOM

ESIA of 200 MW Solar Power Project

Electro Solaire Private Limited AECOM