Rewa Ultra Mega Solar Limited 15 October 2020 Project No.: 0528741 www.erm.com The business of sustainability Document details The report summarizes the results of Environmental and Social Impact Assessment Study for Neemuch Solar Park. Document title Consultancy services for ESIA for three Solar Parks Document subtitle Final ESIA Report Project No. Date Version Author Client Name Document history ERM approval to issue Version Revision Author Reviewed by Name Date Comments Draft 1.0 Anupreet Ajay Pillai Neena Singh 27.06.2020 Anand Aniket Saumya Jalgaonkar Srivastava Dr. Arun Rashmi Dutta Venkataraman Dr. Neetu Dr. N. Nigam Karunakaran Tushar Sumati Bhatia Agarwal Draft Final 2.0 Anupreet Dr. Arun Neena Singh 27.09.2020 Addressing Anand Venkataraman comments of IFC, Saumya Dr. Neetu WB and RUMSL Srivastava Nigam on draft ESIA Sumati Bhatia report Final 3.0 Anupreet Dr. Arun Neena Singh 15.10.2020 Addressing Anand Venkataraman comments of IFC Saumya Dr. Neetu and WB on draft Srivastava Nigam final ESIA report Sumati Bhatia www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Signature Page 15 October 2020 Solar Parks, namely, Agar Solar Park (550 MW), Shajapur Solar Park (450 MW) and Neemuch Solar Park (500 MW), including internal evacuation infrastructure and associated transmission lines, of three parks of aggregate capacity of 1500 MW in the Solar Park Final Report Aniket Jalgaonkar Dr. Neetu Nigam Principal Consultant Principal Consultant Sumati Bhatia Dr. Arun Venkataraman Technical Director Technical Director Neena Singh Managing Partner ERM India Private Limited Building 10A 4th Floor, DLF Cyber City Gurgaon, NCR 122002 Tel: 91 124 417 0300 Fax: 91 124 417 0301 © Copyright 2020 All rights reserved. No part of this work may be reproduced or transmitted in any form, or by any means, without the prior written permission of ERM www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS CONTENTS Final ESIA Report CONTENTS EXECUTIVE SUMMARY ......................................................................................................................... I 1. INTRODUCTION .......................................................................................................................... 1 1.1 PROJECT BACKGROUND ......................................................................................................... 1 1.2 OBJECTIVE AND SCOPE OF THE ASSESSMENT ................................................................... 2 1.2.1 Applicable Framework .................................................................................................. 3 1.3 APPROACH AND METHODOLOGY ........................................................................................... 4 1.3.1 Kick-off Meeting ............................................................................................................ 4 1.3.2 Desk-based Review ...................................................................................................... 4 1.3.3 Inception Report............................................................................................................ 4 1.3.4 Site Visit and Baseline Data Collection ......................................................................... 4 1.3.5 Stakeholders Consultation ............................................................................................ 5 1.3.6 Impact Assessment....................................................................................................... 5 1.3.7 Environmental and Social Management Plan ............................................................... 5 1.4 LIMITATIONS ............................................................................................................................... 6 1.4.1 Uses of the Report ........................................................................................................ 7 1.5 STRUCTURE OF THE REPORT ................................................................................................. 7 2. PROJECT DESCRIPTION ........................................................................................................... 9 2.1 PROJECT LOCATION ............................................................................................................... 10 2.2 OVERVIEW OF THE PROJECT ................................................................................................ 13 2.2.1 Project Components ................................................................................................... 14 2.2.2 Associated Facilities ................................................................................................... 14 2.3 SUMMARY OF PROJECT ACTIVITIES .................................................................................... 16 2.3.1 Planning and Pre-Construction Phase ........................................................................ 16 2.3.2 Construction Phase..................................................................................................... 16 2.3.3 Operation and Maintenance ........................................................................................ 17 2.4 RESOURCE REQUIREMENT .................................................................................................... 17 2.4.1 Raw Materials ............................................................................................................. 17 2.4.2 Water Requirement ..................................................................................................... 17 2.4.3 Power Requirement .................................................................................................... 18 2.4.4 Fire Safety and Security.............................................................................................. 18 2.4.5 Manpower Requirement.............................................................................................. 18 2.5 LAND REQUIREMENT AND ALLOTMENT PROCESS ........................................................... 19 2.5.1 Land Details ................................................................................................................ 19 2.5.2 Land Procurement Process ........................................................................................ 21 2.6 POLLUTION STREAM ............................................................................................................... 23 2.6.1 Solid Waste Generation .............................................................................................. 23 2.6.2 Air Emissions .............................................................................................................. 25 2.6.3 Wastewater Generation .............................................................................................. 26 2.6.4 Noise Emission ........................................................................................................... 26 3. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ...................................................... 27 3.1 APPLICABLE REFERENCE FRAMEWORK ............................................................................ 27 3.1.1 Environmental and Social Management Framework of Ministry of New and Renewable Energy ........................................................................................................................ 45 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS CONTENTS Final ESIA Report 3.2 APPLICABLE ENVIRONMENTAL STANDARDS ..................................................................... 45 3.2.1 National Level Standards ............................................................................................ 45 3.2.2 IFC/ WB Standards ..................................................................................................... 45 4. ENVIRONMENTAL AND SOCIAL BASELINE .......................................................................... 46 4.1 STUDY AREA............................................................................................................................. 46 4.2 PHYSICAL ENVIRONMENT ...................................................................................................... 47 4.2.1 Site Visit ...................................................................................................................... 47 4.2.2 Land Use and Land Cover .......................................................................................... 50 4.2.3 Topography and Slope................................................................................................ 50 4.2.4 Hydrology .................................................................................................................... 54 4.2.5 Geology and Geomorphology ..................................................................................... 57 4.2.6 Natural Hazards .......................................................................................................... 59 4.2.7 Climate and Meteorology ............................................................................................ 63 4.2.8 Ambient Air Quality ..................................................................................................... 64 4.2.9 Ambient Noise Quality ................................................................................................ 68 4.2.10 Water Availability and Quality ..................................................................................... 68 4.2.11 Soil Quality .................................................................................................................. 86 4.2.12 Traffic Monitoring ........................................................................................................ 88 4.3 BIOLOGICAL ENVIRONMENT- FLORA AND FAUNA ............................................................ 89 4.3.1 Objectives ................................................................................................................... 89 4.3.2 Approach and Methodology ........................................................................................ 90 4.3.3 Habitat Mapping .......................................................................................................... 92 4.3.4 Floral Analysis............................................................................................................. 94 4.3.5 Faunal Analysis........................................................................................................... 94 4.3.6 Proximity to areas of ecological significance ............................................................... 99 4.3.7 Migratory Pathways .................................................................................................... 99 4.3.8 Applicability of natural, modified and critical habitat .................................................. 100 4.4 SOCIAL ENVIRONMENT ......................................................................................................... 102 4.4.1 Socio Economic Setting ............................................................................................ 102 4.4.2 Study Area ................................................................................................................ 105 4.4.3 Demographic Profile of Study Area ........................................................................... 108 4.4.4 Social Stratification ................................................................................................... 108 4.4.5 Literacy and Education ............................................................................................. 109 4.4.6 Land ownership and use ........................................................................................... 110 4.4.7 Occupational Profile .................................................................................................. 115 4.4.8 Physical Infrastructure .............................................................................................. 121 4.4.9 Social Infrastructure .................................................................................................. 122 4.4.10 Energy Use ............................................................................................................... 123 4.4.11 Gender: Role in Society ............................................................................................ 123 5. STAKEHOLDER IDENTIFICATION, INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION ...................................................................................................................... 126 5.1 STAKEHOLDER IDENTIFICATION AND CATEGORIZATION .............................................. 126 5.2 STAKEHOLDER ANALYSIS ................................................................................................... 127 6. ENVIRONMENTAL AND SOCIAL IMPACTS .......................................................................... 138 6.1 IMPACT ASSESSMENT METHODOLOGY............................................................................. 138 6.1.1 Screening and Scoping ............................................................................................. 138 6.1.2 Impact Matrix ............................................................................................................ 142 6.1.3 Prediction of Impacts ................................................................................................ 145 6.1.4 Evaluation of Impacts- Impact Significance .............................................................. 145 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS CONTENTS Final ESIA Report 6.1.5 Identification of Mitigation and Enhancement Measures ........................................... 148 6.1.6 Preparation of Environmental and Social Management Plan .................................... 149 6.2 IMPACTS ON PHYSICAL ENVIRONMENT ............................................................................ 149 6.2.1 Assessment Criteria .................................................................................................. 149 6.2.2 Planning and Construction Phase ............................................................................. 156 6.2.3 Operation Phase ....................................................................................................... 171 6.2.4 Photovoltaic Heat Island Effect (PVHI) ..................................................................... 178 6.2.5 Natural hazards- Flood Likelihood Assessment ........................................................ 179 6.3 IMPACTS ON BIOLOGICAL ENVIRONMENT ........................................................................ 182 6.3.1 Assessment Criteria .................................................................................................. 183 6.3.2 Habitat Modification and Loss ................................................................................... 186 6.3.3 Impacts due to Construction Activities ...................................................................... 188 6.3.4 Ecosystem Services.................................................................................................. 190 6.3.5 Collision and electrocution risk.................................................................................. 193 6.4 IMPACTS ON SOCIAL ENVIRONMENT ................................................................................. 195 6.4.1 Avoidance and optimisation of the Project footprint .................................................. 196 6.4.2 Potential impacts from Project activities on stakeholder categories .......................... 197 6.4.3 Assessing the Significance of Impacts ...................................................................... 209 6.4.4 Planning Phase Impacts ........................................................................................... 209 6.4.5 Construction Phase Impacts ..................................................................................... 214 6.4.6 Operations Phase Impacts ........................................................................................ 219 6.4.7 Impact on Indigenous Communities/ Vulnerable Groups .......................................... 221 6.4.8 Impact on Women ..................................................................................................... 223 6.5 SUMMARY OF PRE AND POST MITIGATION IMPACT SIGNIFICANCE ............................. 226 7. ANALYSIS OF ALTERNATIVES ............................................................................................. 228 7.1.1 Project vs No Project scenario .................................................................................. 228 7.1.2 Alternate Source for Power Generation .................................................................... 228 7.1.3 Location for Project Site ............................................................................................ 230 8. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN ..................................................... 233 8.1 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN ..................................................... 233 8.2 INSTITUTIONAL STRUCTURE FOR IMPLEMENTATION ..................................................... 259 8.2.1 Project Implementation- SPPD and SPD .................................................................. 259 8.2.2 Implementation of ESMP .......................................................................................... 260 8.2.3 Monitoring and Reporting.......................................................................................... 263 8.3 ESMP BUDGET ........................................................................................................................ 267 8.4 TRAINING AND CAPACITY BUILDING .................................................................................. 269 9. GRIEVANCE REDRESSAL MECHANISM .............................................................................. 270 9.1 OBJECTIVES OF THE GRIEVANCE REDRESSAL MECHANISM ........................................ 270 9.2 COMPOSITION OF THE GRC ................................................................................................. 270 9.2.1 Functioning of the GRC for Grievance Redress ........................................................ 271 9.3 EXTERNAL GRIEVANCE REDRESSAL MECHANISM OF RUMSL ..................................... 271 9.3.1 Grievance Receipt and Recording ............................................................................ 271 9.3.2 Grievance Resolution and Communication ............................................................... 272 9.4 INTERNAL GRIEVANCE REDRESSAL MECHANISM ........................................................... 272 9.4.1 Grievance Receipt and Recording ............................................................................ 273 9.4.2 Grievance Resolution and Closure ........................................................................... 274 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS CONTENTS Final ESIA Report 9.5 MONITORING AND EVALUATION ......................................................................................... 274 9.6 BUDGETING ............................................................................................................................ 274 10. CONCLUSION .......................................................................................................................... 275 11. REFERENCES ......................................................................................................................... 276 APPENDIX APPENDIX A PHOTO DOCUMENTATION APPENDIX B DETAILS OF CONSULTATIONS UNDERTAKEN DURING NEEMUCH ESIA PREPARATION APPENDIX C NOTE ON LAND REQUIREMENT AND PROCUREMENT PROCESS APPENDIX D ENVIRONMENTAL MONITORING RESULTS APPENDIX E FLOOD LIKELIHOOD ASSESSMENT APPENDIX F ESMP- MANAGEMENT PLANS List of Tables Table 0.1 Brief Description of Project .............................................................................................. I Table 0.2 Neemuch: Village Wise Land Allotment details .............................................................. II Table 0.3 Summary of Current Baseline Status ............................................................................ III Table 1.1 Key sources of information reviewed for the desk-based study ..................................... 4 Table 1.2 Structure of the report ..................................................................................................... 7 Table 2.1 Brief Description of Project ............................................................................................. 9 Table 2.2 Neemuch- Village Wise Land Allotment details ............................................................ 20 Table 2.3 Ownership details of Private & Patta land identified for the project ............................. 20 Table 2.4 Waste generated, source of waste and method of disposal to be adopted for the Project ........................................................................................................................ 24 Table 2.5 Waste Management during Operation Phase .............................................................. 25 Table 3.1 Applicability of Key Legislations in India and Reference Framework in the different phases of life cycle of the Project ................................................................................. 28 Table 3.2 International Standards- IFC Performance Standards and WB Environmental and Social Standards ........................................................................................................... 39 Table 4.1 Primary Baseline Data Collection ................................................................................. 47 Table 4.2 Secondary Baseline Data Collection ............................................................................ 48 Table 4.3 Land use/ Land cover details of 5 km study area ......................................................... 50 Table 4.4 Land use/ Land cover of Project Boundary .................................................................. 50 Table 4.5 Stratigraphic succession of the Region ........................................................................ 57 Table 4.6 Wind hazard categorisation .......................................................................................... 61 Table 4.7 Beaufort scale of wind speed characterisation ............................................................. 62 Table 4.8 Summary of wind hazard categorisation ...................................................................... 62 Table 4.9 Climatological Data, Neemuch ..................................................................................... 63 Table 4.10 Rainfall Data - Neemuch .............................................................................................. 64 Table 4.11 Details of Ambient Air Monitoring Stations ................................................................... 65 Table 4.12 Details of Methods and Detection Limits for different Air Quality Parameters ............. 65 Table 4.13 Ambient Air Quality in the Study Area .......................................................................... 66 Table 4.14 Details of Noise Sampling Locations ............................................................................ 68 Table 4.15 Noise Level in the study area ....................................................................................... 68 Table 4.16 Classification of Water Risk Indicators ......................................................................... 69 Table 4.17 Parameters included to assess water availability ......................................................... 73 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS CONTENTS Final ESIA Report Table 4.18 Details of Water Sampling Locations............................................................................ 83 Table 4.19 Groundwater Quality in the Study Area ........................................................................ 83 Table 4.20 Water Quality Standards by CPCB for Best Designated Usage .................................. 85 Table 4.21 Details of Surface Water Sampling Locations .............................................................. 85 Table 4.22 Surface Water Sampling Results .................................................................................. 85 Table 4.23 Soil Sampling Locations in the Study Area .................................................................. 87 Table 4.24 Results of Soil Analysis ................................................................................................ 87 Table 4.25 Description of Traffic Count Survey Location ............................................................... 88 Table 4.26 Existing Traffic (Motorised) Volumes in Study Area ..................................................... 88 Table 4.27 Percentage Composition of Vehicles in Study Area ..................................................... 88 Table 4.28 Saturation Capacity of the access road ........................................................................ 89 Table 4.29 Water bodies surveyed near the wind farm ................................................................. 93 Table 4.30 Vegetation profile of the Project site ............................................................................. 94 Table 4.31 Flora in the study area .................................................................................................. 94 Table 4.32 Herpetofauna observed/reported in the study area ...................................................... 95 Table 4.33 Avifauna observed/reported in the study area .............................................................. 96 Table 4.34 Mammals observed/reported in the study area ............................................................ 98 Table 4.35 Madhya Pradesh Demographic Profile ....................................................................... 103 Table 4.36 Demographic Profile of Tehsils ................................................................................... 105 Table 4.37 Land Details for the Solar Park ................................................................................... 105 Table 4.38 Project Area and Surrounding Area Villages .............................................................. 106 Table 4.39 Demographic Profile of Study Area ............................................................................ 108 Table 4.40 Land Use Break Up in the Study Area ........................................................................ 111 Table 4.41 Livestock Census data for project villages ................................................................. 114 Table 4.42 Working Population in the Study Area as per Census 2011 ...................................... 117 Table 4.43 Proportion and Break-up of Working Population in the Study Area (as per Census 2001) 117 Table 4.44 Productivity and related costing of major crops in AoI ............................................... 119 Table 4.45 Availability of Schools in the Study Area .................................................................... 122 Table 5.1 Stakeholder Group Categorisation ............................................................................. 126 Table 5.2 Stakeholder Significance and Engagement Requirement .......................................... 127 Table 5.3 Stakeholder Analysis .................................................................................................. 128 Table 6.1 Screening for Impacts ................................................................................................. 139 Table 6.2 Activity Receptor Interaction Matrix ............................................................................ 143 Table 6.3 Impact Characteristic Terminology ............................................................................. 145 Table 6.4 Impact Type Definitions .............................................................................................. 146 Table 6.5 Definitions of Likelihood Designations ........................................................................ 146 Table 6.6 Criteria for Resource/ Receptor Sensitivity or Vulnerability........................................ 150 Table 6.7 Criteria for Impact Magnitude ..................................................................................... 152 Table 6.8 Status of Ground water in Project District................................................................... 173 Table 6.9 Likelihood of flood evaluation ..................................................................................... 179 Table 6.10 Identified interactions that can result in an impact to ecological resources ............... 183 Table 6.11 Habitat Impact Assessment Criteria ........................................................................... 184 Table 6.12 Species Impact Assessment Criteria .......................................................................... 185 Table 6.13 Land identified for the Project at the DPR stage ........................................................ 196 Table 6.14 Details on land identified for the project ..................................................................... 196 Table 6.15 Details of land footprint finalised for the Solar Park ................................................... 196 Table 6.16 Summary of Potential impacts from project activities ................................................. 198 Table 6.17 Demographic Profile for Neemuch Solar Park ........................................................... 221 Table 6.18 Hamlets within Badi village with High Bhil population ................................................ 221 Table 6.19 Gender disaggregated data for identified land owners (in terms of land area) .......... 223 Table 6.20 Gender disaggregated data for identified land owners (in terms of no of owners) .... 223 Table 6.21 Summary of Impacts ................................................................................................... 226 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS CONTENTS Final ESIA Report Table 7.1 Life-cycle Emissions from Power Sources ................................................................. 229 Table 7.2 Environmental Advantages and Disadvantages of Power Generation System ......... 229 Table 7.3 Green House Emissions from Different Electricity Production Chains ....................... 230 Table 7.4 Daily and Monthly GHI at Neemuch Solar Park Site .................................................. 230 Table 8.1 Planning Phase ESMP ............................................................................................... 234 Table 8.2 Construction Phase ESMP ......................................................................................... 238 Table 8.3 Operation Phase ESMP ............................................................................................. 253 Table 8.4 Responsibilities of SPPD and SPD ............................................................................ 259 Table 8.5 Monitoring Action Plan ................................................................................................ 263 Table 8.6 Environmental Monitoring Budget .............................................................................. 266 Table 8.7 Indicative Budgetary allocation for ESMP Implementation......................................... 267 Table 9.1 Format for Grievance Tracker .................................................................................... 272 Table 9.2 Format for Grievance Tracker .................................................................................... 273 List of Figures Figure 2.1 Project Site Location ..................................................................................................... 11 Figure 2.2 Photographs of Project Site and Surroundings ............................................................ 13 Figure 2.3 Power Evacuation Arrangement ................................................................................... 15 Figure 4.1 Map showing environment baseline monitoring stations in the Project AoI ................. 49 Figure 4.2 Land use and land cover map of study area of Neemuch Solar Park .......................... 51 Figure 4.3 DEM map of study area of Neemuch Solar Park ......................................................... 52 Figure 4.4 Slope map of the area .................................................................................................. 53 Figure 4.5 ..................................................................................... 55 Figure 4.6 Drainage Map of the Area ............................................................................................ 56 Figure 4.7 Geomorphology map of site ......................................................................................... 58 Figure 4.8 Earthquake hazard/zoning map for Madhya Pradesh .................................................. 60 Figure 4.9 Basic wind speed map of Madhya Pradesh with overlaid with study area ................... 61 Figure 4.10 Flood affected area of Neemuch district ....................................................................... 63 Figure 4.11 Ambient Air Quality in Study Area ................................................................................ 67 Figure 4.12 Baseline water stress map ........................................................................................... 76 Figure 4.13 Baseline water depletion map ...................................................................................... 77 Figure 4.14 Inter annual variability map .......................................................................................... 78 Figure 4.15 Seasonal variability map ............................................................................................... 79 Figure 4.16 Availability index map ................................................................................................... 80 Figure 4.17 Total annual rainfall map .............................................................................................. 81 Figure 4.18 Hydrogeological map .................................................................................................... 82 Figure 4.19 Percentage Composition of Different Vehicles Categories .......................................... 89 Figure 4.20 Habitats in the study area ............................................................................................. 92 Figure 4.21 Flocking behaviour in Water body adjacent to Unit 3 and a small pond along the way97 Figure 4.22 Central Asian Flyway .................................................................................................. 100 Figure 4.23 Migratory pathways of Anser indicus and Anas crecca .............................................. 100 Figure 4.24 Madhya Pradesh and Neemuch District ..................................................................... 103 Figure 4.25 Neemuch District Divisions ......................................................................................... 104 Figure 4.26 Map depicting villages in the Study Area ................................................................... 107 Figure 4.27 Proportion of SC/ST Population in the villages of Study Area vis-à-vis Tehsil/ District108 Figure 4.28 Comparative Overview of the Literacy Rate across Study Area, District and State ... 110 Figure 4.29 Proportion of Land Use in Study Area ........................................................................ 112 Figure 4.30 Decadal comparison of Working trends in the Project villages .................................. 116 Figure 4.31 Distribution of Main Working Population in the Study Area ........................................ 118 Figure 4.32 Comparison of Adult and Child Sex Ratios across Study Area, Tehsil and District ... 123 Figure 6.1 Impact Assessment Process ...................................................................................... 138 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS CONTENTS Final ESIA Report Figure 6.2 Impact Significance Matrix .......................................................................................... 148 Figure 7.1 RPO target and compliance status of Madhya Pradesh ............................................ 228 Figure 7.2 Map Showing Initially Identified Locations for Solar Park........................................... 231 Figure 8.1 Proposed Organisation Structure for ESMP Implementation ..................................... 261 Acronyms and Abbreviations Name Description AAQ Ambient Air Monitoring AI Availability Index AMSL Above Mean Sea Level AoI Area of Influence BC Block Categorisation BMTPC Building Materials and Technology Promotion Council BWD Baseline Water Depletion BWS Baseline Water Stress C&D Construction and Demolition CGWA Central Ground Water Authority CGWB Central Ground Water Board CH Critical Habitat CHC Community Health Centre CHWTSDF Common Hazardous Waste Treatment, Storage and Disposal Facility CO Carbon Monoxide CPCB Central Pollution Control Board CPR Common Property Resources CR Critical CSR Corporate Social Responsibility D.G. Diesel Generator dB(A) Decibels DC District Collector DCP Dry Chemical Powder DD Data Deficient DEM Digital Elevation Model DPR Detail Project Report E&S Environmental and Social EBRD European Bank for Reconstruction and Development EHS Environment, Health and Safety EN Endangered EPC Engineering, Procurement and Construction ERM Environmental Resource Management India Pvt. Ltd. ESIA Environmental and Social Impact Assessment ESMF Environment and Social Management Framework ESMP Environmental and Social Management Plan ESS Environment and Social Safeguards FLA Flood Likelihood Assessment FPIC Free Prior Informed Consent GAP Gender Action Plan GoI Government of India GoMP Government of Madhya Pradesh GRC Grievance Redressal Cell GRM Grievance Redressal Mechanism GSS Grid Sub Station GW Ground Water www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS CONTENTS Final ESIA Report Name Description Ha Hectare Ham Hectare metre HSE Health, Safety and Environment HW Hazardous Waste IA Impact Assessment IAV Inter Annual Variability IBAs Important Bird and Biodiversity Areas IFC International Financial Corporation IMD India Meteorological Department IP Indigenous People IPP Indigenous People Plan ISTS Inter State Transmission System IUCN International Union for the Conservation of Nature IWT India Water Tool JV Joint Venture KL Kilo Litre KLD Kilo Litre per Day Km Kilo metre Kmph Kilometre per hour KV Kilo Volt kVA Kilo- Volt Ampere LRP Livelihood Restoration Plan LUPA Land Use Permission Agreement MDR Major District Road MNRE Ministry of New and Renewable Energy MoEFCC Ministry of Environment, Forest and Climate Change MoP Ministry of Power MP Madhya Pradesh MPPCB Madhya Pradesh Pollution Control Board MPPTCL Madhya Pradesh Power Transmission Company Limited MPUVNL Madhya Pradesh Urja Vikas Nigam Limited MSK Medvedev-Sponheuer-Karnik Scale MW Mega Watt NAAQS National Ambient Air Quality Standards NFPA National Fire Protection Association NGO Non-Government Organization NH National Highway NOx Oxides of Nitrogen NQ Noise Quality NRSC National Remote Sensing Centre NT Near Threatened O&M Operation and Maintenance PAF Project Affected Family PCA Primary Census Abstract PCU Passenger Car Unit PGCIL Power Grid Corporation of India Limited PHC Public Health Centres PM10 particulate matter of particle size less than 10 micrometres PM2.5 particulate matter of particle size less than 2.5 micrometres PMC Project Management Consultant PPEs Personal Protective Equipments PS Performance Standard www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS CONTENTS Final ESIA Report Name Description PSS Pooling Sub Station PUC Pollution Under Control PV Photo Voltaic PVHI Photo Voltaic Heat Island R&R Resettlement and Rehabilitation RAP Resettlement Action Plan RFCTLARR Act The Right to Fair Compensation and transparency in land Acquisition, 2013 Rehabilitation and Resettlement Act, 2013 RoW Right of Way RPM Respirable Particulate Matter RPO Renewable Purchase Obligation RUMSL Rewa Ultra Mega Solar Limited SAR Sodium Adsorption Ratio SC Scheduled Caste SCADA Supervisory Control And Data Acquisition SECI Solar Energy Corporation of India Limited SH State Highway SO2 Sulphur Dioxide SPD Solar Project Developer SPO Solar Purchase Obligation SPPD Solar Power Park Developer SQ Soil Quality ST Scheduled Tribe SV Seasonal Variability SW Surface Water TAR Total Annual Rainfall TL Transmission Line VD Village Directory VU Vulnerable WB World Bank WHO World Health Organization WII Wildlife Institute of India WRI World Resources Institute www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report EXECUTIVE SUMMARY Introduction ERM India Pvt. Ltd. (ERM) has been engaged by Rewa Ultra Mega Solar Limited (RUMSL) to undertake an Environmental and Social Impact Assessment (ESIA) of three Solar Parks, including internal evacuation infrastructure and associated transmission lines (TLs) of aggregate capacity of 1500 MW in the Neemuch, Agar and Shajapur Districts of Madhya Pradesh, India. The ESIA for the aggregate 1500 MW Solar Parks has been divided into four distinct studies: ESIA for Neemuch Solar Park of 500 MW capacity; ESIA for Agar Solar Park of 550 MW capacity; ESIA for Shajapur Solar Park of 450 MW capacity; and ESIA for the external Transmission Line1 infrastructure for all three Solar Parks. This report is the Environmental and Social Impact Assessment study for the Neemuch Solar Park of 500 MW capacity (her ), located at villages Badi, Kawai and Bardawada, District Neemuch in State of Madhya Pradesh.. The Resettlement Action Plan (RAP) and Indigenous People Plan (IPP) will be prepared as separate deliverables. RAP and IPP shall be referred for most updated information on the social baseline and impacts. Project Description A brief description of Project is given in table below: Table 0.1 Brief Description of Project S. No. Particulars Description 1. Project Village location Badi, Kawai and Bardawada 2. Tehsil Singoli 3. District Name/State Neemuch / Madhya Pradesh 4. Location Coordinates Latitude: 24°59'39.78"N and 25° 0'38.51"N Longitude: 75°13'26.82"E and 75°14'48.53"E 5. Capacity Unit 1: 160 MW Unit 2: 170 MW Unit 3: 170 MW 6. Pooling Stations and Power Three Pooling substations of 33/220 kV (PSS), one in each Unit; Evacuation Power evacuation through proposed 220/400 kV ISTS substation of PGCIL at Badi village located in north of Project site in between Unit 2 and 3. 7. Climatic zone Agro-climatic 8. Average Elevation Elevation ranges from 396 to 440 m amsl High gradient land area (>7o): Nil 9. Site Conditions Agricultural land, scrub land 10. Road Accessibility SH 9A (Bhilwara to Modak) is between 1 to 2.5 km south of the southern boundaries of Neemuch Project site. The individual units of the Project is connected through existing village roads 11. Roads crossing Project site Village roads 12. Nearest Airport Udaipur Airport (~140 km, WSW) 13. Nearest Railway station Mandalgarh, Rajasthan ~ 25 Km (N) 15. River/ pond present in project Nil footprint (refer Section 1.4) 1 The external transmission line infrastructure refers to the power evacuation from the solar park site to the grid substation. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page I CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report S. No. Particulars Description 16. Number of Power line (66 KV 2 Transmission Line of 400 kVA and 220 kVA respectively. and above) present in Project footprint 17. Protected areas (National The closest legally protected area (National Park or Wildlife Sanctuary) is Gandhi Sagar Wildlife Sanctuary located ~ 50 Km Park/ Sanctuary)/ Forest land southeast of Unit 3; and The closest forest land is Arnea Reserve Forest block located 300m north of Unit 2 18. Land Area Identified 1065.7 hectares (as per DPR, July 2020) 19. Water Requirement Construction Phase: 250-300 KLD for civil works and 80-100 KLD for domestic use of labour at site; and Operation Phase: 308 KLD for solar panel cleaning; 10 KLD domestic water; 7 KLD for green belt maintenance; 32 KL for firefighting and miscellaneous 20. Source of Water Construction: Tanker water Operation: Ground water 21. DG sets For backup power requirement during construction phase; No. and capacity yet to be determined. 22. Soil Characteristics Loamy sand Project area 23. Seismic Zone Zone II (Low damage risk zone) 24. Flood prone zone High vulnerable zone 25. Wind zone High Damage Risk Zone Land Requirement and Status The following table provides a summary of the land requirement for the project. Table 0.2 Neemuch: Village Wise Land Allotment details Land Category Unit 1 (ha.) Unit 2-(ha.) Unit 3 Total land (ha.) (Hectare) Bardawada Kawai Kawai Badi Badi Government Land 201.8 89.6 156. 1 163.2 351.7 962. 5 (both NRED allotted & identified) Private Land 5.1 4.2 0 1.7 10.4 21.4 Patta Land 50.7 0 22.4 3.6 5 81.7 Sum 351.5 347 367 1065.7 Source: Land Data provided by RUMSL, 3 June 2020 The private land comprises of 2 percent land of Solar Park, whereas Patta land comprises 7.6 percent of the total land identified for Neemuch Solar Park. As part of the latest update, the total land parcel being considered for the Neemuch Solar Park is 1065.7 ha after feasible avoidance of land being used for agriculture, habitation, structures and access spaces/ routes, etc. Some portion of the government land identified for the Neemuch Solar Park, though classified as government land is currently this use/status is not indicated in the land records. The land procurement process for the Solar Park commenced in 2016-17, where RUMSL identified potential land parcels potential project areas, with large chunks of unused government land. This was driven by the intent to use Government land for the project to minimize the use of Private or Patta lands the extent possible. The land identification was followed by screening and scoping exercises, in order to identify the possible exclusions and avoidances on the identified land, comprising avoiding certain settlements/ clusters of structures, potential Bhil settlements, etc. Based on the recommendations from the scoping www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page II CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report exercise, another drone survey of the identified land parcels were undertaken, to further optimize the land requirement in a manner, that impacts to private and patta land owners and associated livelihoods are minimized. Land Procurement A Land Use Permission Agreement (LUPA) will be signed between New and Renewable Energy Department, Government of MP and RUMSL for the life of the project. Subsequently, M/S RUMSL will have a back-to-back Land Use Permission Agreement with the Solar Project developers, which would enable them to use the land for development of the solar project as per the agreed terms of the LUPA. The private land for the project shall be purchased as per prevailing laws and policies in the State of Under the policy, the District Collector (DC), may purchase private and patta land based on the requirement, due to non-availability of government land and or shortfall in meeting the project land requirement through government land. Applicable Reference Framework Applicable Indian (national, state and local) Environmental and Social Regulations; Applicable Permits (licences, approvals and consents) and permitting agencies; IFCs Performance Standards on Environmental and Social Sustainability (2012) (IFC, 2012); World Bank Environmental and Social Safeguard Policies; IFC/ WB General EHS Guidelines (2007) (IFC, 2007); IFC EHS Guidelines for Electric Power Transmission and Distribution, 2007; and MNRE Environmental and Social Management Framework for Solar PV Park, February, 2017. Applicable National Environmental Standards for Ambient Air, Noise, Water etc. Current Baseline Status The following table provides a summary of the baseline in the study area Table 0.3 Summary of Current Baseline Status S. Category Description of Baseline No. 1. Location Characteristics The Project site is located ~ 70 km from Neemuch town and is spread across three villages- Badi, Kawai and Bardawada of Singoli Tehsil. The Project area lies between Latitude: 24°59'39.78"N and 25° 0'38.51"N Longitude: 75°13'26.82"E and 75°14'48.53"E 2. Study Area The area of up to 5 km radius from the Project boundary (Solar Park area) has been demarcated as study area for the Project. 3. Land Use and Land The current land use of the proposed project site is agricultural land, grazing Cover land, and scrub land with some trees Some are is under water features like natural drains, ponds 4. Topography The Project site area is fairly flat land; The high gradient area, i.e. area > 7o is nil. 5. Drainage Project site have water bodies and 3rd or 4th order dendritic drainage channels within the site area. 6. Soil Characteristics Soil in the area is black cotton soil; No major anthropogenic activities are carried out in the area which may lead to soil contamination. There are stone quarrying activities occurring on the site, mainly in Unit 3 area. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page III CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report S. Category Description of Baseline No. 7. Ground Water Water bodies present in the study are mostly rainfed and are used for domestic purposes as washing of clothes and for domestic animals 8. Ambient Air Quality As per baseline monitoring conducted for the Project, ambient air quality parameters (PM10, PM2.5, SO2, NOX) were within the prescribed CPCB limits. 9. Ambient Noise As per baseline monitoring conducted for the Project, the noise levels during Quality day and night time were observed within the CPCB prescribed limits. However, at two locations day time noise levels are at the edge of prescribed limit of 55 dB for daytime. 10. Biological Habitats in the study area include agricultural land, open scrub, water bodies Environment and open forest areas (no forest area within Project footprint); The closest legally protected area is Gandhi Sagar Wildlife Sanctuary, [IUCN Management Category IV] which is located ~ 50 km southeast of Unit 3; The closest internationally recognized biodiversity area is Gandhi Sagar Wildlife Sanctuary and reservoir which is located ~32 km southeast of Unit III3. This is also declared an Important Bird and Biodiversity Area (IBA) and supports significant concentrations of water birds (IBA Category A4iii); Four species of herpetofauna, 58 species of avifauna and 12 species of mammals were recorded/reported from the study area during site visit. 11. Demographic Profile The project footprint falls in three Project villages, while the AoI comprises 32 villages. The Project villages comprise of 440 households with a population of 2,047 individuals (as per 2011 Census data while the current figure is expected to have increased significantly). The average size of the households is 5 in the Study Area 12. Social Stratification The entire population in the Study Area falls in the rural category. The villages comprise majorly of Dhakad, Gujjar and Rajput communities and some households belonging to Bhil (ST), Balai and OBC groups. 13. Gender Profile The Project Villages exhibit lower adult sex ratio (915) and child sex ratio (750) as compared to the AoI, tehsil, district and the state figures of sex ratio. Badi village has the lowest adult sex ratio of 884 amongst all project villages; Women are responsible for domestic roles in a household along with working on agricultural farms, while men are engaged in activities of sale, purchase of goods and livestock grazing. 14. Education and The total literacy rate (54.2%), male literacy rate (69.2%) and female literacy rate Literacy (38.5%) in the Project villages is the lowest as compared to the AoI, Study Area, Tehsil and district figures. The female literacy rate in the AoI (51.1%) are relatively higher and are comparable to the district and state figures, while in the Project villages, the female literacy rates are quite low. 15. Land Ownership Census 2011 figures for land area indicate that 50.6 percent of the land area in the Project Villages is categorised barren and uncultivable land, 23.1 percent is net sown area, out of which 63 percent is unirrigated land and 37 percent is irrigated land. The Project villages have 7.8 percent of the total land area as forest land, 3.3 percent area under non-agricultural use and 4.2 percent as culturable waste land. Additionally, 4.6 percent is land comprising of miscellaneous tree crops, and 4.6% are permanent pastures and other grazing land. 16. Livelihood Profile The Study Area is categorized by 53.4 percent working population, where majority of the working population comes under Main Workers (56%) 17. Water Supply and The Project villages fall in the region of extremely high baseline water stress Sanitation and high risk of baseline water depletion. The quality of drinking water available at lower depth is reported to be good while higher salt concentration is found in water from deeper levels. There are issues of drying of borewells reported in the summer months. Kawai has piped water connection while Tube-wells are also a significant source of water serving a majority of villages www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page IV CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report S. Category Description of Baseline No. 18. Health facilities and The health facilities in the Study Area follow a three-tier health infrastructure Health Seeking system, as also applies to the state of MP. As per Census 2011 data, in the Project Behaviour Villages, however, there are no Community Health Centres (CHCs) or Primary Health Centres (PHCs). The villages of the Study Area have access to 2 Primary Health Centres, one each in Nayagaon and Jhantala villages. Four AoI villages of Dhangaon, Dhardi, Funsariya and Kadwasa, have a Primary Health Sub Centre in their village. Stakeholder Consultations and Disclosure During the ESIA process, a stakeholder identification and prioritization was conducted for identifying the key stakeholders of the project, while keeping in mind the nature of the project and its setting. Furthermore, consultations were conducted with these identified stakeholders through a participatory approach. The table below gives the list of primary and secondary stakeholders, depending on the extent of impact (direct/ indirect) on the stakeholder by the project. Those person(s) or groups who will be directly impacted by the project are Primary Stakeholders and those who have an indirect influence or the Project impacts indirectly are the Secondary Stakeholders. Stakeholder Groups Primary Stakeholders Secondary Stakeholders Community Private Land Owners from Bardawada, Fence Line Communities Kawai, Badi villages from other villages in the Patta Holders from Bardawada, Kawai, Badi vicinity villages Non- Squatters and Encroachers Agricultural Labourers the patta based on a verbal Graziers agreement with the original Vulnerable Social Groups in other villages in (and registered) patta the vicinity holder; Contractors Potential unskilled labourers to be engaged for the construction phase of the project Owners of land required for temporary occupation or use Local Community from Project villages. Institutional Gram Panchayats of Dhardi (for Bardawada Local Political Groups Stakeholders village) and Badi (for Kawai and Badi Civil Society/ Local NGOs villages); Singoli Tehsil officials Government Regulatory Authorities comprising the Bodies/Regulatory following: Authorities - MP Pollution Control Board; - Central Pollution Control Board (CPCB) - Ministry of Environment Forest and Climate Change (MoEFCC) - Local Fire Authority; - Ministry of Road Transport and Highways - State Transport Authority; - District Collector and Revenue Department; - Central Electrical Authority through C.E(P&D) Jabalpur; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page V CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Stakeholder Groups Primary Stakeholders Secondary Stakeholders - Department of Telegraph Communication, Govt. of Madhya Pradesh; - Department of Panchayati Raj, Madhya Pradesh; - Labour Department; - Wildlife Warden, State Forest Department; - District and State Forest Department, MoEFCC. District Administration Potential Environmental and Social Impacts Assessment of potential impacts on the various environmental, ecological and social elements due to the Project activities were carried out for this ESIA study. The likely impacts on loss of land, land- based and non-land based livelihoods, vulnerable groups (women, youth etc.), labour, water environment, air environment, biological environment and socio-economic environment has been identified based on the actual and foreseeable events/Project activities. For the impact assessment, wherever necessary, professional judgement, experience and knowledge on similar projects have been used. The extent and potential consequences of the impacts have been compared against applicable standards and guidelines. Mitigation measures have been suggested for each of the identified potential impacts. The following table provides a summary of potential environmental and social impacts due to the project. The mitigation measures are also recommended to mitigate the adverse impacts. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page VI CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) Planning Phase Impact due to Private Approx. 21 ha. of private land is being Moderate Minor The private land sellers should be provided with either Land Purchase considered for purchase by the alternate land parcels with similar nature of productivity project, which forms nearly 2% of the and financial assistance to prepare the land for cultivation total area identified for the project; or adequate compensation at twice the value of land and The private land parcels that are assets, as per MP Mutual Consent Land Purchase Policy, identified are not being used for 2014; residential purposes, thus there is no physical displacement due to project; A Resettlement Action Plan- Livelihood Restoration Plan however, economic displacement shall be formulated to cover economic displacement will occur for the private land sellers categories (subject to the qualifications stated under whose land parcels will be purchased embedded controls) to address the following: for project related activities affecting - Livelihood impacts on the land owners if the holdings livelihoods and incomes; that remain are sub-optimal, or owners are rendered Landlessness may potentially result landless; due to purchase of private land parcels in some cases. The total land - Additional livelihood assistance to vulnerable holding and proportion of land households, or women headed households, with skill remaining with the sellers after the trainings or entrepreneurship support, etc. under the mutual consent based sale, is not LRP; known currently, but will be assessed - Impacts on land users or regular agricultural during the RAP survey; labourers affected Agricultural labourers employed by the land owners of the private land - The general community being impacted due to parcels identified for purchase for the access restrictions/easements; project will experience loss of - Other impacts on private land owners. livelihood opportunities; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page VII CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) Loss of access or easement for the Preference to members of the families rendered landless local community due to diversions/ or with sub-optimal holdings post selling land to the barricading of areas due to project for employment opportunities in the construction phase activities. Construction/operation phase and/or small contracts; Timely sharing of project related information with all relevant stakeholders; Provision of Grievance Redressal Mechanism to all impacted stakeholders in order to raise and register their grievances. Impacts due to Patta Approx. 81.7 ha. of Patta land is Moderate Minor Patta is being treated at par with ownership, for the land land Purchase being considered for purchase by the procurement process. Thus treatment of Patta Land project, which forms approx. 8% of holders will be similar to Private land owners and Patta the total area identified for the project; holders shall be provided with either alternate land Economic displacement will occur parcels with similar nature of productivity and financial for the Patta Land holders who have assistance to prepare the land for cultivation or adequate invested cost and efforts in the Patta compensation at twice the value of land and assets, as land to make it cultivable and are per MP Mutual Consent Land Purchase Policy, 2014; currently undertaking agricultural activities; A Resettlement Action Plan- Livelihood Restoration Plan The Tarmeem process demarcated shall be formulated to cover economic displacement the location of 43 Patta land parcels categories (subject to the qualifications stated under in Bardawada, 22 Patta land parcels embedded controls) to address: from Kawai and 8 patta land parcels - Livelihood impacts on the land owners if the holdings in Badi and while the recorded Patta that remain are sub-optimal, or owners are rendered land holders can be based on the landless; available records, these will need to www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page VIII CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) be updated during the RAP survey to - Additional livelihood assistance to vulnerable get the current number of affected households, or women headed households, with skill households and persons (reasons trainings or entrepreneurship support, etc. under the outlined below).; LRP; Typically Patta land owners are likely to be from vulnerable households like - Impacts on land users or regular agricultural SC, ST and other previously landless labourers affected households and the land purchase for - The general community being impacted due to the project may lead to cases of access restrictions/easements; landlessness, (which is more likely - Other impacts on patta land owners. to be in this category than the category of private land holders, as Preference to members (rendered landless or with sub- landlessness is a baseline criteria optimal holdings) of the families post selling land to the for initial award of pattas); project for employment opportunities in the It is understood that certain Patta Construction/operation phase and/or small contracts; Land parcels have been sold off Additional safeguards to be addressed through the RAP- based LRP for Patta Land owners, including those who may household it was originally allotted to, without a change in records. Although allottees based on a verbal agreement and without this is not allowed as per the terms of documentation the allotment, it is reported as a practise. In such cases, the Timely sharing of project related information with all households using the Patta lands relevant stakeholders; through this arrangement are also Provision of Grievance Redressal Mechanism to all understood to be impacted, in impacted stakeholders in order to raise and register their addition to original owners, who are grievances. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page IX CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) Agricultural labourers working at the Patta land parcels identified for purchase for the project will experience loss of livelihood opportunities; Loss of access or easement for the local community due to diversions/ barricading of areas due to construction phase activities. Impacts due to LUPA of Government land being identified for Major Moderate Provision for alternate grazing land for livestock shall be Government land the project from the three project made near the project villages or confirmation of villages amounts to 962.5 ha, which adequacy of remaining grazing land, to be confirmed forms nearly 90% of the total land during the RAP survey (including the assessment of required for project. access and quality of the remaining area); This land has different uses by the local community: Development of a program to include grazing area improvement and fodder intensification (cultivation) in - Livestock grazing in the open as designated areas, as agreed with the Tehsil office and well as within encroached and the local dependent community of graziers. This may include the development of community fodder lots under encroachers(see below); the Livelihood restoration activity in the area as part of - Incidental collection of non-timber Resettlement Action Plan. This, if feasible, shall serve the purpose of improving the quality of the grazing land, ensuring access and as an income generating activity for - Easements, access to assets and people losing land based livelihoods. other resources not within the project boundary, etc. and the change in use The project developer is also encouraged to explore and ownership of Government land identifying unused areas within the solar park boundary www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page X CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) will affect the users in the community and a part of the area with solar panels (10% area), for to varying degrees. fodder cultivation, or controlled and managed open The Impacts on users of this land grazing of goats, or agriculture (selected crops), to type comprise the following: Loss of Grazing land for the parks that benefit the local community too. This may be livestock in the area and loss of done with the agreement of RUMSL and in partnership livelihood and nutritional security with domain specialist agencies and local organisations due to possible reduction in working in the region. Additional positive effects may livestock herd size due to reduced access to grazing land (potential vulnerability) Section 6.2.4. Loss or severance of access for Provision of easements shall be maintained in order to the community, livestock, etc.; not sever the access to CPRs for the community; Loss of cultural resources in terms of religious trees, structures, etc. Preference of members of Project affected households (PAH), as identified in the RAP, in employment opportunities during construction phase; In case of Squatters and encroachers, RUMSL shall serve a three months advance notice to the project affected persons (PAPs) to manage the potential losses to standing crops; In case of crop losses ensuing from project activities, RUMSL shall pay compensation for crops, as defined in the RAP (entitlement matrix); Timely sharing of project related information with all relevant stakeholders in order to serve advance notice and reduce the extent of impacts and losses; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XI CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) Employment to members of such encroacher and squatter households, based on qualification; Skill development of members of such encroacher and squatter households, based on any existing skill set (if any), and self-declared interests; Provision of Grievance Redressal Mechanism to all impacted stakeholders in order to raise and register their grievances. Impact on Vulnerable Out of the three phases, the Moderate Minor To identify and assess the extent of impacts on this Groups Indigenous Communities and group, a review of the scope of FPIC and IPP, in terms of vulnerable groups are understood to remaining impacts on IP groups, their traditional be impacted the most during Planning livelihoods and customary land use; including phase of the project, on account of dependence on natural resources, will be undertaken; loss of livelihoods linked to land being procured for project. Since these Based on this review, the target groups for the FPIC agricultural workers are not rightful process will be identified in terms of villages and number owners or users of land as per of households in each village. records, the project related It should be noted that the exact number of households compensation measures would not be may be identified only post the site walk through and directly reaching out to this group. social mapping. Review the consultation process carried out as part of allotment process of unoccupied government land through discussions with personnel from the Land Division of District Magistrate office to access the Gram Sabha resolutions as part of the land allotment process. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XII CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) Relevant details in relation to the Gram Sabha Resolution will be collected to understand implications for any legacy issues. As part of the stakeholder engagement, ensure adequate representation of the Indigenous groups and vulnerable groups, and specific engagement activities are undertaken with these groups; Ensure that the grievance management mechanism established is accessible to these groups. Construction Phase Land use and Land The establishment of the Solar Park Moderate Moderate Construction activities should be restricted to designated cover will convert scrub land and agricultural area; land to industrial use for the long term (at least 25 years). The total land area On completion of construction activities, land used for of more than 1,000 ha will undergo temporary facilities such as Contractor office, batching land use change, out of which almost plant (if any), stockyard, labour camp should be restored 90% is government land. to the extent possible; In the construction phase, temporary The land use around permanent Project facilities should land use changes will occur at not be disturbed; and contractor facilities and labour camps, material storage areas; The land should be restored back to the original state to During construction phase, there will the extent possible after completion of life cycle of the be permanent change of the land use Project and in case there are plans not to continue further within the land parcels where the at the site Solar Park and pooling substation will be established. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XIII CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) Soil erosion and The site clearance activities, Minor Negligible The topsoil present in the construction shall be removed compaction excavation and levelling of ground will and stock pilled in separate area; cause disturbance of the soil strata and impact on soil quality. The stock pile should be protected from natural elements The project will undertake the soil to prevent from erosion and also degradation; compaction activity to ensure soil Topsoil to be reused on site for landscaping purpose; stability during the establishment of storage areas, labour camp, access Defined routes for transportation and construction road, installation of batching plant, vehicles, workers etc. to minimize soil compaction; establishment of substation, SCADA Good drainage as per the natural slope condition should building etc. be provided to reduce surface runoff and associated During construction activities, there erosion; would be compaction of soil in the Project area during movement of Back filling and revegetation of the area disturbed will be vehicles/ construction machinery and undertaken phase wise immediately after the completion; work force movement. and In addition, laying of electrical wires in Site clearance, piling, excavation and access road the agricultural field during erection of construction will not be carried out during the monsoon internal electrical lines will also lead season to minimize erosion and run-off. to the compaction of agricultural soil to certain extent. Waste generation and General construction waste Construction and Demolition Waste should be stored Minor Minor soil contamination generated onsite will comprise of separately and disposed through approved facility/landfill; concrete, steel cuttings/filings, packaging materials or plastic. All waste should be stored in a shed that is protected Municipal solid wastes consisting of from the elements (wind, rain, storms, etc.) and away food waste, plastic, glass and waste from natural drainage channels; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XIV CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) paper will also be generated by the A log book should be maintained for quantity and type of construction workforce at canteen hazardous waste generated; facility/ labour camp. A small proportion of the waste Designated areas should be provided for Solid Municipal generated during construction phase Waste and daily collection and period disposal should be will be hazardous and will include ensured; waste fuel, grease, broken modules, EPC Contractor should ensure that no unauthorized paints, chemicals and waste oil dumping of used oil and other hazardous waste is containing rags. undertaken at the site; Hazardous waste to be disposed through MPPCB authorised vendors; In case of accidental/unintended spillage, the contaminated soil should be immediately collected and stored as hazardous waste; The guidelines and procedures shall be prepared and followed for immediate clean-up actions following any spillages; Damaged/ discarded solar panels to be disposed with the help of authorised recycling vendors/ module installation contractors/ supplier; and Other wastes such as e-waste, used discarded batteries shall be disposed off in accordance to E-waste rules and batteries management and handling rules www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XV CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) Topography and Impact on topography of the Project Minor Minor site due to site levelling activities. Project shall ensure to avoid any unnecessary changes in Drainage Any changes to topography in the the topography especially during the preconstruction and area will advertently impact the construction phase; drainage channels and might result in water logging in adjoining areas of the Micro drainage channel should be particularly avoided Project site. when constructing access roads or planning the Transmission Line pathway in order to ensure no change to the topography of the area. Storm water drains must be designed in line with the natural topography and eventually drain into the natural seasonal streams in the Site area Water resources Stress on local water resources due Major Major to No ground water abstraction during construction phase to water requirement for the Moderate foundation activities, establishment of As part of project designing, SPD shall consider the substation, labour camp during rainwater harvesting ponds in the open area depending construction phase on the topography, slope, natural drainage etc. Accordingly infrastructure such as drains/ piping system/ size of pond etc. shall be designed. Similarly, in case water is sourced from surface water bodies, infrastructure requirements shall be identified and planned in project design Construction labour deputed onsite to be sensitised about water conservation and encouraged for optimal use of water; Regular inspection for identification of water leakages and preventing wastage of is necessary for efficient utilisation of water www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XVI CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) Water Quality Minor Minor to The quality of water in the water Ensure proper cover and stacking of loose construction Negligible bodies could be affected due to material at site to prevent surface runoff and surface runoff from contaminated soil contamination of receiving water body; (soil contamination due to oil/ fuel Open defecation and random disposal of sewage will be spillage and leakages) especially strictly restricted; during monsoon season. The surface runoff carrying the loose Planning of toilets, soak pits and septic tanks, waste top soil will lead to increased collection areas away from natural drainage channels; sedimentation in the receiving water Provision of number of toilets across with easily bodies. accessible location as the project site is spread across large area of 2 Units separated geographically; Use of licensed contractors for management and disposal of waste and sludge; Labourers will be given training towards proactive use of designated areas/bins for waste disposal and encouraged for use of toilets; Provision for impervious storage area, especially for fuel & lubricant, hazardous waste, etc. will be made onsite; and Spill/ leakage clearance plan to be adopted for immediate cleaning of spills and leakages. Ambient air quality Minor Minor to Fugitive dust emissions from site The construction site shall be barricaded; Negligible clearance, piling work, handling of Keeping areas of open excavation to a minimum; construction materials, emission due www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XVII CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) to movement of vehicles on unpaved Minimising stockpiling by coordinating excavations, roads, plying of vehicles, etc. spreading, re-grading, compaction activities; Vehicular emissions due to increased Cease or phase down work if excess fugitive dust is traffic movement on site and on the observed, investigate source and take suppression approach roads; measures; Exhaust emissions from construction Speed of vehicles on site to be limited to 10-15 km/hr; machinery and other equipment such as batching plant, if any; and The emissions from diesel generator shall be by Emissions from diesel generators optimised operations, orientation at the site and providing required to be run for construction adequate stack height for wider dispersion of gaseous power purposes emissions Switch off machinery and equipment when not in use; Prevent idling of vehicles and equipment; and Vehicle engines will be properly maintained and will have a valid Pollution under Control (PUC) to ensure minimization in vehicular emissions Ambient noise quality Noise generation due to construction Moderate Minor Ensure safe distance of project related activities from schools, hospitals, etc.; machineries, D.G. sets, movement of vehicles and heavy earth moving Only well-maintained equipment to be operated on-site; machineries. ; If it is noticed that any particular equipment is generating Local communities may get disturb too much noise then lubricating moving parts, tightening due to higher than anticipated noise. loose parts and replacing worn out components to be carried out to bring down the noise. It is to be ensured that such machinery are kept far away from the households; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XVIII CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) Machinery and construction equipment that may be in intermittent use to be shut down or throttled down during non-work periods; Low noise equipment shall be used as far as practicable; The number of equipment operating simultaneously shall be reduced as far as practicable; Install enclosures around construction area, in order to reduce the extent of noise emanating due to project related activities; DG set with acoustic enclosures shall be used; Vehicular movement through village roads should be planned to avoid traffic jam and inconvenience to local residents; Equipment noise should be 85 dB (A) at 1 m from the source in line with WB/IFC EHS guidelines; Minimal use of vehicle horns needs to be encouraged; Limit construction related activities to day time in order to restrict the noise related nuisance in the evenings, where permissible noise threshold is lesser; Provision of Grievance Redressal Mechanism to all the key stakeholders in order to raise and register their grievances pertinent to noise and dust related issues www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XIX CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) Occupational health and Minor Minor Construction of support structure for Health & safety training to be provided during both safety PV module would require operation of construction and operation phase; pile drivers. Prior to start of work, workers should be informed about The installation of solar module will the related safety risks and precautions to be taken involve operation of cranes and other through tool box meetings; mechanical lifting equipment. Manual lifting by adult men to be less than 55 kg and for Laying of interconnecting cable with women it should be less than 30 kg; require digging. Adequate PPEs to be provided for all activities at site The commissioning of the inverter including for welding, cutting or similar operations which rooms and Transmission Line will also may cause hazard to eyes; involve live power lines. All persons performing construction work to wear safety Working on live wires carrying power shoes and helmets confirming to national standard; has dangers of electric shock and Every worker engaged in handling sharp objects which electrocution. may cause injury to hand shall be provided suitable hand Construction and commissioning of gloves; PSS and associated structures will While working in hot conditions, measures such as work involve multiple hazards i.e., working break at regular intervals, keeping hydrated by drinking at height, use of cranes and water and liquids, covering face with damp cloth etc. shall mechanical lifting equipment, working be used; with high voltage power; Besides this, there could be slip and trip hazards especially during Monitor health and safety performance and have an monsoon season; and operating audit system; The area experiences extreme winter and summer condition. Working www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XX CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) during very high and low temperature Permitting system should be implemented to ensure that could cause health hazards. cranes and lifting equipment is operated by trained and The Project site also needs to authorized persons only; implement proper measures for fire Appropriate safety harnesses and lowering/raising tools safety, structural safety and any for should be used for working at heights; emergency situations. All equipment should be turned off and checked when not in use; Emergency contact numbers and route to the nearest hospital to be displayed at the construction site; The local/ host community to be kept at safe distance from construction site; Site specific safety or emergency response plan should be in place to account for natural disasters, accidents and any emergency situations; Site specific/ activity specific Hazards Identification and Risk Assessment (HIRA) should be developed prior to start of the activities at site; and Provide H&S achievement information to employees Habitat Modification and The habitat with the highest sensitivity Minor Minor Larger mature trees with significant height and girth Loss in the Project site is the scrub land should be avoided to the extent possible when adjacent to [Water Body adjacent Unit constructing the Solar Park. Larger trees can be set aside 3]. The water body supports migratory within the Solar Park and avoided as part of the micro- and resident bird species including siting of the solar modules small colonies of the Vulnerable Woolly-necked Stork. As vegetation www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXI CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) surrounding the water body is The Kawai Pond and Bardawada Pond is located within commonly utilized by resident bird 500 m and 100 m from Unit 2 and 1 respectively. The species, the loss of these habitats vegetation surrounding these ponds should be avoided to could result in displacement of fauna the extent possible when siting temporary facilities (i.e. from the area. Storks are also labour camps, contractor facilities, batching plant, etc.). commonly found perched at heights on Transmission Lines or trees near A natural canal delineates the border between Kawai and water bodies and therefore the loss of Badi Villages. The canal was dry during the site visit vegetation would affect the Vulnerable despite the assessment being immediately after the Woolly-necked Stork. monsoon season. The canal may pass through Unit II and/or Unit III after the compound is constructed. The natural drainage through the canal should not be blocked due to construction and operation/maintenance activities. If changes in the boundaries of the proposed units or any further expansions are anticipated than the areas surrounding the Arnea Reserve Forest block should be avoided to prevent increased risk of edge effects. The area around the [Water Body Unit 3] should be avoided for the siting of any ancillary facilities including access roads, contractor facilities or labour accommodation and even siting of equipment (e.g. DG set, waste storage area, material storage area, etc.) should not be undertaken adjacent to the water body. Impacts due to Construction activities at Project site Minor Minor will create a disturbance to local fauna No hunting, trapping or injuring of local fauna should be Construction activities and force them to remain in an alert communicated to labourers through a workshop or formal mode for extended periods of time training exercise. The training should also communicate that prevents proper foraging, presence of species protected under Wildlife Protection www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXII CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) roosting, nesting, breeding, mating Act, 1972 Schedule I and the penalties associated with and socializing activities contravention on the identified law; The resultant impact could affect the viability of local flora, ground-roosting Noise control measures such as acoustic enclosures for bird species and ground-dwelling DG sets, noise attenuation barriers in areas near sensitive fauna habitat and proper maintenance of the vehicles used for human-wildlife conflict the Project site should be implemented to reduce the effect of construction noise on local ecology; Set routes, consolidation of trips and no off-roading policies should be introduced by the EPC contractor to reduce the impact from noise and human-wildlife conflict; Adequate toilets, gas/firewood and space should be provided in any anticipated labour accommodation and the labourers should be informed not to enter or utilize any resources from surrounding forest land over the course of the construction period; Local semi-skilled and unskilled labourers should be used to the extent possible to reduce demographic influx into the Project site and therefore reduce the risk of disturbance to local fauna; Waste that is generated from the Solar Park during construction and operation should be stored in covered containers within the site premises. Uncovered waste may attract fauna to the Solar Park; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXIII CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) Excavated areas should be adequately fenced and security should be deployed to prevent wildlife intrusion into these areas; Construction work and anthropogenic movement should be restricted near any major water bodies to reduce the impact on aquatic bird species (resident or migratory); Construction activities and transportation should be avoided during peak ecological activity i.e. dawn (5:30 am to 7:30 am) and dusk (5:00 pm to 7:00 pm). Night-time activities should be kept to a minimum; Areas with pre-existing nests, ground-roosting sites and burrows should be avoided for construction related work to reduce the impact on local fauna; and Hazardous materials and waste should not be stored near any drainage channels or cliff-sides to prevent contamination of the surrounding environment and impact on local flora/fauna. Ecosystem Services Project will include the long-term loss Minor Minor Nesting trees should be avoided to the extent possible of food resources, water, shelter, when it falls within the Solar Park site. nesting sites, etc. The existence of the walled compound Larger mature trees1 with significant height and girth may also hinder daily pathways taken should be avoided to the extent possible when by reptiles, mammals and birds for constructing the Solar Park. Larger trees can be set aside foraging, roosting and socializing within the Solar Park and avoided as part of the micro- siting of the solar modules. 1 Mature trees can provide several ecosystem services including firewood, non-timber forest produce, shelter, climate regulation, habitat provision and foraging resources. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXIV CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) Loss of viability of the [Water Body Natural drain passing between Kawai and Badi should be Unit 3] due to any impacts (e.g. unaffected by the Project construction. Similar seasonal sedimentation, water contamination, drainage pathways should not be blocked during the etc.) from the adjacent construction Project construction. work for Unit 3 of the Project. Seeding of native plant species outside of the Solar Park especially in areas where the soil layers have been impacted and around water bodies to offset the loss of floral resources and dependent ecosystem services. Pollution and spill control mechanisms should be implemented and strictly enforced around [Water Body Unit 3] to ensure that there is no impact to the water quality or any drainage channels into the water body. Impacts due to The land required for temporary Minor Negligible Provision of adequate lease on rental amounts to the land temporary occupation of activities like setting up of a number owners shall be ensured by RUMSL; land for construction of labour camps for the required activities duration, land for safety setbacks, The land leased/ rented shall be restored to its original storage areas, parking areas and state (or made better) at the time of handing it back to the other construction related temporary owners; land requirements, if these are Provision of compensation for the loss of livelihoods to located outside the boundary of the the users of the land required for temporary use as this Project Area. If all these activities can will temporarily economically displace them; be accommodated with the Project Application of all precautions to implement and follow the footprint, the impacts from temporary COVID-19 related safeguards, as relevant and as land lease-rent, will be avoided; prescribed by the government, at that time Other impacts, from noise, nuisance, resource use, etc., are discussed below. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXV CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) COVID 19 related infection risks may Timely dissemination of project related information with all persist and may be enhanced for relevant stakeholders, in order to serve advance notice workers, living and working in close and reduce the extent of losses/ impacts; proximity of each other Provision of Grievance Redressal Mechanism to all the key stakeholders in order to raise and register their grievance. Impact on Community The movement of material and Responsibilities of RUMSL Moderate Minor Health and Safety machinery would pose health and Ensuring stakeholder engagement through the project safety risks to the community and cycle and provision of an effective Grievance Redressal livestock as the vehicular movement Mechanism to avoid, mitigate and mange conflicts and will increase in the area and may disagreements; result in collision and accident risks, and create additional vehicular and As part of the stakeholder engagement and information dust pollution, affecting people, disclosure process, the community will be provided with animals and potentially affecting an understanding of the activities to be undertaken and crops in the vicinity of the corridor of the precautions to be taken for safety; movement; RUMSL shall maintain safe distance of project Labour influx in the area due to components from schools, hospitals, etc. in order to avoid construction phase may lead to interactions with community hotspots and hence risks of community health and safety related accidents; impacts which may include The Contractors to be engaged by RUMSL shall be - Potential spread of communicable informed of the EHSS practices that are expected from its diseases (infectious and vector- workers during the construction phase engagement. borne), if external labour will be Obligations like preparation of Traffic Management Plan, sourced from outside the region, Local Procurement Plan, EHSS Plan (including for www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXVI CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) - The issue of COVID-19 related managing COVID 19 related risks), etc. shall be infections may remain a relevant communicated to them at the time of selection and concern and may need to be appropriate clauses should be included at the time of especially managed both, within contract finalization; labour camps and in the interactions of workers and the local community accommodation guidelines, for the labour camps in terms Conflicts with local community of provisions, sanitation facilities, etc. thus limiting the resulting from disagreements over probability of diseases and infections in the local other issues and local impacts community on account of improper management of waste; RUMSL shall put in place a grievance redressal mechanism to allow community members to report any concern or grievance related to project activities. The contractors engaged shall also be contractually required to put in place a similar mechanism to deal with concerns raised by the community (or external stakeholders) and the workers engaged during construction phases. Contractors The contractor shall induct migrant workers on health and safety awareness and practices to be followed at site during construction phase; The contractors shall cordon off areas that are under construction and put relevant safety signs to restrict movement of local community members or workers engaged at site, which may become safety threats; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXVII CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) The Contractors shall prepare a Traffic Management Plan and traffic movement due to the project in the area will be regulated to ensure road and pedestrian (including livestock) safety; Additionally, training on vehicular safety shall be organised for the transport workers. The movement of workers from the project site and labour camps shall be regulated and similarly the project boundary and labour accommodation to check for unauthorized visitors/ outsiders entering the site in order to avoid any possible interactions leading to conflicts or tensions between the migrant workforce and host community; Contractors shall ensure that regular health check-ups are conducted for the construction phase workers (especially migrant workers staying in temporary labour accommodation) and any major illnesses are reported in the Block level medical authorities at the earliest; The labour accommodation should be clean and hygienic and disposal of kitchen waste and food waste shall be done on a daily basis in an appropriate manner; Proper sanitation facilities shall be provided, taking into account the number of labourers that will be using the facilities, both at construction site, as well as labour accommodation; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXVIII CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) Stress on community Depletion of ground water resources Minor Minor to RUMSL responsibilities resources in the area may take place due to use Negligible for project related activities like There will be a worker Code of Conduct defined by construction, use for drinking water, RUMSL that prevents workers and contractors from using cooking and sanitary purposes, etc. the local resources like water, forest, which will be shared potentially affecting water availability with private SPDs for onward sharing with sub- for the local population, that depends contractors and its workers; on the same resources; An induction session will be organised for the migrant Potential loss of forest resources due workers where they will be sensitized on t to exploitation triggered by influx of labour in the area, thereby affecting the stock available for the local resources; community; Wear and tear of roads may take The contractor shall be asked to use Tanker water supply place due to movement of heavy during the summer months, which are dry months in machinery on the roads, creating which water scarcity issues are reported by the movement problems and risks for community; local road users. Periodic maintenance activities for roads used for transportation of goods for the project shall be the undertaken by RUMSL, through its contractors; Provision of Grievance Redressal Mechanism to all the key stakeholders in order to raise and register their grievance on misuse of locally available resources. Impact on Employment Moderate (Positive) Moderate The construction phase will provide a Enhancement Measures and Entrepreneurship (Positive) boost to the local employment as a opportunities The sourcing of local labour wherever possible should be higher number is expected to be made obligatory by RUMSL (through contractual www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXIX CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) engaged as construction labour provisions) for the Solar Project Developers and sub- during construction phase; contractors and in all major procurement activities; Development of smaller vendors in Preference should be given to the land losers and the area through petty shops, petty vulnerable population in the Project Villages, to the extent contractors, etc. providing essential practicable; goods and services during the Employment of members of SC-STs and Women Headed construction phase; households should be ensured by the Solar Project There will be an impact on local food Developers through documented agreement with basket due to increased demand for contractors/ sub-contractors; agricultural products and food items. Engagement of local vendors, to the extent possible, for the goods and services required for the project during construction phase; The project proponent will establish a mechanism to audit subcontractors and suppliers with respect to compliance of utilizing local labour and resources; Provision of Grievance Redressal Mechanism to all the key stakeholders in order to raise and register their grievance with respect to information sharing related to jobs and opportunities for vendor-ship. Impact on women Potential impacts on women within Moderate Minor households affected by private and A Gender Action Plan is being prepared for the Project patta land procurement, where where women focussed engagement is detailed in women are not land owners: Appendix F; - Women may be potentially Provide alternative arrangements for land, and create affected more severely in such access for ease of use to collect fuelwood, and fodder. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXX CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) households, if they are being rendered Ensure that the employment of women from vulnerable land-less households is done for the project and efforts are made - Risk of gender based violence for development of women owned enterprises in the area, from delayed payments or other land from where procurement for project related needs is ownership based conflicts undertaken; Women Headed households (both Joint as well as independent) may Undertake a profiling of the various social groups in the potentially become more vulnerable in Study Area, to understand the individual needs and cases of sale of land for the project, if concerns of the various women belonging to different land is not in their name, or they do social groups and design community development and not receive the benefits. CSR programmes in light of the same; Women land owners may face additional risks of not being included As part of the stakeholder engagement, RUMSL shall in negotiations, or other key meetings ensure and communicate to the private Solar Project due to prevailing cultural norms and developers, that Women focussed discussions are may not therefore receive the benefits and advantages compared to those conducted in order to ensure adequate representation of who do participate the Women and their needs and concerns in order to Access to jobs during the construction design specific engagement activities; phases generally skews in favour of males, thus preventing women from Include provisions of coverage of women under skill availing project benefits. training and Financial literacy training programs, as part Women and girls are of livelihood restoration activities by the project or through disproportionately at risk in terms of developmental programs of SPDs; safety (gender based violence, harassment, curtailed movement, Provision of Grievance Redressal Mechanism to all the reduced access to resources) during stakeholders in order to raise and register their the construction phase, with the arrival grievances. of migrant labourers in the construction phase and their accommodation being planned near the project villages. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXXI CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) Operations Phase Soil Environment Operation phase will generate small SPD shall prepared SOP for storage and disposal of Minor Minor amount of municipal waste from site broken solar panels and tie up with an authorized office and waste such as broken solar dismantling agency for disposal of panels. MNRE had panels. The hazardous waste prepared a concept note for storage and disposal of used generated at substation include solar panels. The recommendations such as recycling of used/spent oil, oil soaked cotton and glass, storage of discarded panels in cover shed etc. filter waste, waste containers/tins of shall be adopted in the Project; (1) paints, used lead acid batteries, The broken solar panels shall not be mixed with normal nonferrous scrap, insulated glass. aluminium and copper wires/cables, waste dry chemical residues etc. RUMSL shall prepare a waste audit checklist as part of which needs proper storage and their routine site monitoring and auditing plan during disposal. operation phase for monitoring of waste management at site. Improper management of broken panels will cause damage to the A waste management plan is provided in Appendix F of environment. report Water resources and The Jawad Block falls under Critical Major Major to quality category Conserving Water Resources Moderate The utilization of ground water for Dry robotic cleaning of modules to be explored as operation phase of the project may recommended by MNRE (2); compromise with competitive users (drinking water requirement of Alternate sources of water shall be explored villages and irrigation purposes) in the (1) http://164.100.94.214/sites/default/files/webform/notices/DraftBluePrintAntimony.pdf (2) MNRE had issued a letter dated 3 June 2019 to Principal Secretaries of States and Solar Association of all States regarding optimal utilization of water and preferably use Robotic technology for cleaning of modules. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXXII CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) district based on ground water Ground water abstraction shall be done in accordance to availability; CGWB guidelines. Any discharge of waste water from Implement rainwater harvesting and/or groundwater site to waterbodies will impact the recharge and replenishment opportunities within Site water quality of water bodies premises especially near the low-lying and gently sloping area. Optimising water usage in the SCADA building by application of water conservation measures such as sensor based taps, low flush urinals etc.; Maintain logbook for water consumption; Implement groundwater and wastewater monitoring vis-à- vis quality/quantity; Adopt less water consuming module cleaning methods; The surface runoff from during solar panel cleaning shall be diverted to a settlement tank for settlement of suspended solids. The overflow shall be treated in water treatment unit and recycled in the Project. Use of water from multiple sources to avoid dependency on one particular source (groundwater or surface water). This also includes tapping of rainwater received during the monsoons for the long-term and uninterrupted operations. The Project should implement principles of water stewardship to ensure water security not just for the site, www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXXIII CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) but also for other stakeholders within the watershed. Some of the water stewardship frameworks/ standards that can be adopted are UN Global Compact's CEO Water Mandate or AWS Standards. Identify stakeholders directly impacted by the groundwater use at the Project site and develop long- term stakeholder engagement plan particularly focused on stakeholders near site to develop positive perception towards Project and its operations. Rain Water Harvesting Rainwater harvesting pond shall be provided at site. In addition, groundwater recharge shall be undertaken within the Site to replenish the shallow aquifer zones. Piezometers to be installed to monitor the groundwater level changes in the aquifer trapped by the abstraction wells at Project site. Water Quality Ensure proper cover and stacking of loose construction material at site to prevent surface runoff and contamination of receiving water body; Open defecation and random disposal of sewage will be strictly restricted; Planning of toilets, soak pits and septic tanks, waste collection areas away from natural drainage channels; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXXIV CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) Provision of number of toilets across with easily accessible location as the project site is spread across large area of Units; Use of licensed contractors for management and disposal of waste and sludge; Labourers will be given training towards proactive use of designated areas/bins for waste disposal and encouraged for use of toilets; Provision for impervious storage area, especially for fuel & lubricant, hazardous waste, etc. will be made onsite; and Spill/ leakage clearance plan to be adopted for immediate cleaning of spills and leakages. Other Management Aspects Preparing an inventory of water consumption during construction and O&M activities. A water management plan is provided in Appendix F of report Occupational Health and Electrical and mechanical risks during Periodic Health & safety training to be provided to team; Minor Minor to safety O&M activities; Activity specific Hazards Identification and Risk Negligible Fire hazards; Assessment (HIRA) should be conducted and accordingly Contact with the transmission line can SOPs shall be prepared for all O&M activities. result in electrocution; The lock in-lock out system will be followed during At substation location, risks maintenance/ repair activities at substation and associated with transformer blast, Transmission Line; electrical hazards are predicted. Records of incident/ accidents shall be maintained; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXXV CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) Root cause analysis shall be carried out for any incident/ accident All persons performing maintenance/repairing work to wear safety shoes and helmets confirming to national standard; Appropriate safety harnesses and lowering/raising tools should be used for working at heights; All equipment should be turned off and checked when not in use; Emergency contact numbers and route to the nearest hospital to be displayed at the construction site; The local/ host community to be kept at safe distance from construction site; Site specific safety or emergency response plan should be in place to account for natural disasters, accidents and any emergency situations; Provide H&S achievement information to employees Photovoltaic Heat Island PVHI effect are detectable in the day, The existing ground vegetation in the Solar Park area shall be disturbed to minimum extent; Effect the real significant warming occurs in Ground vegetation shall be planted in the buffer areas/open areas available in the Solar Park; the evening hours, partially because these large photovoltaic installations The feasibility of mixed land use development in the Solar Park shall be explored took longer to cool down in the night time hours; The increase in localized temperature may cause discomfort to the habitation and wildlife in the vicinity of Solar Park www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXXVI CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) Flood Likelihood Undertake an assessment to estimate the High Flood Level (HFL) at the Site. This will help in Likelihood of flooding event and its estimation of the risks of flooding and inundation to the Site. Installation of solar panels and other Assessment impact in and around the Site is critical infrastructure above the HFL will greatly reduce disruptions and losses to the Park; evaluated as medium. Enhance structural stability of banks of all seasonal streams which are in close vicinity of the Site units and provide robust erosion protection to withstand flood water; Storm water drains must be designed in line with the natural topography and eventually drain into the natural seasonal streams in the Site area; the natural seasonal streams; Provide sluice/ flap gates at the SWD outfall to prevent backflow during a backflow event; Make provisions for pumping infrastructure within the Site to ensure rapid evacuation of water in case of high flow/backflow associated with ponds and seasonal streams ; Implement an effective flood monitoring and disaster management system in place for effective mitigation of floods at a Site level; Coordinate with the district and local disaster management cells to update on flood early warning notifications. Collision and Electrocution risk occurs when bird Moderate Negligible and bat species roost or nest Restrictions should be imposed so that dead carcasses electrocution risk Transmission Lines and are exposed are not disposed near the Solar Park. The O&M team to the uninsulated electrical should be trained on removing any carcasses found components. There is also a chance around these Project components in a timely manner to of collision with the live electrical line ensure that no vulture or birds of prey are attracted to the components due to the line being not Project site. clearly visible during daytime hours (lack of reflective capacity) and night- RUMSL should maintain a carcass register as part of the time hours (poor light). Operation and Maintenance (O&M) phase to record any The presence of the Solar Park in bird carcasses or suspected bird carcasses. The register close proximity to [Water Body Unit 3] should include a date, type of specie (to the extent can increase the risk of collision and electrocution because the walled identifiable), geographic location and nearest compound and internal Transmission Transmission Line infrastructure for each carcass entry. If Line infrastructure (if overhead lines possible, the register should be backed-up with photo- www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXXVII CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) are close to the boundary wall near documentation of any identified carcasses or remains. If the water body) would be used by the number of carcasses are significant, then RUMSL avifauna for roosting should commissioning an ecologist to suggest more stringent mitigation measures at the sensitive Project components. The O&M team should be instructed to regularly inspect transmission towers as part of their periodic maintenance and rounds of the operational Solar Park. The purpose is to identify any roosting or nesting of bird species. The internal Transmission Line, if any, should be marked with diffractors/diverters at a spacing of 10m apart including bird guards/diverters in low voltage lines/cables. Community health and The Operations phase would have very Where community residential clusters are closer to the Minor Negligible safety limited activity outside the project site as project boundary, keep a safety setback (as relevant) to the construction phase would have been mitigate the heat island effect. over and the scale of activity and Community sensitization sessions should be re-organised workforce at the project footprint area at the beginning of Operations phase, in order to mention would have reduced significantly. This about the new developments in the area and provided an would lead to far fewer impacts: understanding of the precautions to be taken for safety; Less or negligible noise, Fewer workers at site on near project community shall still be in implementation to deal with villages, any concerns of community health and safety, being Reduced traffic load (compared to raised by the local community. construction phase) from the movement of people and goods. Impact on employment The Operations phase would require The private SPDs shall advertise the roles of Technical Minor Minor much smaller workforce as compared staff required during operations phases, in the local to construction phase and the skillset www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXXVIII CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Category Impacts Mitigation Measures Impact Impact Significance Significance (without (post- mitigation mitigation) measure) of the required workforce shall be newspapers to enable hiring of competent people from different. nearby areas, to the extent feasible; The Operations phase would require Preference shall be given (to the extent feasible) to hire Engineers, Technicians to manage competent members from PAHs for semi-skilled jobs like the Plant operations and amongst the housekeeping or Security Guards. requirement of semi-skilled workers in limited numbers for housekeeping and Security related jobs, on the payroll of RUMSL. Additionally, there may be some vacancies with the private Solar Project Developers (SPDs) that may have some local employment, if feasible Impact on women The nature of impacts are envisaged The SPDs shall ensure appropriate measures for hiring of Minor Negligible on women in the Operations phase women, as per required skill set, are put in place, during the will be as following: Operations phases The extent of outsiders and migrant population in the area would have reduced along with risk to their safety; There would be limited requirement of labourers jobs or vendor-ship opportunities in Operations phase, which might render them in search of livelihood options again. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XXXIX CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Analysis of Alternatives An analysis of probable alternatives for the chosen technology and location of Project site along with other similar factors that contribute to the Project as a whole has been carried out. The following scenarios have been taken into consideration: Project vs No Project scenario; Alternate Source for Power Generation; Location for Project Site The selected Project has following advantages: The Project is environment friendly with minimal greenhouse gas emissions; It is the most feasible choice of power generation in the State of Madhya Pradesh; and It will contribute towards the state of Madhya Pradesh attaining self-sufficiency in power supply Site with high solar irradiation; ~ 90% of Land area is government land; Most of the land parcels selected are scrubland with barren rocky surfaces with sparse vegetation; No physical displacement for Project; No ecological sensitive receptor such as National Parks, Wildlife Sanctuary, within 5 km radius; There are no places of Archaeologically Important Places (ASI recognized); There exists no major obstacles around the site in the form of trees, buildings etc. that could lead to near shading; and Site is approachable through State Highway 9A and National Highway (NH) 76 connecting Kota and Chittorgarh. Environmental and Social Management Plan The ESMP identifies potential impacts from the planned activities and outlines mitigation measures required to reduce the likely negative effects on the physical, biological and social environment. This is in accordance to Environmental and Social Management Framework, February, 2017. A separate RAP-LRP document will contain the management plan for resettlement related impacts. The ESMP describes the mitigation measures for all the identified potential impacts associated with the proposed project during its planning, construction and operation phases. 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. The ESMP shall ensure a continuous communication process between RUMSL, EPC contractor, workers (including sub-contractors), local community and other stakeholders. RUMSL have an obligation to ensure compliance to all the commitments towards Environment, Social, Health and Safety Standards while executing all the project related activities for the proposed project. A designated EHS Manager and a Supervisor for overseeing social and community aspects shall be appointed for the project and shall be responsible for implementation of ESMP at site, its monitoring, liaison with local community and reporting. An indicative budget for ESMP implementation and monitoring indicators are also given. As part of ESMP, Project specific management plans have been identified and developed. Following management plans have been developed for the Project: Waste Management Plan; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XL CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report Water Management Plan; Occupational Health and Safety Plan; Disaster Management and Emergency Response Plan; Contractor and Labour Management Plan; Gender Action Plan; and Stakeholder Action Plan Grievance Redressal Mechanism The primary objective of the GRM shall be to provide an accessible mechanism to the stakeholders of the project and resolve any social and environmental related grievances. For this purpose, a Grievance Redressal Cell (GRC) shall be established, to resolve non-judicial disputes arising out of various matters related to the implementation of the ESMP, as well as other aspects of the project, as deemed fit to be raised before the GRC. The GRC will comprise of members from the EPC contractor team, RUMSL, community representatives, members of Gram Panchayat, women representatives. The GRC will be driven internally by the Project team and shall have representation from the following teams to ensure fair and timely solution to the grievances: Site Manager/Project Manager; EHS Officer; Community Relations Officer; Senior representation on behalf of the Project Company; and Any other concerned person with decision making authority in relevance to the grievance or aggrieved party. Formats for recording of grievances and maintaining the grievance records have been provided as part of the report. Conclusion The ESIA has assessed the overall acceptability of environmental and social impacts likely to arise as a result of construction and operation of Neemuch Solar Park. mostly confined to construction phase and site- specific. These impacts include change in land use, stress on ground water resources, increase noise & vibration and air quality, etc. during the site preparation of Solar Park, pooling substations and community health and safety during material transportation. The proposed project will require water for cleaning of solar modules during operation phase. The project area falls under semi-critical category in terms of ground water availability. Water requirement for the project will be met mainly through ground water. Considering the stress on water resources in the area, it is recommended to evaluate alternate sources or plan for dry robotic cleaning. The land footprint of the project is 1065.7 hectares for Solar Park. The social impacts of the project will be higher in the planning and construction phases of the project, where land linked livelihoods will be impacted, there would be an impact on community resources and community health and safety risks, during construction phases and some short term employment will be generated. The Environmental and Social Management Plan (ESMP) describes mitigation measures for impacts specific to Project activities and also discuss implementation mechanism. Project specific management plans are also provided for certain Project activities such as waste management, occupational health & safety, contractor and labour management plan, gender action plan, www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XLI CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS EXECUTIVE SUMMARY Final ESIA Report stakeholder management plan, grievance redressal, etc. This ESIA study together with mitigation measures and follow up of recommendations on management actions will help RUMSL in complying with the environmental standards. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page XLII CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report 1. INTRODUCTION ERM India Pvt. Ltd. (ERM) has been engaged by Rewa Ultra Mega Solar Limited (RUMSL) to undertake an Environmental and Social Impact Assessment (ESIA) of three Solar Parks, including internal evacuation infrastructure and associated transmission lines of aggregate capacity of 1500 MW in the Neemuch, Agar and Shajapur Districts of Madhya Pradesh, India. The ESIA for the aggregate 1500 MW Solar Parks has been divided into four distinct studies: ESIA for Neemuch Solar Park of 500 MW capacity; ESIA for Agar Solar Park of 550 MW capacity; ESIA for Shajapur Solar Park of 450 MW capacity; and ESIA for the external Transmission Line1 infrastructure for all three Solar Parks. This report is the Environmental and Social Impact Assessment study for the Neemuch Solar Park of 500 MW capacity ( ), located at villages Badi, Kawai and Bardawada, District Neemuch in State of Madhya Pradesh. The subsequent Resettlement Action Plan (RAP) report and Indigenous Peoples Plan (IPP) will contain baseline information on the households from the villages falling in the project boundary, as well as the associated impacts. 1.1 Project Background The Government of India has identified the solar power sector as one of the critical components for infrastructure development and overall economic growth. The Government of Madhya Pradesh (GoMP), through the Ministry of New and Renewable Energy (MNRE), is developing ground mounted grid connected solar power projects in Madhya Pradesh. Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10th July 2015 as a 50:50 joint venture (JV) company between Solar Energy Corporation of India Limited (SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL). Its primary objective is to develop and facilitate development of large scale solar power projects in the state of Madhya Pradesh. RUMSL is planning to develop following three Solar Parks and their associated internal evacuation infrastructure and transmission lines: Agar Solar Park of 550 MW capacity Shajapur Solar Park of 450 MW capacity and Neemuch Solar Park of 500 MW capacity RUMSL is in the discussions with World Bank (WB) to provide financial support for the Project. The International Finance Corporation (IFC) is providing investment advisory services to the GoMP to develop the Project on a Public Private Partnership mode and to support the GoMP in meeting its energy requirements and in the process, to meet the (RPO)2 3 and Solar Purchase Obligation (SPO) . 1 The external transmission line infrastructure refers to the power evacuation from the solar park site to the grid substation. 2 Renewable Purchase Obligations (RPOs) refers to the obligation imposed by law on some entities to either buy electricity generated by specific 'green' sources or buy, in lieu of that, renewable energy certificates from the market. The obligated entities are mostly electricity distribution companies and large consumers of powers. 3 Solar Purchase Obligations (SPOs) are state-specific obligations for solar RPOs that have been created as per the National Tariff Policy. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 1 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report Scoping Study An Environmental and Social Scoping Study for the entire 1500 MW Project had been previously undertaken during September 2018- March 2019. The key outcomes of the scoping study relevant to the Neemuch Project site are described below: Local community indic land ((habitation area) used by squatters for residence and livelihood should be excluded from the Project footprint. Local community had raised concerns about the settlement of Bhil families within the Project footprint area i.e. Badi Village, as these communities had been residing on these land parcels for over 30 years; The Project may impact patta land (1), which was reportedly uncultivable at the time of allotment by the GoMP. The community was afraid that the compensation provided for these land parcels may not consider the time, money and effort put into these land parcels to make them cultivable; The groundwater resources in the Neemuch District (Jawad Block) had been categorized as - prepared by the World Resources Institute (WRI) has recognized the area as low groundwater availability and extremely high baseline water stress; The Neemuch site has been identified to fall within a high vulnerable zone for flooding as indicated in the Flood Vulnerability Index developed by Government of India National Remote Sensing Centre (NRSC); Applicability of Free Prior Informed Consent (FPIC) to determine potential impact on private and patta land in Kawai and Badi Village has been identified; and Applicability of Critical Habitat (CH) for the transmission lines from all projects that could potentially affect vulture (Gyps bengalensis, Sacrogyps calvus and Neophron percnopterus) habitat2 has been identified. The defined list of impacts has been revisited during the ESIA study to confirm/validate the scoping study outcome as provided in Section 6. 1.2 Objective and Scope of the Assessment The key objective of this assignment is to conduct an ESIA with a view to identify the critical environmental, ecological and social concerns of the proposed Neemuch Solar Park, including the internal transmission line, and address them as an integral part of Project design. The specific scope of work includes: To assess the existing environment and social status in the study area and area of influence and to identify issues which have potential to adversely impact important environmental, ecological and social features of the Project influence area. Carry out environmental, ecological and social assessment of Solar Park area and potential activities envisaged under the Project including internal evacuation infrastructure and associated transmission lines up to pooling sub-station. Analyse various options available in the site layout and arrangements for ancillary facilities, like water supply, with special reference to sources whether local groundwater or water from distant sources would be used; in case of the latter situation, conveyance facilities will also be analyzed for impacts, drainage, access, etc. to minimize adverse impacts and enhance positive impacts, where feasible. (1) Patta land comprises of land assigned to certain households in the project area by the Government. 2 Note that the Transmission Lines of the projects are being covered in a separate ESIA assessment for all Solar Parks under the aggregate 1500 MW. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 2 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report Conducting labour influx risk assessment with key impacts on local community associated with the temporary influx of labour during construction activities; Based on final land footprint and georeferenced site boundaries of the Project, the ESIA will also include a Resettlement Action Plan (RAP) and a Livelihood Restoration Plan (LRP) with an identification of the Project affected households; assessment of loss of livelihood/ common property resources for affected communities and/or using the proposed site and in its immediate vicinity and also covering transmission line alignment through primary surveys covering all Project affected families/ consultations. Assess impacts on the indigenous/marginalized communities within the site and its influence area. Involve the services of a suitably experienced Indigenous People Expert to assist with the development of the approach and implementation of a Free, Prior, Informed Consent (FPIC) process. The overall principles, engagement process, and criteria for obtaining FPIC should be agreed on with the affected Indigenous People (IP) communities. Therefore, the focus of this task will be on seeking consent from affected IP communities for a draft package of proposed impact mitigation measures and benefits. To undertake consultations with potentially affected people to understand their views/concerns, taking into account perspectives from different social groups, women and men, to obtain their inputs regarding environmental and social issues, and to take these into account during the preparation of the plans that would be executed before the developers start working on the site. To provide technical inputs to the client in establishing the site boundary on-site by integrating the total station outputs (available with client department) with the baseline study output, based on impact avoidance/minimisation in environmental, ecological and socioeconomic terms. To identify the environmental and social issues associated with implementation of Solar Park and develop environmental codes of practices for common activities that need to be followed during various stages, such as planning, construction and operation & maintenance. Preparation of ESIA report, in line with agreed Environment and Social Management Framework (ESMF) already in place for RUMSL. To prepare an Environmental and Social Management Plan (ESMP); Resettlement Action Plan (RAP); Gender Action Plan (GAP) and /or Indigenous Peoples Development Plan (IPDP); Stakeholder Engagement Plan, in line with agreed Environment and Social Management Framework (ESMF) and, Grievance Redress Mechanism for the mitigation/enhancement activities that will be undertaken by RUMSL. The ESMP / RAP /GAP /IPDP will include the description of relevant activities, institutional responsibilities, budgetary allocations, timelines and reporting arrangements for the same. To identify portions of the codes of practice/management framework that need to be integrated with the bidding documents to ensure that the prospective bidders are aware of what all will be required during Project implementation and operation from an environmental, health and safety, as well as social perspective. 1.2.1 Applicable Framework The applicable reference framework for the ESIA study are as follows: Relevant environmental, land labour and other relevant policies, laws, regulations and rules of the state of MP, and the Government of India; World Bank Environmental and Social Framework - Environmental and Social Standards; IFC Performance Standards, 2012; Environmental and Social Management Framework by Ministry of New and Renewable Energy Department, February 2017; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 3 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report IFC/WB General EHS Guidelines and sector specific guidelines for Electric Power Transmission and Distribution; ; and IFC Project Developer's Guide to Utility-scale Solar Photovoltaic Power Plants. 1.3 Approach and Methodology The approach and methodology followed for the ESIA Study has been described in the relevant sections of this report and summarised below. 1.3.1 Kick-off Meeting ERM undertook a kick-off meeting with RUMSL, IFC and WB on 21 October 2019, prior to site reconnaissance visit. A discussion was held with regard to the expectations from this assessment in terms of scope of work, deliverables, timeline and the methodology to be followed for the same. 1.3.2 Desk-based Review ERM undertook a desk-based review of the Project to identify any environmental, social and ecological sensitivities around the Project site. The key sources of information that was reviewed as part of the study has been provided below. Table 1.1 Key sources of information reviewed for the desk-based study S.N. Source 1. Environmental and social scoping study conducted in 2018 for the proposed 1500 MW Solar Park Project 2. Topographic Sheets 450/4 and 450/8 and other mapped data relevant for the site 3. Detailed Project Report for the Project, July 2020 4. Project details provided by RUMSL- Khasra and sub-khasra maps with ownership, 3 June 2020 5. The Project boundary map. layout and Area statement, 3 June 2020 6. Land Allotment letters for government land 1.3.3 Inception Report A site reconnaissance study for the entire 1500 MW Solar Park was undertaken from 22 October 2019 to 25 October 2019. The purpose of the site reconnaissance was to understand the Project setting, associated facilities, confirm discussion outcomes of the kick-off meeting, undertake limited documentation review and conduct onsite discussions with the RUMSL team. Post reconnaissance site visit, an Inception report for the complete 1500 MW Project was prepared and submitted to client. This inception report provided an understanding of the following: An understanding of the Project and Project setting and the associated facilities based on the kick-off meeting, documentation review, discussions with RUMSL and reconnaissance site visit undertaken; The status of ongoing activities related to the Project; Validation of earlier screening and scoping carried out for the ESIA of Solar Parks and Transmission Lines and identification of any changes since previous studies were conducted; The proposed work plan and methodology for next step in assignment including status of other inter- linked Project activities. 1.3.4 Site Visit and Baseline Data Collection An ERM team comprising of environment, biodiversity, hydrology and social experts undertook the site visit during 19- 22 November, 2019, 3-6 December, 19-25 December and 7-9 January, 2020 to www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 4 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report understand the site setting, environmental and social sensitivities, baseline data collection and to identify the relevant local stakeholders. The activities undertaken during the site visits has been summarized below: Identification of key social and environmental risks/receptors in the study area; Understanding of prevailing community engagement processes; Understanding aspects of community health and safety, if any, linked to the proposed Project; Understanding land-based impacts, livelihood impacts, issues of vulnerable groups, cultural heritage issues; Understanding significance of impacts on biodiversity and natural resource management; and Consultations with the local communities and focused group discussions in the vicinity to understand their views and concerns of the Project. Environmental baseline data was collected through primary monitoring and surveys of the study area (5 km distance from Project area) during 19- 25 December 2019. Secondary information through literature surveys was also collected for the study area of the Project. The primary baseline study undertaken included the following. Ambient air quality monitoring at 2 locations within the study area; Ambient noise quality monitoring at 5 locations within the study area; Ground water quality at 3 locations and surface water quality at 2 locations; Soil quality covering different land uses at 5 locations; and Traffic count at 1 location for 24 hours. The details of environmental and social baseline conditions in the study area is provided in Section 4 of this report. Photo-documentation of the site visit has been provided in Appendix A. 1.3.5 Stakeholders Consultation The consultations with various stakeholders during site visit, has been guided by an internal stakeholder engagement strategy developed by ERM, to streamline the communication and messaging, for the ERM teams engaged for various tasks, viz, ESIA, RAP and IPP. During site visit, the team undertook consultations with various stakeholders of the Project. The summary of the stakeholder consultations undertaken for the Project has been provided in Appendix B and a detailed identification and categorization and analysis is provided in Section 5. This will be further updated in RAP, based on the in-depth consultations undertaken as a part of the RAP study. 1.3.6 Impact Assessment Assessment of potential impacts on the various environmental, ecological and social elements due to the Project activities were carried out for this ESIA study. The likely impacts on loss of land, land- based and non-land based livelihoods, vulnerable groups (women, youth etc.), labour, water environment, air environment, biological environment and socio-economic environment has been identified based on the actual and foreseeable events/Project activities. For the impact assessment, wherever necessary, professional judgement, experience and knowledge on similar projects have been used. The extent and potential consequences of the impacts have been compared against applicable standards and guidelines. Mitigation measures have been suggested for each of the identified potential impacts. The detailed Impact Assessment is provided in Section 5 of this report. 1.3.7 Environmental and Social Management Plan The Environmental and Social Management Plan (ESMP) has been developed to include the following: www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 5 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report Introduction of purpose and objectives of the ESMP; Summary of significant adverse impacts and potential risks; Mitigations and control technologies as well as safeguards etc. to minimize adverse impacts on air, water, soil, ecological and socioeconomic environment; Institutional mechanism - roles and responsibilities for ESMP implementation including training of ESMP implementation team; Action Plans for effective control measures to minimize adverse impacts/risks; and Monitoring program for effective implementation of the mitigations and ascertain efficacy of the environmental management and risk control systems in place. 1.3.7.1 Management Plans As part of ESMP, Project specific management plans have been identified and developed. Following management plans have been developed for the Project: Waste Management Plan; Water Management Plan; Occupational Health and Safety Plan; Disaster Management and Emergency Response Plan; Contractor and Labour Management Plan; Gender Action Plan; and Stakeholder Action Plan The Management Plans have been provided in Appendix F of this report. The Resettlement Action Plan and Indigenous People Plan (IPP) will be prepared as separate deliverables. 1.4 Limitations This ESIA report is based on scientific principles and professional judgment applied to facts with resultant subjective interpretations. Professional judgements expressed herein are based on the currently available facts within the limits of the existing data, scope of work, budget and schedule. We make no warranties, express or implied, including, without limitation, warranties as to merchantability or fitness for a particular purpose. In addition, the information provided to the Client in this report is not to be construed as legal advice. The report was prepared with the following limitations: The ESIA report has been prepared based on the site assessment undertaken till 9 January 2020 and information provided until 3 June 2020. The final DPR for this site was received from RUMSL on 9 Sept 2020. All public domain information source also been accessed until 31 August 2020. If there is any change in the site conditions, documented information and/or public domain information post the above cited dates, then the same has not been captured in the report. Solar projects do not require an Environmental Clearance under the EIA Notification, 2006 and as amended. The ESIA has therefore been prepared based on international standards defined in Section 1.2.1. The details pertaining to temporary facilities (batching plants, contractor facilities, labour accommodation and storage yards) were not determined at the time of the ESIA visit. ERM conducted a reconnaissance of environmental, social and ecological sensitivities associated with the entire land parcel being procured for the Project but has not identified any site-specific sensitivities associated with the temporary facilities in absence of their details. The land maps for the Project site were being developed during the course of the ERM site visits and were not finalized, at the time of writing this report. It is understood that the land requirement provided to ERM is subject to change. The identification of environmental, social and ecological www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 6 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report impacts has therefore been identified based solely on the last version of land requirements and site boundary maps received on 3 June 2020. Avoidance criteria used for identifying the final land requirement may also result in changing the type/ significance/ extent/ duration/ magnitude of the assessed impacts. As per the ToR, ESIA study had assessed impacts due to the Project during Construction and Operation phases; There is a water body adjacent to Unit 3 in South East direction. As per land allotment letters, this area is not allotted for the Project and Khasra no. 921, Village Badi does not have any water body in on this land. Same is also verified by Revenue Department. However, the drone imagery and related GIS maps shows this water body within Khasra no. 921. This is possibly due to some distortions and overlaps in the overlaying of data layers in the maps. After discussion with RUMSL, the water body is not considered within the Project boundary for impact assessment, though the maps used in the report show it with in boundary. The GIS maps will be revised by the SPPD or its contractors prior to construction, as part of the confirmation survey. 1.4.1 Uses of the Report ERM is not engaged in consulting or reporting for the purpose of advertising, sales promotion, or endorsement of any client interests, including raising investment capital, recommending investment decisions, or other publicity purposes. Client acknowledges that none of its advertising, sales promotion, or other publicity matter containing information obtained from this assessment and report will mention or imply the name of ERM. Nothing contained in this report shall be construed as a warranty or affirmation by ERM that the site and property described in the report are suitable collateral for any loan or that acquisition of such property by any lender through foreclosure proceedings or otherwise will not expose the lender to potential environmental or social liability. 1.5 Structure of the Report The structure of this ESIA report (as defined in ESMF) is given in Table 1.2. Table 1.2 Structure of the report Section Title Description Executive Summary Section 1 Introduction (this section) Introduction to the Project and ESIA methodology Section 2 Project Description Technical description of the Project & related infrastructure and activities Section 3 Policy, Legal and Institutional Discussion of the applicable environmental and social Framework regulatory framework and its relevance for the Project. Section 4 Environmental and Social An outline of the Environmental, Social and flora & fauna Baseline baseline status in the area of the Project. Section 5 Stakeholder Identification, Identification and engagement with the key stakeholders, Information disclosure, in order to assess the impact of the Project on them and Consultation and Participation their influence on the Project. Section 6 Environmental and Social This section includes details of identified environmental Impacts impacts and associated risks due to Project activities, assessment of significance of impacts and presents mitigation measures for minimizing and /or offsetting adverse impacts identified. Section 7 Analysis of Alternatives This sections provides an analysis of alternatives considered for the project w.r.t to location, technology etc. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 7 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report Section Title Description Section 8 Environmental and Social Outline of the Environmental and Social Management Management Plan Plan (ESMP) taking into account identified impacts and planned mitigation measures and monitoring requirements. This section also includes details of institutional arrangements for the Project, monitoring and reporting indicators for performance of ESMP and budgetary allocation. Section 9 Grievance Redressal This section provides the grievance redressal mechanism Mechanism proposed for the Project. Section 10 Conclusion This section summarize the conclusion of ESIA study Section 11 References - Appendices Appendix A Photo- Documentation Appendix B Details of Consultations undertaken during Neemuch ESIA preparation Appendix C Note on Land Requirement and Procurement Process Appendix D Environmental Monitoring Results Appendix E Flood Likelihood Assessment Appendix F ESMP- Management Plans www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 8 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report 2. PROJECT DESCRIPTION This section provides an overview of the proposed Project in terms of location, Project components and associated infrastructure, resource requirements, land requirement and activities to be performed during the construction and operation stages of the project. A brief description of the Project is given in Table 2.1. Table 2.1 Brief Description of Project S. No. Particulars Description 1. Project Village location Badi, Kawai and Bardawada 2. Tehsil Singoli 3. District Name/State Neemuch / Madhya Pradesh 4. Location Coordinates Latitude: 24°59'39.78"N and 25° 0'38.51"N Longitude: 75°13'26.82"E and 75°14'48.53"E 5. Capacity Unit 1: 160 MW Unit 2: 170 MW Unit 3: 170 MW 6. Pooling Stations and Three Pooling substations of 33/220 kV (PSS), one in each Unit; Power Evacuation Power evacuation through proposed 220/400 kV ISTS substation of PGCIL at Badi village located in north of Project site in between Unit 2 and 3. 7. Climatic zone Agro-climatic 8. Average Elevation Elevation ranges from 396 to 440 m amsl High gradient land area (>7o): Nil 9. Site Conditions Agricultural land, scrub land 10. Road Accessibility SH 9A (Bhilwara to Modak) is between 1 to 2.5 km south of the southern boundaries of Neemuch Project site. The individual units of the Project is connected through existing village roads 11. Roads crossing Village roads Project site 12. Nearest Airport Udaipur Airport (~140 km, WSW) 13. Nearest Railway Mandalgarh, Rajasthan ~ 25 Km (N) station 15. River/ pond present in Nil project footprint (refer Section 1.4) 16. Number of Power line 2 Transmission Line of 400 kVA and 220 kVA respectively. (66 KV and above) present in Project footprint 17. Protected areas The closest legally protected area (National Park or Wildlife Sanctuary) is Gandhi Sagar Wildlife Sanctuary located ~ 50 Km southeast of Unit 3; and (National Park/ The closest forest land is Arnea Reserve Forest block located 300m north of Sanctuary)/ Forest Unit 2 land 18. Land Area Total: 1065.7 hectares 19. Water Requirement Construction Phase: 250-300 KLD for civil works and 80-100 KLD for domestic use of labour at site; and Operation Phase: 308 KLD for solar panel cleaning; 10 KLD domestic water; 7 KLD for green belt maintenance; 32 KL for firefighting and miscellaneous 20. Source of Water Construction: Tanker water Operation: Ground water www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 9 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report S. No. Particulars Description 21. DG sets For backup power requirement during construction phase; No. and capacity yet to be determined. 22. Soil Characteristics Loamy sand Project area 23. Seismic Zone Zone II (Low damage risk zone) 24. Flood prone zone High vulnerable zone 25. Wind zone High Damage Risk Zone Source: RUMSL, DPR July 2020, site visit and secondary literature; land data taken from Area statement sheet shared by RUMSL in June 2020 2.1 Project Location The proposed 500 MW Solar Park is proposed to be developed on 1065.7 Ha of land area spread across three villages namely, Badi, Kawai and Bardawada of Singoli Tehsil of Neemuch District in the state of Madhya Pradesh. The Solar Park is divided into three units (Unit 1, Unit 2 and Unit 3) and lies between 24°59'39.78"N and 25° 0'38.51"N latitude and 75°13'26.82"E and 75°14'48.53"E longitude. Nearest village is Badi village located adjacent to Unit 2. Kawai village is present at a distance of ~ 450 m (W) from Unit 1. Site is located near Madhya Pradesh (MP) and Rajasthan border (~1.5 km aerial distance from Unit 1 and Unit 3). Neemuch town is present at an aerial distance of ~ 70 km in south-west direction. Mandalgarh, Rajasthan is the nearest railway station located at a distance of ~ 25 km (N) and the Udaipur Maharana Pratap airport is the nearest airport at a distance of ~ 140 km (SW) from the Project site. The Project is connected through State Highway (SH) - 9A (Bhilwara to Modak) and followed by village roads. National Highway (NH) 76 connecting Kota and Chittorgarh is at a distance of ~ 7 km from the site. The project site location map is presented as Figure 2.1 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 10 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report Figure 2.1 Project Site Location www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 11 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report Site Setting The Project site lies between 24°59'39.78"N and 25° 0'38.51"N latitudes and 75°13'26.82"E and 75°14'48.53"E longitudes. Proposed project site is mostly flat and irregular in shape with elevation ranging from 396 to 440 m amsl. The site is primarily scrub land (used by local communities as grazing land for their livestock), part of the land is used for agriculture (in terms of ownership, agriculture is practised on private land patta land, by holders on encroached or squatted upon land). The proposed site also contains some structures of religious significance, structures /infrastructure for irrigation- bore wells, water channels and boundary walls made of stone slabs, the details of which are presented in Section 4.4. There is no natural water body in the proposed Project site. A water body is present adjacent to Unit 3 in South- East direction. As reported this water body serves the purpose of recharging groundwater aquifers and irrigation. Other similar manmade lakes present in the study area include Kawai Lake and Arnya Lake at a distance of ~ 700 m from unit 2 (west), and ~ 3 km (north-west of Unit 1) respectively. Proposed Project site has number of dug wells in all the three Units. River Brahmani flows in South of the proposed site at a distance of ~ 2 km. Rana Pratap Sagar Reservoir is present at an aerial distance of ~32 km towards South-East. Two transmission lines, 400 kV and 220 kV are present in the Southern and South East portion of Project site passing across few of the land parcels of the proposed Project. 400 kV transmission line passes through all the three Units however 220 kV transmission line passes through Unit 1. There are no places of archaeological importance within the study area. There are no National Parks/ Wild Life Sanctuaries within 5 km radius. The Arnea Reserve Forest block is present within 5 km radius of the proposed site towards North. The site photographs are shown in Figure 2.2. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 12 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report Figure 2.2 Photographs of Project Site and Surroundings View of Unit 1 View of Unit 2 View of Unit 3 Kuccha road in Unit 3 View of Water Body adjacent to Unit 3 in SE direction View of village road in the Project area Source: ERM Site Visit 2.2 Overview of the Project The Neemuch Solar Park of capacity 500 MW is proposed to have three units, Unit 1- 160 MW, Unit 2- 170 MW and Unit 3- 170 MW. Each Unit land parcel will be designed in consideration of MNRE guidelines. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 13 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report 2.2.1 Project Components The project is in the planning phase and comprehensive technical details pertaining to project components (including make, model and number) of the PV modules, inverters, transformers are yet to be finalized. As per Detailed Project Report (DPR), July 2020, solar module and inverter as described below are proposed. Solar PV Modules - Solar PV Modules based on Poly/Mono Crystalline and/or Thin Film (CdTe) technologies of different rated capacities with fixed tilt and single axis tracking Module mounting structure are proposed to be installed. Power Conditioning Unit (PCU) or Inverter - ABB make Inverter of 1000 kW rating is proposed to be installed. This would be finalized by SPD. Cables - The cable rack method is envisaged to be adopted by Solar Project Developers to connect plant to 33 kV outdoor air insulated substation for the solar projects because of increased internal grid availability, low cost, lower losses and no impact of shading on generation etc. Main Control Room Infrastructure - The control rooms are envisaged at the pooling substation. This will have the facility for gathering data on monitoring, forecasting, scheduling and dispatching for the submission to the load dispatch center. The Main Control Building has been proposed to have the Switchgear Room, SCADA/ Control Room, telecommunication infrastructure, Battery/ Auxiliary Room apart from rooms for staff, supervisor and administrative purposes, one Pantry along with Toilets, Stores etc. Air conditioning shall be provided in the SCADA/ Control Room and Heat Ventilation System shall be provided in the Switchgear Room, Auxiliary Room, Battery Room and Toilets. The entire building shall be provided with fire protection and detection system. 2.2.2 Associated Facilities 2.2.2.1 Evacuation Infrastructure Pooling Substations (PSS) RUMSL plans to develop three 33/220 kV Pooling Substations (PSS), with one PSS at each individual unit. The Solar Project developer will be responsible to connect plant to 33/220 kV Pooling Substation through appropriate 33 kV cable arrangement. ISTS Substation The power generated from the Solar Park will be evacuated through the proposed 220/400 kV ISTS substation of PGCIL (Power Grid Corporation of India Limited) planned in Badi village, north of the Project site. The connection of internal pooling substation and grid substation will be established through proposed 220 kV single circuit transmission line. Transmission Line It is proposed to erect Transmission Lines from Unit 2 (length-2.2 km) and Unit 3 (length-2,55 km) PSS connecting to PGCIL ISTS station. There will be a Transmission Line of length 2.2 km interconnecting Unit 1 PSS to Unit 2 PSS. Total length of Transmission Line will be approximate 8 km. The route of Transmission Line is under planning and not yet finalised. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 14 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report Note: Environmental and Social impacts of Transmission Lines will be assessed as separate ESIA study. Power evacuation arrangement for the project is as presented in Figure 2.3 below. Figure 2.3 Power Evacuation Arrangement Source: RUMSL, August 2020 2.2.2.2 Access and Internal Roads (Source: DPR, July, 2020) The access to the all the three parcels of land shall be through the road connecting to the Bhilwara Modak road (nearest state highway). The existing road from this state highway is a single lane village road having width of ~4 to 5 meter. However for Solar Park utility, during the construction stage, heavy equipment such as transformer, SS equipment, containers of solar panel in huge quantity etc. would be required to be transferred to the site. This would require the strengthening and widening of the existing road. The access road shall be provided as follows:- Access to Unit 1 substation- It is proposed to develop a bituminous road of width 7.5 meter including 500 mm shouldering on both the sides having estimated length of 5.5 km. Access to Unit 2 & 3 substations- It is proposed to develop a single lane bituminous road of width 7.5 m including 500 mm shouldering on both the sides having estimated total length of 10 km (Unit 1:- 2.1 km, Unit 2:-4.7 km and Unit 3:- 3.2 km) The total length of road infrastructure to be developed is estimated as 15.5 km (Primary road connecting providing the main access, 5.5 km and Secondary road of width 7.5 m is 10 km). The internal roads of each unit shall be designed & developed by the respective unit Developers. The widening/ strengthening of access roads will be done by RUMSL. 2.2.2.3 Green Belt A Greenbelt is proposed to be developed close to utility area and near fencing & boundaries by SPD. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 15 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report 2.2.2.4 Common Facilities The utility area is proposed near the internal pooling substation located at the Unit 3, adjacent to the 33/220 kV pooling substation. Facilities proposed to be provided at Neemuch Solar Park includes street lighting, drainage, RUMSL office building, firefighting, telecommunication infrastructure, sewage, medical dispensary, weather monitoring station, etc. Temporary labour camps shall be set up within the boundary of the land identified for the project during the construction phase of the Solar Park, which is expected to be around 21 months. At present no additional need for external labour camps has been identified. 2.3 Summary of Project Activities Key project activities during different phases of the Project have been summarised below: 2.3.1 Planning and Pre-Construction Phase The planning phase includes the following components: Identification of land area and site; Site surveys as topographic, geo-technical investigations, solar radiation and yield study, electrical grid studies, etc.; Obtaining all necessary approvals/clearances; Land procurement; Selection of Solar Project Developers (SPDs); and Appointment of contractors. Identification and land procurement is a key component of the planning and pre-construction phase. The process of land procurement can be divided into following (a) Land survey and final land area demarcation; (b) Land title verification; (c) Land compensation; and (d) Land procurement. The land survey and final demarcation of land footprint was under process at the time of assessment and shall be handed over to the SPPD. 2.3.2 Construction Phase Construction phase of project activities will include the following: Contractor mobilization; Establishment of labour camps; Site Preparation including fencing, clearing of bushes, pit filling, levelling and grading; Construction of site office and internal roads; Construction of temporary storage facilities; Foundation laying for ground mounted structures; Storage of PV modules delivery and their installation; Laying of internal electrical cables; and Construction of sub-station and office buildings. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 16 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report 2.3.3 Operation and Maintenance The list of activities to be carried out in the operation and maintenance phase would be: Routine cleaning of PV modules; Control of vegetation viz. weeds, bushes etc. within the site and those immediately surrounding it; Routine inspection of all PV modules and associated structures viz. cables, transformers, inverters, mounting structures etc.; Operation and maintenance of pooling substation; and Inspection and maintenance of internal site pathways/access roads. The Project proposes to have a dedicated operations and maintenance (O&M) team comprising of technical staff to conduct the aforesaid maintenance activities. This will also require additional resources in the form of water (for module cleaning), consumable spares and insurance. 2.4 Resource Requirement As mentioned above, the proposed project is in early stage of planning, details on the resources such as raw materials, man power requirement, definite water sources, power supply and backup etc. are not yet decided. Hence, a tentative estimation of these resources are given in subsequent sections. 2.4.1 Raw Materials 2.4.1.1 Construction Phase The major raw materials for the Project include cement, aggregates, sand, electrical installations, capacitors, stringing wires, transformers, transmission tower components such as steel tower structure, circuit plates etc. As informed, construction materials such cement, aggregates, sand etc. will be procured from local market. The project specific components will be purchased from selected vendors via procurement tendering process. 2.4.1.2 Operation Phase There will not be any major raw material required during operation except for repair and maintenance purpose viz. consumable spares. 2.4.2 Water Requirement 2.4.2.1 Construction Phase Based on industry practices, it is estimated that approximately 250 - 300 KLD of water would be required for civil works during peak construction stage. Water will also be required for domestic use by workers at Project site. Considering average worker requirement of 500-600 workers, daily water requirement is estimated as 80- 100 KLD including labour camp. The water requirement will be met through tanker water supply. Bottled water will be used for drinking purpose. 2.4.2.2 Operation Phase The water required during operation phase of the Project will be mainly for washing of solar modules. Apart from the module cleaning, water will be required for the other purposes such as domestic use for manpower deployed at site, green belt, firefighting, etc. As per DPR July 2020, total workforce during operation phase is estimated to be 225. Total water requirement is estimated as 357 KLD (~360 KLD) and described below www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 17 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report ~308 KLD for solar panel cleaning, assuming 2.5 litres per sq.m for panel cleaning and considering 12 cleaning cycles per year; 10 KLD domestic water, assuming 225 no. of O&M staff and 45 LPCD; 7 KLD for green belt maintenance (as per DPR); 32 KL for firefighting and miscellaneous Water requirements for the Solar Park is proposed to be met by bore-wells within each unit after the approval of CGWA/CGWB and from nearby surface water bodies. 2.4.3 Power Requirement 2.4.3.1 Construction Phase Construction Power shall be met through individual D.G. sets for each unit. 2.4.3.2 Operation Phase Based on initial assumptions, power requirement during daytime would be met through auxiliary generation. During the night time power requirement would be met through the grid as per applicable regulations. DG sets would also be kept at the control room for emergency power backup. 2.4.4 Fire Safety and Security 2.4.4.1 Construction Phase Appropriate firefighting system and equipment shall be provided throughout the construction period. The fire extinguishers will be placed at all strategic locations such as site office, storage yard, near construction area, welding area, etc. Besides this, emergency contact numbers shall also be displayed onsite. 2.4.4.2 Operation Phase The Solar Park shall be equipped with suitable Fire Protection and Fighting Systems for all common infrastructure and Pooling Sub-station as per the National Fire Protection Association (NFPA) and CEA Fire Safety Standards and requirements of Government of Madhya Pradesh. Following firefighting protection system are proposed: Portable Fire Extinguishers of DCP, CO2, Foam type. Fire Buckets, painted red with additional handle at the bottom with fine sand and fixed on an angle iron frame as per requirement of Local Authorities. Automatic Fire Detection cum Alarm System in the Switchyard, Main Control Building and Administration Building. Fire Detection and Alarm System integrated with required cabling to a single Fire Alarm Control Panel with long range audible alarm facility. Manual Call Points and Hooters integrated with the Fire Alarm Control Panel in the respective Control Rooms. 2.4.5 Manpower Requirement Currently, manpower requirement for construction, labour camp requirement etc., are under planning stage. It is estimated that average 500-600 workers will be deployed on site. During the operation phase, approximately 165 technicians would be deployed at site. Apart from these, project will also deploy housekeeping and security guards. Total work force during operation phase is estimated to be ~225. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 18 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report 2.4.5.1 Labour Accommodation As reported by RUMSL, during construction phase, labour accommodation will be provided by SPD within the Solar Park site area. According to RUMSL, t Accommodation shall be followed during establishment of the labour camp for the project. Box 2.1 - Summary Living facilities shall be located to avoid flooding and other natural hazards. Where possible, living facilities are located within a reasonable distance from the worksite; Transport from the living facilities to worksite is safe and free; The living facilities shall be built with adequate materials, kept in good repair and kept clean and free from rubbish and other refuse; The building site shall be adequately drained to avoid the accumulation of stagnant water; Heating, air-conditioning and ventilation should be appropriate for the climatic conditions; Access to an adequate and convenient supply of free potable water shall be always available. Drinking water shall meets national/local or WHO drinking water standards; Wastewater, sewage, food and any other waste materials shall be adequately discharged, in compliance with local or World Bank standards; Specific containers for rubbish collection shall be provided and emptied on a regular basis; Rooms/dormitories shall be kept in good condition, aired and cleaned at regular intervals; - voided; Sanitary facilities shall be provided separately for men and women. Sanitary and toilet facilities shall be constructed of materials that are easily cleanable; An adequate number of toilets, facilities for washing and bathing shall be provided to workers; Canteen, cooking and laundry facilities shall be kept in a clean and sanitary condition. If workers can cook their own meals, kitchen space is provided separate from sleeping areas; An adequate number of staff/workers shall be trained to provide first aid; In addition, National/State/Local guidelines shall be followed amid of COVID Pandemic 2.5 Land Requirement and Allotment Process The key land requirements for the project pertain to the permanent land requirement for the Solar Parks, the tower footing for the transmission lines; the land use restrictions within the RoW and the temporary land requirements (if not located within the identified project footprint) during the construction phase. Table 2.2 provides the summary of the land requirement for all the three units of the project based on the information available. The discussion on the existing land use in the villages within which the project is situated and the potential dependence of communities on the land identified is discussed in Sections 4.4.6 and 4.4.7. 2.5.1 Land Details The Neemuch Solar Park will be spread across three villages in Singoli Tehsil, Neemuch District. The land required for 500 MW Solar Park including solar fields, roads, and transmission and distribution network is 1065.7 hectares (including 21.4 hectares of private land and 81.7 hectares patta land). The Neemuch Solar Park plot comprises of three proximate but non-contiguous land parcels. The three categories of the land in terms of their ownership (Government Land, Private Land and Patta Land) are detailed in the table below. Private Land Private Land is largely the land owned by the local population ancestrally and the ownership is backed by land documents in the name of the owners; Patta Land Patta land comprises of land assigned to certain (at the time) landless households in the project area by the State Government. The understanding of allotment of land under a particular scheme or to specific groups of community is not documented; however, it is understood that households from landless and constitutionally recognised socio- economic backward communities (SCs and STs) have been assigned the Patta Land by the GoMP. This land cannot be sold as per www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 19 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report conditions of the patta though special circumstances may be considered by the District Collector, who can allow its sale. This land can be purchased by the Government under the MP Mutual Consent Land Purchase Policy. Government Land Government Land is the land under ownership of Government but is not necessarily under use by the Government. This land types comprises the majority in the identified land parcel for the project; however it is reportedly being used for cultivation by local community as encroachers and for livestock grazing. The following table provides a summary of the land requirement by village and land category. Table 2.2 Neemuch- Village Wise Land Allotment details Land Category Unit 1 (ha.) Unit 2-(ha.) Unit 3 Total land (ha.) (Hectare) Bardawada Kawai Kawai Badi Badi Government Land 201.8 89.6 156. 1 163.2 351.7 962. 5 (both NRED allotted & identified) Private Land 5.1 4.2 0 1.7 10.4 21.4 Patta Land 50.7 0 22.4 3.6 5 81.7 Sum 351.5 347 367 1065.7 Source: Land Data provided by RUMSL, 3 June 2020 The private land comprises of 2 percent land of Solar Park, whereas Patta land comprises 7.6 percent of the total land identified for Neemuch Solar Park. As part of the latest update, the total land parcel being considered for the Neemuch Solar Park is 1065.7 ha after feasible avoidance of land being used for agriculture, habitation, structures and access spaces/ routes, etc. Some portion of the government land identified for the Neemuch Solar Park, though classified as government land is currently (informa however this use/status is not indicated in the land records. The government land identified in the villages consists of land classified as Charnoi, Charagah, Kamdal, Germumkin, Danta and Kavil Kast1. The land identified for the project is approximately 1092.7 ha. which is higher than the actual land requirement for the project (as presented in Table 2.3). The Table 2.3 presents the beak up of private and patta land owners identified for the project land; such that 35.5 ha private land belongs to 48 private land owners and 73 patta holders possess 87.7 ha patta land. Out of the total land identified for the project, only 1065.7 ha land will be used and there is a chance that not all of the land owners identified below will be affected; however the detail of the exact numbers are not known yet. Table 2.3 Ownership details of Private & Patta land identified for the project Villages Bardawada Kawai Badi Total Private Land (ha) 5.1 13.9 16.5 35.5 Patta Land (ha) 50.7 26.2 10.8 87.7 Total Land 55.8 40.1 27.3 123.2 Private land owners (No.) 6 12 30 48 Patta Land Owners (No.) 43 22 8 73 Total Land Owners 49 34 38 121 Source: Land Data provided by RUMSL, 3 June 2020 As per the data provided there are 6 female private land owners and 12 female Patta land owners out of 48 private land owners and 73 Patta land holders. Out of the private and patta land identified for the 1 According to the discussions with the Revenue department officials conducted in 2018 (scoping stage), these land categories pertain to land classified for community use such as grazing, fire wood collection etc. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 20 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report project, the combined ownership by women (Private +Patta land) is 5.2% in Badi village, while 26.4% in Kawai and 14.2% Bardawada villages. 2.5.2 Land Procurement Process The land procurement process for the Solar Park commenced in 2016-17, where RUMSL identified potential land parcels, with large chunks of unused government land. This was driven by the intent to use Government land for the project to the extent possible and minimize the use of Private or Patta lands. The land identification was followed by screening and scoping exercises, in order to identify the possible exclusions and avoidances on the identified land, comprising avoiding certain settlements/ clusters of structures, potential Bhil settlements, etc. Based on the recommendations from the scoping exercise, another drone survey of the identified land parcels was undertaken, to further optimize the land requirement in a manner, that impacts to private and patta land owners and associated livelihoods are minimized. The details of the land identification, screening, scoping and optimization process are presented in Appendix C along with description of next steps to be taken during land procurement. The section below outlines the brief procurement process to be followed for each type of land identified in the project area. 2.5.2.1 Process for procurement of Government Land A Land Use Permission Agreement (LUPA) will be signed between New and Renewable Energy Department, Government of MP and RUMSL for the life of the project. The duration of construction phase will be incorporated in the project life to ensure that the LUPA is for a period of 25 years from the day of commissioning. M/S RUMSL will sign the LUPA with the Govt. of Madhya Pradesh for the Government land. The transfer of rights is undertaken once the allotment is finalized and approved by the Superintendent of Land Records (SLR) of the district. Subsequently, M/S RUMSL will have a back-to-back Land Use Permission Agreement with the Solar Project developers, which would enable them to use the land for development of solar project as per the agreed terms of the LUPA. 2.5.2.2 Process for procurement of Private and Patta Land The private land for the project shall be purchased as per prevailing laws and policies in the State of Madhya Pradesh (through MP Mutual Consent Land Purchase Policy dated 14 November, 2014. M/S RUMSL will have the ownership of the land and sign the sub lease agreements with the Solar Project developer for a period of 25 years from the commissioning date, which is the anticipated life of the project. The broad steps under the MP Mutual Consent Land Purchase Policy 2014, are given below: The Designated official from the Department/ Enterprise (in this case RUMSL) will submit an application to the collector for the purchase of the land as per the MP Mutual Consent Land Purchase policy 2014. RUMSL to undertake land survey and demarcate the land to be acquired and submit the information to the District Collector for verification; The application would include the following particulars: - - Area of the land proposed to be purchased; - Details of budget availability with the Department/ Enterprise for the purpose of land purchase for the project, as assessed, based on the Policy; - Land details (survey number, plot number, nazool sheet number, area, village, tehsil and map) - Land owner details; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 21 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report - Estimated land value based on the prevailing market rates, also known as the Collector Guideline Rate; - Estimated value of the assets available on the land - Any other details which Department/ Enterprise would like to provide; In case of land requirement for the purpose of the infrastructure and development projects of various projects and enterprises of the state government, the collector will firstly allocate suitable government land available as per the established rules. The District Collector (DC) identifies private land parcels (only after government land options have been exhausted); Private land to be identified and shortlisted. The rate for the same to be decided, based on the The District Collector after receiving the application from the concerned department/ enterprise: - Will require the Tehsildar to submit a report ascertaining claims over the land and whether the land title is clear or not. A team from the district and the tehsil visit the parcel and undertake an inventory of the assets thereon; - The District Collector will also ask the concerned departments (Forest, horticulture, Public work s dep to measure the assets, as relevant (house, well, trees boundary wall, etc.) and undertake the valuation of the assets. - As per the guideline, the land value (double the district level official market rate which is technically known as the Collector Guideline Rate plus a one-time Solatium) and the asset value (double the value of the asset assessment) will together form the final value to be offered to the sellers After verification of land use of the private land parcels, if the DC feels that the land is suitable for owner which has the proposed price. After being notified through the Bhoomi Kray Prastav (prastav), the landowner has 15 days to provide consent. This timeline can however be extended by the DC as per need. In addition to providing the (first) consent, the land owner will also need to provide an undertaking that the land is free of any litigations and/or encumbrances (sahmati patra); and in case there are encumbrances or other claims, the land owner will provide all the necessary details to the DC. After the undertaking has been received from all landowners, the DC to publish a Public Notification to raise any concern, within a timeline of fifteen (15) days from the date of publication of notification. The publication to be published in a local newspaper, and available with the Panchayat or an equivalent village level administration office, Tehsil office and the District If any objection is received regarding ownership disputes of the identified land (defective title), or regarding the compensation amount, the land procurement would not proceed. In case of no objections are received, the DC will allow the land purchase to proceed; After seeking land owner and public consent, the payment of the consideration amount to the land seller should be completed within one year from the date of consent provided by the landowner. Any expenses pertaining to the land registration such as stamp duty, registration cost will be borne by the concerned government Department/ Agency; After the registration, the Mutation process (to update the land records) will be completed in the name of the MP government and the name of the concerned department/ agency will also be mentioned; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 22 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report In case the proposed project for which the land is purchased fails or does not move forward for any reason, the concerned Department/ Agency will transfer this land to the Revenue Department, and Revenue Department will be free to give it for any other project, as required. Any Government land given on patta for agriculture by the Government will be treated like private land for the purpose of seeking consent and payment of the purchase price to the patta holder. The required private land for the Project M/S RUMSL will hold ownership of all such private land parcels and sign sub-lease agreements with Solar Project Developers. RUMSL intends to procure all private and patta land through the MP Mutual Consent based Land Purchase Policy. The RFCTLARR 2013 Act may only be used for land parcels that do not have clear titles, or have ownership related disputes. Any additional private land, if required for temporary use outside the project footprint, during the construction phase will be taken on lease based on negotiations with landowners. However, no such need for temporary land has been assessed, as RUMSL intends to use the land within the project boundary for all temporary requirements, such as temporary labour camps, lay down and storage areas etc., during the construction phase. According to the discussion with the project team, to the extent possible, the temporary land requirement for the construction phase will be accommodated within the identified project footprint. The land area and land boundaries finalised during this stage will be further assessed as part of RAP and FPIC resource mapping surveys, in terms of extent of economic losses, confirmation on the number and types of Project affected families (General, SC, ST, Women Headed Households, etc.), nature of impacts and whether landlessness is arising out of the land procurement for the project. 2.6 Pollution Stream Pollution streams during construction and operation phase of Solar Park will include air emissions, noise generation, wastewater generation and solid waste generation. 2.6.1 Solid Waste Generation 2.6.1.1 Construction Phase The solid waste generated by the Project will consist of domestic solid waste, packaging waste, metal scrap and construction debris. The main types of waste that would likely be generated and its sources are shown in Table 2.4. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 23 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report Table 2.4 Waste generated, source of waste and method of disposal to be adopted for the Project S. Waste Type Source Method of disposal No Non-Hazardous Waste 1. Domestic solid waste Temporary site office, storage Waste shall be segregated onsite and area, labour activities shall be disposed of as approved by local authority. 2. Construction debris Construction activities within Excavated materials shall be used for Solar Park including construction backfilling and levelling and other of access road, substation, construction debris shall be used for storage yard etc. road construction. 3. Packaging waste Packaging material from solar Return back to the supplier or used as containing wood, panels, cables and accessories storage boxes/ racks at site. cardboard and other recyclables. 4. Sludge from Septic Tank Site Office and labour camp Collected and disposed off through contractors. 5. All non-recyclables waste Construction activities Collected and disposed off by the contractor at designated municipal landfill site. 6 Plastic waste Packaging material Shall be collected and disposed of through recycler 7 Biomedical waste First aid kits kept at construction Shall be collected, transported and site and site office disposed through an authorised agency as prescribed in Bio-Medical Waste (Management and Handling) Rules 2016, as amended. 8 Broken solar panels and Solar Park, PSS and Site Office Shall be sent back to vendor as a buy back arrangement other electronics waste (E waste) 9 Batteries Solar Park, PSS and Site Office Batteries shall be disposed through manufacturer under the buy-back arrangement. Hazardous Waste 1. Used oil/waste oil, DG set, construction machinery Hazardous wastes shall be stored lubricants and oil onsite at separate designated covered contaminated rags area provided with impervious flooring and secondary containment. The storage containers/ bins/ drum will be clearly marked and identified for their hazards. Before completion of 90 days, hazardous waste materials shall be sent to MPPCB/CPCB authorised vendor for eventual disposal at the Common Hazardous Waste Treatment, Storage and Disposal Facility (CHWTSDF). The www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 24 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report S. Waste Type Source Method of disposal No nearest CHWTSDF facility is located in Pithampura, ~ 300 km away from the site. 2.6.1.2 Operation Phase Waste expected to be generated during operation phase from the Project will include domestic waste at site office, scrap materials like scrap tools, damaged personal protective equipment (PPEs) etc.; hazardous waste like waste oil, lubricants, used transformer oil; damaged batteries; damaged PV modules etc. Main types of waste generation and its disposal is as presented in table below. Table 2.5 Waste Management during Operation Phase S. No Waste Type Source Method of Disposal Non Hazardous Waste 1 Site Office Will be disposed of through local municipal corporation Domestic solid waste and office waste 2 Site Office Will be disposed of with the help of authorised scrap dealer Metal Scrap and PSS 3 Site Office Through authorised vendor Damaged PPEs and PSS Hazardous Waste 4 Used oil/waste oil, Maintenance stored temporarily onsite at separate designated covered lubricants and oil activities atarea provided with impervious flooring and secondary contaminated rags site containment and will be disposed in accordance with Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, as amended 5 Broken solar panels, Site office and will be sent back to the vendor as part of buyback batteries (dry type or wet PSS arrangement type), electronics 2.6.2 Air Emissions 2.6.2.1 Construction Phase There will be impact on air quality due to onsite construction activities. The likely emissions from construction activities would include the following: Fugitive dust emissions from site clearance, piling work, handling of construction materials, emission due to movement of vehicles on unpaved roads, plying of vehicles, etc. Vehicular emissions due to increased traffic movement on site and on the approach roads; Exhaust emissions from construction machinery and other equipment such as batching plant, if any; and Emissions from diesel generators required to be run for construction power purposes To control air emission during construction phase from operation of D.G. sets, adequate stack height as per CPCB norms will be provided to ascertain regulatory compliance. Fugitive dust emission arising from various activities such as piling, transportation of material (loading and unloading), vehicular movement (on unpaved roads) will be minimized through sprinkling of water www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 25 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS PROJECT DESCRIPTION Final ESIA Report and maintaining vehicular speed to 10-15 km/hr. Vehicular emission will be controlled through proper maintenance of vehicles and vehicles with proper PUC will be operated at project site. 2.6.2.2 Operation Phase Under normal operating conditions there would be no gaseous emissions from the operating areas. However, there is a likelihood of gaseous and fugitive dust emissions, albeit in smaller concentrations, owing to the operating of maintenance vehicles. As a means of best practice and adherence to country regulations, well maintained vehicles with proper PUC will only be used for operation and maintenance purposes. 2.6.3 Wastewater Generation 2.6.3.1 Construction Phase Liquid effluents generated during the construction phase will include domestic sewage from temporary site office as well as from labour camps. As part of the site preparation stage, a drainage and sewerage system will be constructed for the site office. The sewerage system will consist of soak pits for the collection of wastewater from the kitchen and washing areas and Office facility. Sewage from the toilets shall be discharged into lined septic tanks. Sewage disposal trucks shall be used to periodically remove the sludge/sewage from the site. 2.6.3.2 Operation Phase The operational phase will have ~8 KLD of wastewater generation at site office. Septic tank and soak pits will be provided at the site offices, pooling substations of each Units for disposal of sewage. 2.6.4 Noise Emission 2.6.4.1 Construction Phase During the construction phase noise will be generated primarily during the day time. Noise will be generated from pilling activities, construction equipment and machineries, D.G. sets and vehicular movement in the area. Since there are settlements in the near vicinity of the construction site, the receptors of noise pollution will be the residents of the settlements and the construction workers. not exceed 91 dB(A) (for Passenger or commercial vehicles with gross vehicle weight above 12000 kg as specified in Central Motor Vehicles Rules, 1989, as amended). D.G. sets will be provided with acoustic enclosures and workers near noise generating machines will be provided with earplugs as safeguard against high noise hazards. 2.6.4.2 Operation Phase Under normal operations, none of the activities of Solar Park will generate noise. Any noise generating activities during maintenance work will be restricted to daytime only. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 26 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report 3. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK This section presents key environmental and social rules and regulations as well as international safeguard requirements that will be applicable to the Project, during different phases with respect to the following reference framework: Applicable Indian (national, state and local) Environmental and Social Regulations; Applicable Permits (licences, approvals and consents) and permitting agencies; IFCs Performance Standards on Environmental and Social Sustainability (2012) (IFC, 2012); World Bank Environmental and Social Safeguard Policies; IFC/ WB General EHS Guidelines (2007) (IFC, 2007); IFC EHS Guidelines for Electric Power Transmission and Distribution, 2007; and MNRE Environmental and Social Management Framework for Solar PV Park, February, 2017. Applicable National Environmental Standards for Ambient Air, Noise, Water etc. 3.1 Applicable Reference Framework A list of applicable environmental legislations and their specific application for the proposed Project are given in Table 3.1. The International Standards and their applicability for the Project is provided in Table 3.2. Earlier, a preliminary review of applicable regulations was conducted in the scoping stage. The present table has been built upon that and is an outcome of revised review. The table shall be updated as the Project progresses. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 27 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report Table 3.1 Applicability of Key Legislations in India and Reference Framework in the different phases of life cycle of the Project Applicable Indian Agency Responsible Remarks Legislation/Guidelines/International Conventions Pre-construction Construction Operations Environment Protection Environment Protection Act, 1986 and as X Madhya Pradesh Permissible limits for ambient air quality, water quality, noise limits has been amended Pollution Control Board laid down by CPCB under EP Act, 1986 which requires to be complied with (MPPCB) during Project lifecycle. Central Pollution Control Board (CPCB) Ministry of Environment Forest and Climate Change (MoEFCC) Noise Pollution (Regulation and Control) X MPPCB Per the Act, ambient noise levels are to be maintained as stipulated in the Rules, 2000 and the Noise Pollution rules for different categories of areas such as residential, commercial and (Regulation and Control) (Amendment) Rules, industrial and silence zones. Considering the context of the project, the 2010 rules for residential areas would need to be followed. The Water (Prevention and Control of X MPPCB The conditions within the Water and Air Act need to be followed through Pollution) Act, 1974, as amended construction and operation of the project. The Air (Prevention and Control of Pollution) X MPPCB Act 1981, as amended As per MPPCB Notification no. 4551 dated 27.12.2016, Solar Parks are listed under White Category and does not require Consent to Establish/Operate. Guidelines/Criteria for Evaluation of X MPPCB Per the guidelines, any ground water abstraction for project will require Proposals/Requests for Groundwater permission from Central Ground Water Authority (CGWA). Presently, DPR Abstraction, 2012 as amended of the Project has identified tanker water and ground water as source of water to meet water requirements of the Project during construction and operation phases respectively. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 28 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report Applicable Indian Agency Responsible Remarks Legislation/Guidelines/International Conventions Pre-construction Construction Operations Hazardous and Other Wastes (Management X MPPCB Generation of used oil/diesel, paint cans, oil contaminated rags transformer and Transboundary Movement) Rules, 2016, oil, oil contaminated materials at Solar Park and substation site attracts the as amended provisions of Hazardous and Other Waste Rules, 2016. As per amendment vide G.S.R 178 dated 1st March 2019, Project does not require HW authorisation as the project does not require consent to establish and consent to operate under white category provided. HW and other wastes generated from the project shall be given to the actual user, waster collector or operator of the disposal facility in accordance with CPCB guidelines. Explosive Rules 2008 X X Chief Controller of If any controlled blasting is proposed in the project for site levelling, these Explosives, Petroleum Rules will be applicable. The Project will have to obtain a license for storage and Explosives Safety and use of explosives from the Chief Controller. The rules with respect to Organisation storage requirements, safety, labelling and records/submission of annual returns needs to be followed as indicated in the explosive rules. Batteries (Management and Handling) Rules, X MPPCB Batteries need to be managed and stored with respect to the Batteries 2001, as amended Management and Handling Rules and disposed through an authorized recycler. E-waste (Management) Rules, 2016, as X MPPCB Electrical and electronic waste needs to be managed and stored with amended respect to the electronic waste rules and disposed through an authorized recycler. Construction and Demolition (C&D) Waste X X MPPCB If there is any demolition for structures in the Project during construction and Management Rules, 2016 decommissioning activities, these Rules will be applicable. The C&D waste has to be disposed as per the Rules. Manufacture, Storage & Import of Hazardous X MPPCB Storage and handling of hazardous chemicals in the form of diesel and Chemical Rules, 1989 as amended transformer oil will be carried out in accordance to the relevant provision of this Rule. All chemical storage to be appropriately labelled with Material Safety Data Sheets (MSDS) available and displayed. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 29 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report Applicable Indian Agency Responsible Remarks Legislation/Guidelines/International Conventions Pre-construction Construction Operations The Madhya Pradesh Bhumi Vikas Rules, X Local Fire Authority The Project will require Fire NOC for substations if the height of control 1984 room qualifies category of High rise building (height of building above 18 m) as given in the Rules. The Motor Vehicles Act, 1988 as amended X Ministry of Road Compliance of stipulated standards under Rule; Transport and Highways Display of emergency information panel by vehicles carrying hazardous substances as per Rule 134; State Transport Authority Vehicular pollution control measures; Other environmental and safety compliance under the Rules. Social www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 30 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report Applicable Indian Agency Responsible Remarks Legislation/Guidelines/International Conventions Pre-construction Construction Operations The Madhya Pradesh Land Revenue X X District Collector and This Act provides guidance on the evaluation of land and assets impacted; Code,1959 and amendment 2018 Revenue Department According to this Act, "Market Value" means the value of land assessed according to guidelines issued by the Collector under the Madhya Pradesh Bajar Mulya Margdarshak Siddhanton ka Banaya Jana Tatha. Unka Punrikshan Niyam, 2000 made under the Indian Stamp Act, 1899 Chapter 18 of the Act puts in place the provisions for the declaration of Nistar rights by the Sub-Divisional officer, for each village. The Nistar Patrak may include matters such as: Terms and conditions on which grazing of livestock in the village may be permitted The terms and conditions on which and the extent to which any resident may obtain - Wood, timber, fuel or any other forest produce - Mooram, kankar, sand, earth, clay, stones or any other minor mineral etc. The Wajib-ul-arz document, also with the Sub-Divisional Officer, is a record of customary land on non-vacant land- rights suck as easements and wayleaves, rights of water use for irrigation, fishing etc. The code also allows for the Collector to set apart unoccupied land for uses including timber and fuel reserve, pasture grass bir or fodder reserve, gaothan, encamping ground, threshing floor etc. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 31 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report Applicable Indian Agency Responsible Remarks Legislation/Guidelines/International Conventions Pre-construction Construction Operations MP Mutual Consent X X Revenue department The government agencies requiring land for various infrastructure projects Policy, 2014 (Aapasi sehmati se Bhu kraya can procure land with the mutual consent of the land owners as it saves Niti, 2014) time, ensure timely payment of land value to owners and the procedures are less cumbersome. The objective is to purchase land from owners with their consent and making them understand the social and economic benefits as a result of the project. The policy will facilitate speedy procurement of land and the sellers will get the land and asset value as per the provisions of the policy in a timely manner. The Right to Fair Compensation and X X District Collector and This act is only planned to be used for private or patta land parcels that do Transparency in Land Acquisition, Revenue Department not have clear titles or have ownership disputes. All other private and patta Rehabilitation and Resettlement Act 2013 land will be procured using the MP Mutual Consent based Land Purchase Policy 2014. Such parcels within the area required for the project will not exceed 100 acres for any unit The Section 45.1 and 45.2 of the Act require that in case the land for acquisition is => 100 acres; a R & R Committee will be formed, with the collector as the Chairman. The purpose of the committee will be to monitor and review the progress of the implementation of the R & R Scheme and to undertake post-completion audits in consultation with the GS and municipalities. The Indian Telegraph Act, 1885 X X Department of The Electricity Act and Telegraph Act define the compensation payable Telecommunication, Govt. for damages to crops/ trees and structures along the transmission line of Madhya Pradesh route www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 32 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report Applicable Indian Agency Responsible Remarks Legislation/Guidelines/International Conventions Pre-construction Construction Operations Seventy Third Constitution Amendment Act, X X Department of Panchayati The Act enables participation of Panchayat level institutions in decision- Raj, State Government making. Panchayats at the village level will be involved for preparation and implementation of the project. MoP Guidelines for Payment of X X Revenue Department Guidelines for payment of compensation towards damages in regard to Compensation Towards Damages in regard Right of Way for transmission lines. The guidelines have proposed to RoW, 2015 compensation to be paid for the base area in between the transmission tower (between four legs) and towards diminution of land value in the width of the RoW corridor due to laying of transmission line @ 85 % and 15 % respectively of the land value as determined by the District Magistrate or any authority based on circle rate/ guideline value/ stamp value/ stamp act. Labour Minimum Wages Act 1948 Labour Department The act ensures minimum wages for each category of workers www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 33 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report Applicable Indian Agency Responsible Remarks Legislation/Guidelines/International Conventions Pre-construction Construction Operations Equal Remuneration Act 1976; Labour Department Puts in place rules and regulations governing the remuneration payable to workers and employees The Payment of Wages Act, 1936, amended in 2005 and 2017; Maternity Benefit Act, 1961 & The Maternity Benefit (Amendment) Act, 2017 The E.P.F. and Miscellaneous Provisions act, 1952 and The Madhya Pradesh Labour Laws (Amendment) And Miscellaneous Provisions Act 2015 was passed under the Madhya Pradesh Act (21 of 2015) in November 2015; Payment of Bonus Act, 1965 and rules and subsequent amendment Payment of Gratuity Act, 1972; ESI Act , 1948 (Employees State Insurance Act, 1948) Child Labour (Prohibition and Regulation) Act, Labour Department Prohibits employment of children below 14 years of age 1986 and subsequent amendments www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 34 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report Applicable Indian Agency Responsible Remarks Legislation/Guidelines/International Conventions Pre-construction Construction Operations Contract Labour (Regulation & Abolition) Labour Department Ensure basic welfare measures to be made available to the contract workers Central Act 1970 and Rules, 1971 by the employer The Bonded Labour System (Abolition) Act Labour Department Abolishes Forced labour in the country 1976; Inter-state Migrant Workmen Act 1979. Labour Department Regulate the condition of service of inter-state labourers in Indian labour law The Building and other Construction Workers Labour Department Ensure safety measures at construction work site and other welfare Act, 1996 measures such as canteens, first-aid facilities, ambulance, housing accommodation for Workers near the Workplace etc. The Sexual Harassment of Women at District Officer Ensure prevention of Sexual Harassment against women and provides for Workplace (Prevention, Prohibition and forums for raising these grievances and their independent evaluation Redressal) Act, 2013 Indigenous People www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 35 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report Safeguards in the Indian Constitution "Scheduled Tribes" means such tribes or tribal communities or parts of or groups within such tribes or tribal communities as are deemed under article 342 to be Scheduled Tribes for the purposes of the Constitution. As it is stipulated in the constitution, the President (President of India) may with respect to any State or Union Territory, and where it is a State, after consultation with the Governor thereof, by public notification, specify the tribes, or tribal communities or parts of or groups within tribes or tribal communities which shall for the purposes of this Constitution be deemed to be Scheduled Tribes in relation to that State or Union Territory, as the case may be. With regard to inclusion or exclusion, Parliament may by law include in or exclude from the list of Scheduled Tribes specified in a notification, any tribe or tribal community or part of or group within any tribe or tribal community. Prohibition of Discrimination As per this provision, the States shall not discriminate against any citizen on grounds only of religion, race, caste, sex, place of birth or any of them. Other provisions are; No citizen shall, on grounds only of religion, race, caste, sex, place of birth or any of them, be subject to any disability, liability, restriction or condition with regard to (a.) access to shops, public restaurants, hotels and places of public entertainment; or (b.) the use of wells, tanks, bathing Ghats, roads and places of public resort maintained wholly or partly out of State funds or dedicated to the use of general public. Nothing (clause (2) of article 29) shall prevent the State from making any special provision for the advancement of any socially and educationally backward classes of citizens or for the Scheduled Castes and the Scheduled Tribes. Nothing (sub-clause (g) of clause (1) of article 19) shall prevent the State from making any special provision, by law, for the advancement of any socially and educationally backward classes of citizens or for the Scheduled Castes or the Scheduled Tribes in so far as such special provisions relate to their admission to educational institutions including private educational institutions, whether aided or unaided by the State, other than the minority educational institutions referred to in clause (1) of article 30. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 36 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report The SCs and the STs (Prevention of The act was passed in 1989 to prevent Scheduled Castes and Scheduled Atrocities) Act, 1989 Tribes from atrocities. The act suggests Precautionary and Preventive Measures under which State Government shall identify the area where it has reason to believe that atrocity may take place or there is an apprehension of reoccurrence of an offence under the Act: The state shall order the concerned officer to visit the identified area and review the law and order situation. If deemed necessary, in the identified area cancel the arms licenses of the persons, not being a member of the Scheduled Castes or Scheduled Tribes, their near relations, servants or employees and family friends and get such arms deposited in the Government Armoury. The act suggests constitution of a high-power State-level committee, district, and divisional level committees or such number of other committees as deemed proper and necessary for assisting the Government in implementation of the provisions of the Act; The act has made provision to set-up a vigilance and monitoring committee to suggest effective measures to implement the provisions of the Act. The state can set-up Awareness Centres and organise Workshops in the identified area or at some other place to educate the persons belonging to the Scheduled Castes and the Scheduled Tribes about their rights and the protection available to them under the provisions of various Central and State enactments or rules, regulations and schemes framed there under. Under the act, Non-Government Organisations are encouraged for establishing and maintaining Awareness Centres and organizing Workshops and provide them necessary financial and other sort of assistance. As per the provision of the act, the State Governments shall set up a Scheduled Castes and the Scheduled Tribes Protection Cell at the State head quarter under the charge of Director General of Police/Inspector General of Police. This Cell shall be responsible for (i) conducting survey of the identified area; (ii) maintaining public order and tranquillity in the identified area; (iii) recommending to the State Government for deployment of special police force or establishment of special police post in the identified area; (iv) making investigations about the probable causes leading to an offence under the Act; (v) restoring the feeling of security amongst the members of the Scheduled Castes and the Scheduled Tribes; (vi) informing www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 37 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report Applicable Indian Agency Responsible Remarks Legislation/Guidelines/International Conventions Pre-construction Construction Operations the nodal officer and special officer about the law and order situation in the identified area; (vii) making enquiries about the investigation and spot inspections conducted by various officers; (viii) making enquiries about the action taken by the Superintendent of Police in the cases where an officer in-charge of the police station has refused to enter an information in a book to be maintained by that police station; (ix) making enquiries about the wilful negligence by a public servant. Biodiversity Conservation Wildlife Protection Act, 1972, 2002 and Rules, Wildlife Warden, State If any protected/ endangered flora or fauna (as listed in Schedules of WP 2003 and as amended Forest Department Act, 1972) are found in the project area, the proponent should implement conservation measures for their protection. Forests (Conservation) Act, 1980 and Rules District and State Forest None of the Project components were being sited on forest land at the time 1981 as amended Department of the ESIA study. However, the exact route of the external transmission line MoEFCC. was not confirmed at the time of the ESIA and the unit pooling substations were located less than 500m from the boundaries of the Arnea Reserve Forest block. If the finalized transmission line route or any access roads to the Project require the clearing of vegetation within a declared forest area then the provisions of the Forest Conservation Act, 1980 and amendments would be applicable and the Project would need to go in for a forest clearance. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 38 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report Table 3.2 International Standards- IFC Performance Standards and WB Environmental and Social Standards S. No. IFC PS (2012) WB- Safeguard Requirement Standard Applicability/ Compliance Policies Triggered 1. PS 1: Assessment OP 4.01: Social and Environmental Assessment and Yes The Project will have moderate impacts on environment, and Management of Environmental Management Systems for managing social and health, safety and social aspects throughout its lifecycle Environmental and Assessment environmental performance throughout the life cycle and will need to be managed and monitored through the Social Risks and of the Project and runs through all subsequent implementation of policies and procedures in Impacts standards. compliance with IFC PS 1 and WB OP 4.01. World Bank compliant ESMF is already developed for the project and will guide the impact assessment and management plans. (Section 6 and 8) Identification of the area of impact, types of impacts and affected stakeholders, to be addressed/ mitigated/ managed and consulted, respectively. Conducting environmental and social assessment of the Project to identify E&S risks and impacts of the project. It shall inform the design of the project, and be used to identify mitigation measures and actions 2. PS 2: Labour and OP 4.01: The economic growth through employment creation Yes The construction and operation phase for the Project Working Conditions Environmental and income generation is recognised and balanced will include employment of labour for varying activities Assessment protecting the basic rights of workers. This standard such as widening of access roads, site preparation, outlines the minimum requirements of working boundary wall construction and module installation The conditions, protection to the workforce (including Project will also require the establishment of temporary issues of child and forced labour) and ensuring labour camps during the construction phase at all sites occupational health and safety of both its employees and staff accommodation during the operation phase as well as non- that fall within the purview of IFC PS 2 and WB OP contractors. 4.01. 3. PS 3: Resource OP 4.01: The Standard outlines the approach to pollution Yes Some air emissions and pollution discharge is Efficiency and Environmental prevention and abatement in line with internationally anticipated from the Project including use of D.G. sets, Pollution Prevention Assessment disseminated technologies and practices. use of groundwater in project activities (both during construction and operation phase) and labour camp, impact on drainage, wastewater discharge from labour camps, solid waste disposal such as broken solar www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 39 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report S. No. IFC PS (2012) WB- Safeguard Requirement Standard Applicability/ Compliance Policies Triggered panels, general office waste, waste generated during repair and maintenance during project life cycle. Water requirement during construction and operation phase, will also lead to stress on available water resources. The above activities fall within the purview of PS 3 and WB OP 4.01. 4. PS 4: Community OP 4.01: The Standard requires a project to evaluate risks and Yes The construction and operational phases of the project Health, Safety & Environmental impacts to the health and safety of the affected will have impacts on neighbouring communities Security Assessment community during the Project life cycle and establish particularly traffic safety risks during movement of measures to avoid minimize and reduce risks and construction materials and machinery. Electrocution risk impacts from the Project. linked to transmission line and substations during operation phase. In addition, there will be interaction of community with security personnel during construction and operation phases. These falls under purview of PS 4 and WB OP 4.01. 5. PS 5: Land OP 4.12: The PS-5 applies to physical or economic Yes (for The Project will involve land procurement (Government Acquisition and Involuntary displacement resulting from the following types of Private and Patta and Private land) for development of Solar Park Involuntary Resettlement land transactions: Patta land) and its associated facilities. The IFC PS and WB OP Resettlement Yes- for 4.12 are likely to be applicable on the project if land is Type I: Land rights for a private sector project encroached/ taken in the types of transactions identified and will acquired through expropriation or other compulsory squatted result in physical or economic displacement. This will in procedures; Type II: Land rights for a private sector upon land turn guide the land procurement process, the project acquired through negotiated settlements with Resettlement Action Plan and Livelihood Restoration property owners or those with legal rights to land, Plan for the project. including customary or traditional rights recognised or recognisable under the laws of the country, if - expropriation or other compulsory process would based Land Purchase Policy, 2014 for land have resulted upon the failure of negotiation; procurement of private and patta land. However, the land acquisition act may be used for the parcels that do The OP applies to permanent or temporary physical not have clear titles or have ownership during disputes, and economic displacement resulting from the if any are found the MP Mutual Consent process. following types of land acquisition or restrictions on www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 40 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report S. No. IFC PS (2012) WB- Safeguard Requirement Standard Applicability/ Compliance Policies Triggered land use undertaken or imposed in connection with The process of land procurement is understood to be project implementation: through negotiated settlement hence, PS 5 is (a) Land rights or land use rights acquired or applicable. restricted through expropriation or other compulsory procedures in accordance with national law; (b) Land rights or land use rights acquired or There will be economic displacement for Graziers using restricted through negotiated settlements with property owners or those with legal rights to the Government land for livestock grazing and the land, if failure to reach settlement would Agricultural labourers working on the identified private have resulted in expropriation or other compulsory Patta or occupied (encroached or squatted upon) land procedures; parcels that they do not have rightful claims on the land. (c) Restrictions on land use and access to natural resources that cause a community or groups within a These economic displacement impacts will also be community to lose access to resource usage where covered through the RAP-LRP. they have traditional or customary tenure, or recognizable usage rights. This may include situations where legally designated protected areas, forests, biodiversity areas or buffer zones are established in connection with the project; (d) Relocation of people without formal, traditional, or recognizable usage rights, who are occupying or utilizing land prior to a project specific cut-off date; (e) Displacement of people as a result of project impacts that render their land unusable or inaccessible; (f) Restriction on access to land or use of other resources including communal property and natural resources such as marine and aquatic resources, timber and non-timber forest products, fresh water, medicinal plants, hunting and gathering grounds and grazing and cropping areas; (g) Land rights or claims to land or resources relinquished by individuals or communities without full payment of compensation; and (h) Land acquisition or land use restrictions occurring prior to the project, but which were undertaken or www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 41 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report S. No. IFC PS (2012) WB- Safeguard Requirement Standard Applicability/ Compliance Policies Triggered initiated in anticipation of, or in preparation for, the project. 6. PS 6: Biodiversity OP 4.04: The Standard aims at protecting and conserving Yes The Neemuch site Unit 3 is located immediately Conservation and Natural Habitats biodiversity, the variety of life in all its forms, including adjacent to [Water Body Unit 3]. As observed during the Sustainable genetic, species and ecosystem diversity and its site assessment, this water body supports flocks of Management of ability to change and evolve, is fundamental to migratory and resident bird species. The proximity of the Natural Living sustainable development. water body to the Project site can pose collision and Resources electrocution risks for birds taking off and landing from the [Water Body Unit 3].The birds may also mistake the operational solar modules as a part of the water body contribute to the collision risk. The three substation units and external transmission line are proposed along the northern end of the Project site. The units are therefore located less than 500m from the Arnea Reserve Forest block. Anthropogenic movement and development in close proximity to a forest block can have impacts associated with human- wildlife conflict, noise, stress on resident species and habitat modification of forest edge areas. 7. PS 7: Indigenous OP 4.10: The Standard acknowledges the possibility of Yes The villages in the project footprint area are comprised Peoples Indigenous vulnerability of indigenous people owing to their of ST population (primarily Bhil) who may be impacted Peoples culture, beliefs, institutions and living standards, and by the project activities, in terms of loss of Common that it may further get compromised by one or other property resources, loss of structures and impact on project activity throughout the life cycle of the project. livelihoods. The PS is thus applicable for all three sites. The FPIC approach paper has identified two locations (villages) where the processes will be carried out to seek consent for the project.(Details are included in the Draft FPIC approach note, submitted 3rd Sept 2020) www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 42 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report S. No. IFC PS (2012) WB- Safeguard Requirement Standard Applicability/ Compliance Policies Triggered 8. PS 8: Cultural OP 4.11: The Standard aims to protect the irreplaceable No Presently the Standard is not expected to be triggered Heritage Physical cultural heritage and to guide clients on protecting for the project. However, structures or places with Cultural cultural heritage in the course of their business religious or cultural significance may be identified during Resources operations. In addition, the requirements of this PS the resource mapping process for FPIC and during the RAP survey, the applicability of the Standard will be on standards set by the Convention on Biological reviewed and management plans prepared, if avoidance Diversity is not feasible. WB/IFC EHS Guidelines 9. General EHS The IFC/WB General Environmental, Health and Yes General EHS Guidelines will need to be followed during Guidelines Safety (EHS) Guidelines documents Good the construction and operation phase of the project. International Industry Practices (GIIPs) by covering the ambit of environmental, social and ecological concerns associated with establishing and managing a project. The aspects covered in the guidelines include ambient air quality monitoring, energy conservation, wastewater management, water conservation processes, hazardous materials management, waste management, noise reduction processes, occupational health and safety, community health and safety and project phase- specific concerns. 10. Electric Power The IFC/WB EHS Guideline for Electric Power Yes Aspects of the EHS guidelines with respect to Transmission and Transmission and Distribution covers industry-specific occupational health and safety, right of way Distribution issues associated with laying, operation and maintenance and hazardous materials management as dismantling of transmission towers, lines and is relevant for internal transmission lines and the pooling substations. Key issues covered in the guidelines substation infrastructure has been covered in the report. include terrestrial habitat alteration, right-of-way access, right of-way maintenance, electrocution risk to bird and bat species, health and safety of working with or near electric and magnetic fields, storage and www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 43 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report S. No. IFC PS (2012) WB- Safeguard Requirement Standard Applicability/ Compliance Policies Triggered maintenance of hazardous materials (e.g. oils, fuels, preservatives) and aircraft navigational safety. 11. This guidance note, provide guidance on the provision Yes These guidelines will need to be followed during accommodation: of housing or accommodation for workers by establishment of labour camps for the project. processes and employers and the issues that arise from the standards planning, construction and management of such facilities. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 44 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Final ESIA Report 3.1.1 Environmental and Social Management Framework of Ministry of New and Renewable Energy MNRE have framed an Environmental and Social Management Framework for Solar PV Park, dated February 2017. The framework had identified the following key environmental and social issues/ impacts to be kept in consideration for sub-projects: Impacts on biological environment, especially forest land; Impacts due to water requirements as most projects are located in water scarce regions; Impacts on livelihoods of land owners and land users; Impacts on common property resources; Impacts due to soil erosion and dust. In keeping with the impacts identified, the ESMF requires the formulation of a project specific Environmental and Social Management Plan, which would include relevant management plans, such as (not limited to) the following: Resettlement Action Plan/ Framework Gender Action Plan Indigenous Peoples Policy Framework Stakeholder Engagement Plan; and Grievance Redressal Mechanism 3.2 Applicable Environmental Standards 3.2.1 National Level Standards The Central Pollution Control Board (CPCB) has stipulated different environmental standards w.r.t. with respect to ambient air quality, noise quality, water and waste water quality for the country as a whole under EP Act, 1986. Following standards are applicable for the project and needs to be complied with during the project life cycle. National Ambient Air Quality Standards (NAAQ Standards), as prescribed by MoEF&CC vide, Gazette Notification dated 16th November, 2009; Drinking water quality- Indian Drinking Water Standard (IS 10500: 2012); General standards for discharge as prescribed under the Environment Protection Rules, 1986 and amendments (G.S.R 422 (E) dated 19.05.1993 and G.S.R 801 (E) dated 31.12.1993 issued under the provisions of E (P) Act 1986); Noise standards specified by the MoEF&CC vide gazette notification dated 14th February, 2000 (Noise Pollution (Regulation and control) Rules, 2000) 3.2.2 IFC/ WB Standards The General EHS Guidelines (30th April 2007) of IFC/ WB have outlined following environmental standards which needs to be complied for the project. IFC/WB Air Emissions and Ambient Air Quality Standards; IFC/WB Guidelines for treated sanitary sewage discharges; and IFC/WB Noise Standards. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 45 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report 4. ENVIRONMENTAL AND SOCIAL BASELINE This section describes the existing environmental and social sensitivities of the study area (described below). The sensitivities include the relevant components of the physical, biological and socio- economic environment. The purpose of describing the environmental and social sensitivities of the study area is to: To describe the environmental characteristics of the Project site and surrounding areas to identify key resources and receptors that will be affected by the Project during the scoping process; To determine if any nearby communities or structures will be affected by the Project establishment; and To understand the significance of the different habitats within the study area and its importance for sustaining species of conservation importance, in terms of providing habitat contiguity to the surrounding region and dependency of surrounding communities. 4.1 Study Area The area of up to 5 km radius from the Project boundary (Solar Park area) has been demarcated as study area for the Project by considering the extent of project impact in terms of air quality, noise, water resources, human settlement, cultural heritage sites, location of labour sites, location of the access roads besides considering the actual land area which has been procured for the project and its utilities footprints. 4.1.1.1 Project footprint area The Project footprint is the area that may reasonably be expected to be physically touched by Project activities, across all phases. The Project footprint for Project includes land used for the setting up the Solar PV panels, transformer rooms, site office, access roads, storage of material and equipment, labour camps and pooling substation at Solar Park site. It was informed by RUMSL that all temporary structures during construction phase, i.e. material storage area, labour camp, site office etc. will be established only within the Solar Park area. The Project footprint details provided by RUMSL dated 3 June, 2020 has been considered for this report. 4.1.1.2 Project Area of Influence (AoI) The effects of the Project and Project activities on a particular resource or receptor will have spatial (distance) and temporal (time) dimensions, the scale of which is dependent on a number of factors, including: Nature of the activity; Specific resource or receptor; Sensitivity of that resource or receptor; and Whether the impact is direct or indirect (e.g. a secondary effect). The Project area of influence refers to the Project footprint area as well as to a larger area in its immediate vicinity. This includes the footprint of the associated Project components, such as access road as well as the immediate surroundings that will see increased movement of vehicles, personnel and land-use change. Most of the impacts will occur within the Project footprint area as identified above. However, certain impacts can be further reaching in terms of expected impacts. The AoI considered for Project with respect to the environmental and social resources was based on the following reach of impacts: Environmental parameters: Project site boundary, immediate vicinity, access road and surroundings, i.e. a study area of approximately 2 km distance from the Solar Park site. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 46 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report - Air Quality: Dust emissions, fugitive dust typically up to 500 m from major construction areas; - Noise: Noise impact area (defined as the area over which an increase in environmental noise levels due to the Project can be detected) typically 500 m from construction site; - Soil environment: The impacts on soil and land- typically up to 500 m from project foot print area; - Water Environment: The impacts on water quality of water bodies on the water bodies present in nearby area of project activities. Flora and Fauna (Terrestrial and Aquatic): This includes: (a) the direct footprint of the Solar Park and Transmission Line; (b) The areas immediately adjacent to the Project footprint within which a zone of ecological disturbance is created through increased dust, human presence and project related activities (e.g., trampling, transportation activities).This kind of disturbance has been estimated to occur within 500 m of the project footprint; Social: The project footprint is spread across 3 villages (excluding the Transmission Line, the alignment for which is presently being finalised). Roads for movement of materials and people during the construction phase will be included in the Area of influence, based on volume and intensity. This is taken as the area of influence, though social impacts are likely to largely remain confined to the villages falling in the project footprint or in the Project villages, as defined in Section 4.4.2. Other villages/groups may come to be included if it emerges during RAP surveys and consultations that there is economic dependence on the proposed project areas and details shall be covered in the RAP report. The detailed sub-categorization of Study Area considered for Social baseline and assessment is presented in Section 4.4.2. 4.2 Physical Environment 4.2.1 Site Visit ERM team undertook a site survey from 19 to 22 November 2019 to understand the site setting and to map environmental sensitivities in the area. The primary environmental monitoring data was collected during 19 to 25 December 2019. 4.2.1.1 Primary Baseline Data Collection M/s Netel India Private Limited, an MoEF&CC and NABL (National Accreditation Board for Testing and Calibration Laboratories) accredited laboratory was engaged for collection of baseline information on ambient air quality, surface water quality, ground water quality, ambient noise quality, soil quality and traffic count. The primary baseline data was collected for aspects detailed out in Table 4.1. Table 4.1 Primary Baseline Data Collection S. Environmental No. of Frequency Remarks No Attribute Locations/ Area 1 Ambient Air Quality 2 24 hourly, twice a week Ambient air quality at nearby villages for one week were monitored to understand baseline of AAQ of the area 2 Ambient Noise Quality 5 Once for 24 hours during Ambient noise samples were monitoring period collected over a 24 hour period from the nearby villages 3 Ground Water Quality 3 Once during monitoring Water was collected from hand pump period installed in villages in the study area to analyse ground water quality 4 Surface Water Quality 2 Once during monitoring Water was collected from surface period water bodies/ ponds present in the villages in the study area www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 47 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report S. Environmental No. of Frequency Remarks No Attribute Locations/ Area 5 Soil Quality 5 Once during monitoring Soil samples covering different land period uses were collected from the study area 6 Traffic Count 1 Once during monitoring Traffic count was done on hourly period basis for 24 hours at the road proposed to be used for transportation of raw material and manpower during construction phase Map showing monitoring locations is present in Figure 4.1. 4.2.1.2 Secondary Baseline Data Collection Secondary baseline data collection involved identifying and collecting existing published materials and documents. Information on various environment aspects (like geology, hydrology, drainage pattern, ecology etc.), meteorology were collected from different institutions, government offices and literatures etc. Secondary data was collected for the aspects as given in Table 4.2. Table 4.2 Secondary Baseline Data Collection S. Attribute Source of Data Collection No 1 Meteorological data India Meteorological Department (IMD) 2 Geology, geomorphology, hydrogeology and U.S. Department of the Interior, U.S. Geological hydrology Survey, 2017 National Remote Sensing Centre (NRSC)-Bhuvan services Central Ground Water Board (CGWB) Geological Survey of India (GSI) India Water Tool - Ministry of Water Resources, 2014 3 Land use Through Satellite Imageries 4 Natural Hazards National Flood Vulnerability Assessment System World Resource Institute (WRI) Vulnerability Atlas of India Building Materials and Technology Promotion Council Environmental baseline data was collected through primary surveys as well as through secondary sources by literature survey and discussions with the concerned departments/agencies. Details of data collected are summarized in subsequent sections. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 48 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.1 Map showing environment baseline monitoring stations in the Project AoI www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 49 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report 4.2.2 Land Use and Land Cover The land is primarily used for agricultural practices in the study area (5 km) of Solar Park contributing to 39.04% of geographical extent, followed by scrub land of 36.05%. The other land uses in the study area are forest area, contributing 23.14 % followed by water bodies contributing 1.0%, settlements 0.34% and road network contributing 0.19% of the total geographical extent. The breakup of land use within 5 km distance of the Solar Park site and within project footprint is provided in Table 4.3 and Table 4.4. Land use map of the study area is presented as Figure 4.2. Table 4.3 Land use/ Land cover details of 5 km study area S. No Land use Type Area in % 1 Agriculture Land 39.04% 2 Scrub Land 36.05% 3 Forest 23.14% 4 Water Body 1.0% 5 Settlement 0.34% 6 River 0.25% 7 Road Network 0.19% Total 100% Source: GIS based assessment for the Project; Data Source: GIS based assessment for the Project , Data Source: Esri, Digital Globe, Geo Eye, Earthstar geographics, CNES/Airbus, DS, USDA, AEX, Getmapping, Aerogrid, IGN,IGP,Swisstopo and the GIS user community Table 4.4 Land use/ Land cover of Project Boundary S. No. Land use Type Area in % 1. Agriculture Land 8.78 2. Scrub Land 88.31 4. Water Body/streams* 2.91 Total 100% Source: GIS based assessment for the Project; Data Source: GIS based assessment for the Project , Data Source: Esri, Digital Globe, Geo Eye, Earthstar geographics, CNES/Airbus, DS, USDA, AEX, Getmapping, Aerogrid, IGN,IGP,Swisstopo and the GIS user community * The percentage of water body/streams also includes water body near Unit 3 which appears within the site boundary due to some distortion in maps provided by RUMSL. Refer Section 1.4 for detail). This shall be revised after receiving maps corrected for distortion. 4.2.3 Topography and Slope The topography and slope information plays a vital role in understanding land use and runoff- recharge characteristics of the terrain. The topography within the region surrounding Neemuch Site varies from 396- 440 m above mean sea level (amsl). The slopes of watersheds were classified into following categories: Flat (0-2%), gentle (2- 9%), moderate (9 -15%), steep (15 -30%) and very steep (above 30%). The major portion of the study area (5 km around the Project site) was observed to be very gently sloping (0 5% slope) and scattered pockets of gently sloping (5 - 10 %). The general slope of the study area was observed to be from North to South. Steep and very steep slopes were observed in the northern portion along the ridges which for the northern boundary of the micro- watersheds. The Project site and its immediate surroundings were observed to have very flat to gentle slopes with slopes varying between 0 10%. ow attributed to very gentle slopes. The DEM map and slope map of the study area of Solar Park is presented as Figure 4. and Figure 4.4. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 50 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.2 Land use and land cover map of study area of Neemuch Solar Park www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 51 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.3 DEM map of study area of Neemuch Solar Park www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 52 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.4 Slope map of the area www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 53 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report 4.2.4 Hydrology Based on the geographical location of the Project site, the corresponding drainage network and watersheds (major and micro) were delineated using the SRTM data. The delineated watersheds fall in Chambal River watershed or sub-basin, which further falls under Yamuna Basin. A major stream flowing from west to east, divides the macro-watershed into two parts. The stream eventually joins Chambal River at downstream of Rana Pratap Sagar reservoir at Bainsororgarh village. The Project area falls in multiple micro-watersheds which are located in the north of the major stream. The surface water flow direction was anticipated from north to south towards the major stream. The base map of the Project site and its corresponding watersheds is presented in Figure 4.5. The reconnaissance survey corroborated the presence of ridges in the west which dictate the flow of surface water towards the east. The Project area is drained by a network of seasonal streams/nallas flowing mainly in the North to South direction, which eventually drain into the Brahmani River to the South. Drainage map of the area is shown in Figure 4.6. Unit-1: South-western portion and south-eastern portion were evaluated to be the lowest level in the unit at 390-400 m amsl (above mean sea level). The excess runoff from the western portion of the Site unit is likely to drain into a minor nalla that flows through Bardwada Pond and drains into S1. Surplus runoff from the eastern portion is drained by S2; Unit-2: South-eastern portion of Unit-2 was evaluated to be the lowest level within the Site unit at 390- 400 m amsl. The elevated portions along the central portion of the Site unit divides the flow direction. Surplus water from the western portion of the Site unit is drained by S2. Excess runoff from the eastern portion of the Site unit is drained by S3; and Unit-3: South-western and south-eastern portions of Unit-3 were evaluated to be lowest level at 390- 400 m amsl. Surplus water from the central, eastern and south-western portions of the Site unit is drained by S4 and routed through adjacent water body. The excess runoff from north-western portion of the Site is drained by S3. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 54 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.5 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 55 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.6 Drainage Map of the Area www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 56 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report 4.2.5 Geology and Geomorphology 4.2.5.1 Geology The Chambal watershed region is a junction between the north-western lobe of the Vindhyan watershed and the south-eastern fringe of the Aravalli range such that the younger formations of the Vindhyan period have truncated and faulted against the Gwalior formation. The north-western part comprises the intensely folded Archean formations while the south-eastern part is composed of horizontally reposing Vindhyan system. The Vindhyans of the southern part are covered by the Deccan Trap. In particular, the study region comprising of district Neemuch is located in Malwa region of Madhya Pradesh and is underlain by rocks of Vindhyan Super Group (Pre- Cambrian) and the Deccan Traps (Upper Creteceous to lower Eocene). Table 4.5 presents the geology of the region. Table 4.5 Stratigraphic succession of the Region Age Super Group Member Sub-Recent to Recent Laterite, Quaternary Alluvium, Laterite Lower Eocene to Upper Deccan Traps Basaltic lava flow Creataceous Pre-Cambrian Lower Vindhyan Limestone and conglomerate 4.2.5.2 Geomorphology Neemuch district forms the part of Malwa plateau. It can broadly be divided into two physical divisions; northern plateau consists of Vindhyan rocks and southern Malwa plateau, under trap with gentle sloping topography. The highest elevation of 573 m amsl in the district is recorded at north-western corner of the district in Jawad tehsil, comprising of upper Vindhyan rocks. Almost entire district is falling under Chambal sub-basins area of the Ganga Basin. (1) Geomorphic features integrated with geology and hydrogeology controls the occurrence, movement and quality of groundwater. from National Remote Sensing Centre (NRSC)- Bhuvan services2 and are presented in Figure 4.7. Most of the region was observed to be under pediment complex of structural and denudational origin. Denudational origin features were reported along the flow of the major stream as such their topography is influenced by weathering caused due to the flow of water. The other parts of the watershed were reported to have structural origin- the topographic features were formed by the differential wearing away of rocks and the deposition of the resulting debris under the influence of exogenic geomorphic forces. The geomorphology of the region is not indicative of much groundwater recharge due to presence of structural features in large parts of the watershed. This is likely to result in poor yield and limited scope for groundwater development in the watershed. However, existence of major fractures/lineaments/ faults might influence the groundwater yield. -watersheds, topography is mainly influenced by denudational features with structural features present along the northern periphery. The prospects of groundwater recharge and occurrence are anticipated to be low resulting in limited scope for groundwater development. The lineaments are developed generally due to tectonic stress and strain and provide an important clue on surface features that are responsible for infiltration of surface run off into sub-surface and movement/ storage of groundwater. Lineaments in the pediplain or valley fill are considered significant in groundwater prospects. Further, the flood plains along the river course are expected to have good groundwater prospects. (1) http://cgwb.gov.in/District_Profile/MP/Neemuch.pdf 2 http://bhuvan.nrsc.gov.in/bhuvan_links.php www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 57 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.7 Geomorphology map of site www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 58 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report 4.2.6 Natural Hazards Various relevant natural hazards were analysed based on secondary information. This includes earthquake, high wind and cyclones and flood hazards. 4.2.6.1 Earthquake Risk As per the Earthquake Hazard/Zoning Map 1 , India is classified into four (4) zones based on the severity of probable earthquake on the Medvedev-Sponheuer-Karnik Scale (MSK), as shown below: Zone V: Very High Damage Risk Zone (MSK IX or more); Zone IV: High Damage Risk Zone (MSK VIII); Zone III: Moderate Damage Risk Zone (MSK VII); and Zone II: Low Damage Risk Zone (MSK VI or less) MSK Intensity Scale is a macro-seismic intensity scale used to evaluate the severity of ground shaking on the basis of observed effects in an area of the earthquake occurrence. The MSK scale XII represents most severe intensity. The zoning was defined primarily depending on the known seismic history of the region, the postulated seismic activity of the future, and the indicative time intervals between two (2) consecutive occurrences in the same area 2 . The earthquake hazard map is presented in Figure 4.8. Based on the review of the earthquake data and map, the location of the Project site falls under Zone II (low damage risk zone/ degree VI or less earthquake hazard on the Low. 1 Building Materials and Technology Promotion Council (BMTPC), Ministry of Housing and Urban Affairs, Government of India. Earthquake Zoning Map: http://bmtpc.org/DataFiles/CMS/file/VAI2019/MAP/eqmap/EQ_JPG/EQ_INDIA.jpg 2 Building Materials and Technology Promotion Council (BMTPC), 2019. Vulnerability Atlas of India, Ministry of Housing and Urban Affairs, Government of India: http://bmtpc.org/DataFiles/CMS/file/VAI2019/index.html www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 59 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report Figure 4.8 Earthquake hazard/zoning map for Madhya Pradesh Source: Building Materials and Technology Promotion Council (BMTPC), 2019. Vulnerability Atlas of India, Ministry of Housing and Urban Affairs, Government of India: http://bmtpc.org/DataFiles/CMS/file/VAI2019/index.html 4.2.6.2 Wind and Cyclones Wind hazard for Project site was evaluated based on two (2) wind hazard maps. These are Average Wind Speed Map (available in Global Wind Atlas 2.0 and developed by DTU) and Basic Wind Speed Map of India (developed by BMTPC). Basic Wind Speed is defined as the peak wind velocity over a 50 years return period, and is considered to be an extreme and conservative estimate of wind speed at the Site and in surrounding areas. On the other hand, the average wind speed is defined as long term annual mean wind velocity. The macro-level wind speed zones of India have been formulated and published in IS: 875 (Part 3) - kes) for and extent of likely damage corresponding to each wind speed zone are presented in Table 4.6. Figure 4.9 presents the basic wind hazard map of the study region. The basic wind speeds are applicable to 10 m height above mean ground level in an open terrain with a return period of 50 years 1 . The basic wind speeds (as per BMTPC) were compared against the Beaufort Scale of Wind Classification 2 as presented in Table 4.7. The Beaufort scale is an empirical measure that relates wind speed to observed conditions at sea or on land. The scale classifies mean speeds, usually averaged over 10 minutes by convention, and does not capture the speed of wind gusts. The quoted wind speed is that measured at 10 m above ground, not at the surface (which, at 2 m, may be only 50-70% of these estimates). 1 Building Materials and Technology Promotion Council (BMTPC), 2019. Vulnerability Atlas of India, Ministry of Housing and Urban Affairs, Government of India: http://bmtpc.org/DataFiles/CMS/file/VAI2019/index.html 2 The Beaufort Scale. Royal Meteorological Society: https://www.rmets.org/resource/beaufort-scale www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 60 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report Table 4.6 Wind hazard categorisation S. No Wind Speed (m/s and km/hr) Wind Damage Zone 1 55 m/s (198 km/h) Very High Damage Risk Zone - A 2 50 m/s (180 km/h) Very High Damage Risk Zone - B 3 47 m/s (169.2 km/h) High Damage Risk Zone 4 44 m/s (158.4 km/h) Moderate Damage Risk Zone - A 5 39 m/s (140.4 km/h) Moderate Damage Risk Zone - B 6 33 m/s (118.8 km/h) Low Damage Risk Zone Source: Building Materials and Technology Promotion Council (BMTPC), 2019. Vulnerability Atlas of India, Ministry of Housing and Urban Affairs, Government of India: http://bmtpc.org/DataFiles/CMS/file/VAI2019/index.html Figure 4.9 Basic wind speed map of Madhya Pradesh with overlaid with study area www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 61 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report Table 4.7 Beaufort scale of wind speed characterisation The Project site falls in the region with average wind speed of <5 m/s while wind speed ranging between 5-10 m/s was reported along the ridges of the macro-watershed. In a conservative scenario, these wind speeds are representative of gentle breeze with constant motion of leaves and twigs based on the Beaufort scale. From wind damage viewpoint, the Project site falls in the region with a basic wind speed of 47 m/s natural environment. Based on the basic wind speed maps, the likelihood of risk at the Project site was evaluated as High based on BMTPC scale and Beaufort scale of wind classification. Table 4.8 Summary of wind hazard categorisation Asset Name (A ) Wind Hazard Zone per (B) Beaufort Scale as per Wind Hazard Category BMTPC Map Basic Wind Speed (higher of (A) and (B) Neemuch High Damage Risk Zone High High Solar Park 4.2.6.3 Flood Risks As per the District Disaster Management Plan for Neemuch District 1 report prepared by MP School of Good Governance and Policy Analysis, floods and droughts are the major natural hazards of the district. Flood prone areas in the district due to overflow from Gandhisagar Dam (40 km south-east of the Project site, along Chambal River) have been marked out (in red) as shown in the Figure 4.10. Per the map, the Project site does not fall under the flood prone area. The detail flood likelihood assessment is provided in Section 6.2.4. 1 https://cdn.s3waas.gov.in/s334173cb38f07f89ddbebc2ac9128303f/uploads/2019/07/2019070330.pdf www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 62 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report Figure 4.10 Flood affected area of Neemuch district Source: District Disaster Management Plan, Neemuch District 4.2.7 Climate and Meteorology Regional Meteorology The long term meteorology (period 1961-1990) of the region based on data recorded at the nearest observatory station of India Meteorological Department (IMD) at Neemuch is presented in Table 4.9 and described in subsequent sections. Table 4.9 Climatological Data, Neemuch Mean Predominant Wind Relative Humidity Rainfall Temperature (°C) Wind Direction Months Speed Morning Evening 8.30 hrs 17.30 hrs Monthly Mean Mean (kmph) Total Max Min (mm) January 24.5 9.8 5.5 NE NE 53 28 2.5 February 27.3 12.3 6.3 NE NE 43 21 2.3 March 32.6 17.2 7.2 NE W 33 16 4.4 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 63 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report Mean Predominant Wind Relative Humidity Rainfall Temperature (°C) Wind Direction Months Speed Morning Evening 8.30 hrs 17.30 hrs Monthly Mean Mean (kmph) Total Max Min (mm) April 37.5 22.7 9.0 W W 29 15 1.5 May 39.6 25.7 12.7 W W 43 19 11.1 June 36.9 25.7 16.1 W W 67 41 84.6 July 31.3 23.9 14.2 W W 83 68 211.9 August 29.4 23.0 12.0 W W 87 75 289.4 September 31.3 22.3 9.1 W W 78 59 125.8 October 33.2 19.6 5.6 CALM NE 52 31 18.5 November 29.5 14.9 4.4 NE NE 48 30 25.7 December 25.6 10.9 4.9 NE NE 56 32 4.7 Average 56 36 782.4 total or 31.6 19.0 8.9 mean Source: Climatological Table 1961-90, India Meteorological Department; Observatory Coordinates: 24o 74o Temperature: Temperatures vary considerably from season to season. The summers are generally hot and winters are cool. Mean maximum temperature ranges between 24.5°C during January to about 39.6°C during May and the mean minimum temperatures vary between 9.8°C during January and 25.7°C during May - June. Wind Speed and Wind Direction: The average wind speed in the area is 8.9 kmph, with highest in June Month (16.1 kmph) and lowest in November (4.4 kmph). The predominant wind directions in the area are North East (November to March) and West (April to October). Relative Humidity: The Relative Humidity in the area ranges between 15% (April) to 87% (August). The annual average RH is 56% and 36% during morning and evening time respectively. Rainfall: Long-term (1961 - 1990) average annual total rainfall for Neemuch station is 782.4 mm, as per IMD Climatological Table. Most of the rainfall is received during the month of July (27.08%) and August (36.99%) and minimum in February (0.29%). Rainfall recorded in Neemuch district from 2014 to 2018 has also been presented below which show that July and August are the wettest months whereas February and November are driest months of the year. Table 4.10 Rainfall Data - Neemuch Year January Februar March April May June July Augus September October November December y t 2014 1.0 0.0 0.0 0.0 0.0 0.0 248.1 368.3 208.9 4.3 0.0 0.0 2015 8.3 0.0 29.3 0.0 0.0 83.2 465.3 152.8 2.7 0.0 0.0 0.0 2016 2.3 0.0 0.0 0.0 0.0 88.1 222.8 678.0 86.0 36.1 0.0 0.0 2017 1.3 0.0 0.7 0.0 0.0 121.3 386.2 182.3 107.0 0.0 0.0 1.7 2018 0.0 0.0 0.0 0.0 0.0 143.5 355.2 295.0 264.7 0.0 0.0 0.3 Source: http://hydro.imd.gov.in/hydrometweb/(S(zq1q35r5cjodlizybet3jlqn))/DistrictRaifall.aspx 4.2.8 Ambient Air Quality The existing ambient air quality of the study area was monitored at 2 locations during the study period. The monitoring parameters includes Respirable Particulate Matter (RPM) i.e. PM 10 (particulate matter of particle size less than 10 micrometres) and PM2.5 (particulate matter of particle size less than www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 64 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report 2.5 micrometres), Sulphur Dioxide (SO2), Oxides of Nitrogen (NOx) and Carbon Monoxide (CO). PM10, PM2.5, SO2 and NOx were monitored on 24 hourly basis while CO was monitored on 8 hourly basis twice a week for a week during the study period. Selection of sampling locations The baseline status of the ambient air quality has been established through ambient air quality monitoring network and is based on the following consideration: Meteorological conditions of the area based on information of IMD; Topography of the study area; and Location of sensitive receptors such as major settlements. The details of monitoring locations within the study area has been presented in Table 4.11 below. Map showing location of ambient air quality monitoring locations is presented in Figure 4.1. Table 4.11 Details of Ambient Air Monitoring Stations S. Sampling Location Zone Easting Northing Direction and Justification for No location Code (mE) (mN) distance from selection of project site location and its setting 1 Village AAQ1 43R 524781.45 2766087.45 ~ 170 m (W) of Unit 3 These stations Badi ~ 240 m (E) of Unit 2 captures the 2 Village AAQ2 43R 521597.23 2764645.67 ~ 600 m (E) of Unit 1 baseline of AAQ Kawai ~ 650 m (W) of Unit 2 for settlement in the Project area Source: ERM site visit The sampling and analysis of ambient air quality parameters was carried out as per the procedure detailed in relevant parts of IS-5182 (Indian Standards for Ambient Air Quality Parameters). The applied testing procedures are given in brief in Table 4.12 below. Table 4.12 Details of Methods and Detection Limits for different Air Quality Parameters S. N Parameter Range/ Detection Limit 1 Particulate Matter (size less than 10 µm or IS-5182 (Part -23):2006 & CPCB Guidelines PM10 Volume 1 (2012-2013) 2 Particulate Matter (size less than 2.5 µm or CPCB Guidelines Volume 1 (2012-2013) PM2.5 3 Sulphur Dioxide (SO2) IS-5182 (Part-II):2001 4 Nitrogen Oxide (NOx) IS-5182 (Part-VI):2006 5 Carbon Monoxide (CO) CO Analyser Summarised AAQ results as monitored at various locations are presented in Table 4.13 and Figure 4.11. The detailed ambient air quality results have been presented in Appendix D. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 65 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report Table 4.13 Ambient Air Quality in the Study Area Parameter Units Observed AAQ1 AAQ2 Inferences (Village (Village Badi) Kawai) PM10 µg/m3 Maximum 72.3 70.1 The PM10 concentration recorded at Minimum 68.9 63.8 both the sampling locations was Average 70.60 66.95 within the National Ambient Air 98%le 72.23 69.97 Quality Standards (NAAQS). NAAQS 100 100 PM2.5 µg/m3 Maximum 21.3 26.9 The PM2.5 values were observed to be Minimum 19.1 20.4 within the prescribed NAAQS standards Average 20.20 23.65 (60 µg/m3). 98%le 21.26 26.58 NAAQS 60 60 SO2 µg/m3 Maximum 19.3 13.1 All the values were observed to be within Minimum 10.2 9.7 the prescribed NAAQS standards (80 Average 14.75 11.40 µg/m3). 98%le 19.12 12.93 NAAQS 80 80 NOx µg/m3 Maximum 26.4 27.7 All the values were observed to be within Minimum 24.8 23.7 the prescribed NAAQS standards (80 Average 25.60 25.70 µg/m3). 98%le 26.37 27.50 NAAQS 80 80 CO mg/m3 Maximum 0.84 0.82 CO values in the study area is well within Minimum 0.59 0.80 the prescribed NAAQS standards (2 Average 0.72 0.81 mg/m3) 98%le 0.84 0.82 NAAQS 2.0 2.0 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 66 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.11 Ambient Air Quality in Study Area www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 67 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report 4.2.9 Ambient Noise Quality The ambient noise levels within the study area was monitored at five (05) locations within the study area as provided in Table 4.14. Map showing noise monitoring locations have been presented as Figure 4.1. The Noise monitoring results were given in Table 4.15. Detailed results are provided in Appendix D. Table 4.14 Details of Noise Sampling Locations SN. Location Sample Zone Easting (mE) Northing (mN) Distance and direction Code from Project Site 1 Village Badi NQ1 43R 524781.45 2766087.45 ~ 170 m (W) of Unit 3 ~ 240 m (E) of Unit 2I 2. Village Kawai NQ2 43R 521597.23 2764645.67 ~ 600 m (E) of Unit 1 and ~ 650 m (W) of Unit 2 3 Village Bardawada NQ3 43R 518478.85 2763660.27 ~ 750 m (S) of Unit 1 4 Village Chaksodijar NQ4 43R 527070.85 2768162.78 ~ 880 m (NE) of Unit 3 5 Village Arnya NQ5 43R 518497.00 2766787.00 ~ 860 m (N) of Unit 1 Source: Note: The Coordinates have been presented in the UTM Format Table 4.15 Noise Level in the study area CPCB and WHO CPCB and WHO SN. Location Leq day Leq night limits* Leq limits Leq 1 Village Badi 54.82 55 43.89 45 2 Village Kawai 52.80 55 42.49 45 3 Village Bardawada 49.08 55 40.61 45 4 Village Chaksodijar 51.56 55 44.87 45 5 Village Arnya 53.24 55 37.20 45 * Note: As per CPCB, Day time is considered from 6 am to 10 pm and night time is considered from 10 pm to 6am; As per WHO limits, Day time is considered from 7 am to 10 pm and night time is considered from 10 pm to 7 am. Discussion of Results The observations from noise monitoring at 5 locations in the study area indicate that recorded Leq day and Leq night levels are within the specified standards for residential area i.e. 55 dB(A) and 45 dB(A) during day and night time respectively. The daytime noise levels at Badi village are at the edge of prescribed limits. 4.2.10 Water Availability and Quality 4.2.10.1 Ground Water Resources Ground Water Levels Variation of groundwater levels in an area is an important component of hydrological cycle because it is a physical reflection of aquifer systems. As the change in groundwater level is directly related to groundwater balance its continuous records provide direct information to subsurface geo environmental changes due to withdrawal of groundwater. To monitor the seasonal and year-by-year change in quantity and quality of groundwater, CGWB has established 19 National Hydrograph Stations (Jat, Jawad, Morban, Patan, Ratangarh, Singoli, Besla, Chachaor, Gota pipaliya, Jamalpura, Kukrashwar, Kundaliya, Girdola, Harkiyakhal, Nayagaon, Neemuch, Savan & Manasa) and 4 deep Piezometers (Jawad, Kukreshwar, Morban & Nayagaon) in Neemuch district. The monitoring of groundwater levels in these wells is being done by CGWB during the month of May, August, www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 68 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report November and January every year since seventies. It is observed that due to large-scale ground water development in the district the phreatic aquifers are being overexploited which results in erratic water level record from monitoring dug well. Depth of Water level The pre-monsoon depth to water level in Neemuch district ranges between 5.3 m bgl and 18.90m bgl. Major part of the district have water level in the range of 5-12 m bgl during the pre monsoon. During post-monsoon period, water level varies from 1.15m bgl to 22.75m bgl. In major part of the district, water level lies between 3 & 10 m bgl. Analyses of Groundwater level data of pre monsoon period indicate that there is declining trend in the range of 0.19 - 0.48 m/yr. 4.2.10.2 Water Availability Water availability at the watershed/ study area of Project site was evaluated using the online water risk assessment tool Aqueduct Water Risk Atlas developed by World Resource Institute (WRI) 1 and the India Water Tool (IWT). Eight (8) parameters were considered to evaluate water availability which consists of parameters such as Baseline Water Stress (BWS); Baseline Water Depletion (BWD); Inter Annual Variability (IAV); Seasonal Variability (SV); Availability Index (AI); Total Annual Rainfall (TAR), Hydrogeology, and Block Categorisation (BC). Table 4.16 presents the original and new classification of water risk indicators. Table 4.16 Classification of Water Risk Indicators Original Categorization (2) Modified Sr. Water Risk Indicator Categorization (3) No. 1 Baseline Water Stress (BWS) Low: <10% Low: <20% Low-Medium: 10-20% Medium: 20-40% Medium-High: 20-40% High: >40% High: 40-80% Extremely High: >80% 2 Baseline Water Depletion (BWD) Low: <5% Low: <5% Low-Medium: 5-25% Medium: 5-25% Medium-High: 25-50% High: >25% High: 50-75% 1 Hofst https://www.wri.org/publication/aqueduct-30 (2) Technical Note.Washington, DC: World Resources Institute. Available online at: https://www.wri.org/publication/aqueduct; India Water Tool (3) Modified by ERM www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 69 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Original Categorization (2) Modified Sr. Water Risk Indicator Categorization (3) No. Extremely High: >75% 3 Inter Annual Variability (IAV) Low: <0.25 Low: <0.25 Low-Medium: 0.25-0.5 Medium: 0.25-0.5 Medium-High: 0.5-0.75 High: >0.5 High: 0.75-1 Extremely High: >1 4 Seasonal Variability (SV) Low: <0.33 Low: <0.33 Low-Medium: 0.33-0.66 Medium:0.33-0.66 Medium-High: 0.66-1 High: >0.66 High: 1-1.33 5 Availability Index (AI) Extremely Low High Low Low-Medium Medium-High Medium High Low Extremely High 6 Total Annual Rainfall (TAR) Low (0-708 mm/year) High Low-Medium (709 -1104 Medium mm/year) Medium (1105-1500 mm/year) Medium-High (1501- Low 1896mm/year) High (1896+ mm/year) 7 Hydrogeological Map (HM) >40 (Unconsolidated) Low www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 70 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Original Categorization (2) Modified Sr. Water Risk Indicator Categorization (3) No. 25-40 (Unconsolidated) 10-25 (Unconsolidated) Medium <10 (Unconsolidated) 1-25 (Consolidated/semi- High consolidated) 1-10 (Consolidated/semi- consolidated) 1-5 (Consolidated/semi- consolidated) <1 (Hilly areas) 8 Block Categorisation (BC)1 Safe Low 1 The ground water resources are assessed in units, i.e., blocks/ talukas/ mandals/ watersheds. The blocks are generally be of the same size (or lesser) as the Talukas. These assessment units are categorized for ground water development based on two criteria - a) stage of ground water development, and b) long-term of pre and post monsoon water levels. The groundwater resources are typically assessed by CGWB (Central Ground Water Board) and categorized for groundwater development based on two (2) criteria: Stage of groundwater development; and Long-term trend of pre- and post-monsoon water levels The long-term groundwater level trends are computed generally for a period of ten (10) years. Based on the above, - -notified areas are further divided into the following categories: 'Safe' areas which have ground water potential for development; 'Semi-critical' areas where cautious groundwater development is recommended; 'Critical' areas and 'Over-exploited' areas, where there should be intensive monitoring and evaluation and future ground development will be linked with water conservation measures. The details of criteria for categorization of assessment units are provided in the table below. Criteria for groundwater categorisation Serial Stage of Groundwater Significant Long-term Decline Categorization No. Development Pre-monsoon Post-monsoon 1. <= 70% No No Safe 2. >70% and <=90% No No Safe Yes/No No/Yes Semi-critical 3. >90% and <=100% Yes/No No/ Yes Semi-critical Yes Yes Critical 4. >100% Yes/No No/Yes Over-Exploited Yes Yes Over-Exploited www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 71 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Original Categorization (2) Modified Sr. Water Risk Indicator Categorization (3) No. Semi-Critical Critical Medium Over-Exploited High The assessment against these parameters are described in Table 4.17. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 72 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Table 4.17 Parameters included to assess water availability S. Parameter Definition Analysis No. 1 Baseline Water Baseline water stress is defined as the ratio of the total annual water BWS map is presented in Figure 4.12. This map, originally Stress (BWS) withdrawals to the total available annual water renewable supply, developed for the world, also captures baseline water stress for accounting for upstream consumptive use. Higher value indicate the Project site. This map was developed based on BWS at the Aqueduct more competition among users. watershed- level for different regions of the world. The Project site fall in the region of extremely high baseline water stress. This High 2 Baseline Water Baseline water depletion measures the ratio of total water BWD map is presented in Figure 4.13. The Project site falls in the Depletion (BWD) consumption to available renewable water supplies. Total water High consumption includes domestic, industrial, irrigation and livestock risk of depletion. Aqueduct consumptive uses. Available renewable water supplies include surface and groundwater supplies and considers the impact of upstream consumptive water users and large dams on downstream water availability. Higher values indicate larger impact on the local water supply and decreased water availability for downstream users. 3 Inter Annual It indicates the variation in water supply from year to year. Inter Annual Variability (IAV) map is presented in Figure 4.14. Variability (IAV) This map, originally developed for the world, also captures IAV for study area. The Project site fall in the region of medium to high Aqueduct IAV. This indicates risk from inter-annual variability. 4 Seasonal Variability Seasonal variability indicates variation in water supply between SV map is presented in Figure 4.15. This map, originally (SV) months of the year. developed for the world, also captures SV for study area. The Project site fall in the region of medium-high seasonal variability Aqueduct indicating non-uniform availability of water supply over different month/seasons in a year. Hence, the water risk from seasonal High www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 73 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report S. Parameter Definition Analysis No. 5 Availability Index (AI) This indicator the Normalised Difference Water Index (NDWI)- is a AI map is presented in Figure 4.16. The Site fall in the region of remote sensing derived index estimating surface water availability by low to medium availability index indicating relatively lower India Water Tool recording water level in open surface water. Positive values are High typically open water areas and negative values are non-water water availability in the area. features (i.e. terrestrial vegetation, bare soil etc.). Source: National Aeronautics and Space Administration and U.S. Geological Survey, 2001-2016; Data processed with the support of the Earth Genome 6 Total Annual Rainfall This indicator is the arithmetic average of the annual rainfall recorded TAR map is presented in Figure 4.17. The Total Annual Rainfall (TAR) at all Meteorological stations under each district. is indicative of low replenishment of water in surface and India Water Tool Source: India Meteorological Department, 2004-2013 groundwater reservoirs. The risk of water availability is estimated Unit: mm High 7 Hydrogeological Map The indicator gives the broad types of geological formations Hydrogeological map (HM) for the Project site is presented in Unconsolidated, Semi-consolidated and Consolidated - that inform Figure 4.18. The map provides information on the aquifer yield of India Water Tool the groundwater potential and control the hydraulics of groundwater. hydrogeological formations in the regions where the Site is This is a relatively qualitative estimate based on the tentative water yielding potential of the geological unit and does not include the indicating lower possibility of aquifer recharge and hence has a groundwater availability in the region. likelihood of groundwater risk. Source: Central Ground Water Board, 2011 This was also corroborated by consultations with the community members Badi, Kavai and Bardawada villages. A total of 200- 250 dugwells and 300-400 tubewells were reported in these villages. General depth of the dugwells was reported in the range of 80-100 feet (24-31 m). General depth of tubewells was reported in the range of 450-800 feet (137- 245 m). Approximately 90 % of the dugwells and tubewells were reported with only seasonal water availability influenced by the rainfall. Only the tubewells located in www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 74 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report S. Parameter Definition Analysis No. the proximity of surface water bodies were reported to provide water to the community throughout the year. 8 Block Categorisation The ground water resources are assessed in units, i.e. blocks/ The Block category provides an understanding of the overall talukas/ mandals/ watersheds. These assessment units are status of groundwater in the block. Site region block (Jawad Block) India Water Tool categorized for ground water development based on two criteria - a) High risk of groundwater in stage of ground water development, and b) long-term of pre and post the area as groundwater development in the region is relatively monsoon water levels. The long term ground water level trends are less due to poor aquifers yield and productivity. computed generally for the period of 10 years. The significant rate of water level decline are taken between 10 to 20 cm per year depending upon the local hydrogeological conditions. There are four categories, namely - 'Safe' areas which have ground water potential for development; 'Semi-critical' areas where cautious groundwater development is recommended; 'Critical' areas; and 'Over-exploited' areas, where there should be intensive monitoring and evaluation and future ground development be linked with water conservation measures. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 75 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.12 Baseline water stress map Source: DC: World Resources Institute. https://www.wri.org/publication/aqueduct-30 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 76 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.13 Baseline water depletion map Source: Resources Institute. https://www.wri.org/publication/aqueduct-30 (2019) www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 77 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.14 Inter annual variability map Source: Resources Institute. Available online at: https://www.wri.org/publication/aqueduct-30 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 78 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.15 Seasonal variability map Source: Resources Institute. Available online at: https://www.wri.org/publication/aqueduct-30 (2019) www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 79 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.16 Availability index map www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 80 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.17 Total annual rainfall map www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 81 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.18 Hydrogeological map www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 82 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Overall Water Resources Availability Risk The overall water risk was evaluated based on groundwater and surface water risk. Groundwater risk was estimated based on Block Categorization and Hydrogeology while surface water risk was estimated based on Inter Annual Variability, Seasonal Variability, Availability Index and Total Annual Rainfall. Baseline Water Stress and Baseline Water Depletion were evaluated as risk factors common to both groundwater and surface water risk. For each asset, total water risk was evaluated based BWS and BWD while groundwater and surface water risks were evaluated based on the aforementioned individual factors. High high risk from BC and high risk based on stakeholder consultations. Surface Water High High high risk from BWD. 4.2.10.3 Water Quality Ground Water Quality The groundwater quality assessment was done to understand the baseline water (ground water) quality of the study area. The groundwater samples were collected from three (03) hand pumps from select villages in the study area. A map showing location of ground water sampling is presented in Figure 4.1. The details of water sampling locations are presented in Table 4.18. Table 4.18 Details of Water Sampling Locations SN. Location Sample Zone Easting (mE) Northing (mN) Code 1 School, Village Badi GW1 43R 524813.00 2765771.00 2. School, Village Kawai GW2 43R 521718.05 2764820.71 3. School, Village Bardawada GW3 43R 518628.25 2763257.42 Source: The groundwater samples obtained from within the Project AoI were analysed against the IS: 10500:2012 standards and the same have been shown below in Table 4.19 and discussed. Table 4.19 Groundwater Quality in the Study Area S.N. Parameter Unit GW1 GW2 GW3 IS: 10500, IS: 10500, 2012 Limits, 2012 Limits, Desirable Permissible Physico- Chemical Tests 1. 1 pH at - 7.04 6.93 7.2 6.5-8.5 No relaxation 2. 2 Temperature °C 25 25 25 --- --- 3. Electrical ms/cm 1.03 0.96 1.7 --- --- Conductivity 4. 3 Turbidity NTU 1.1 0.4 0.5 1 5 5. 4 Colour Hazen BDL BDL BDL 5 15 Chemical Parameters 6. Total Alkalinity mg/L 312 309.6 384 200 600 7. Total Dissolved mg/L 566 527 935 500 2000 Solids 8. Salinity ppt 0.16 0.19 0.43 --- --- 9. DO mg/L 6.9 6.3 6.2 --- --- 10. Chloride (as Cl) mg/L 69.43 87.7 218.8 250 1000 11. Fluorides as F- mg/L 1.4 0.61 0.34 1.0 1.5 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 83 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report S.N. Parameter Unit GW1 GW2 GW3 IS: 10500, IS: 10500, 2012 Limits, 2012 Limits, Desirable Permissible Total hardness (as 12. mg/L 284.2 399.4 564.5 200 600 CaCO3) 13. Sulphate (as SO4) mg/L 66.5 16.4 225.2 200 400 14. Nitrate (as NO3) mg/L 0.99 3.82 0.64 45 No Relaxation 15. Phosphate as PO4 mg/L <3 <3 <3 --- --- 16. COD mg/L <10 <10 <10 --- --- 17. BOD mg/L <5 <5 <5 --- --- Phenolic Compound 18. mg/L BDL BDL BDL 0.001 0.002 (as C6H5OH) 19. Iron (as Fe) mg/L BDL BDL BDL 0.3 No Relaxation 20. Mercury (as Hg) mg/L BDL BDL BDL 0.001 No Relaxation 21. Lead (as Pb) mg/L BDL BDL BDL 0.01 No Relaxation 22. Cadmium (as Cd) mg/L BDL BDL BDL 0.003 No Relaxation 23. Arsenic (As) mg/L BDL BDL BDL 0.01 0.05 24. Nickel as Ni mg/L BDL BDL BDL 0.02 No Relaxation 25. Copper (as Cu) mg/L BDL BDL BDL 0.05 1.5 26. Zinc (as Zn) mg/L 2.13 0.35 1.38 5 15 27. Manganese mg/L BDL BDL BDL 0.1 0.3 28. Calcium (as Ca) mg/L 27.6 129 129 75 200 29. Magnesium (as Mg) mg/L 51.6 18.4 58.1 30 100 Microbiological Parameters 30. MPN/10 Shall not be detectable in any Total Coliform 4 2 0 0ml 100 ml sample BDL: Below Detectable Limits Discussion of Results pH of the groundwater samples were found to be in the range of 6.9 7.2, which are in compliance to the IS 10500 standard of 6.5 to 8.5. Turbidity in the water samples ranges from 0.4 to 1.1 NTU, exceeds the acceptable limit (1 mg/l) in the permissible limit. TDS in the water samples was found to be between 527 to 935 mg/L and all the samples was found to exceed the acceptable limit of IS 10500 standard (500 mg/l) but is within permissible limit (2000 mg/l). Total Hardness values in the groundwater samples were found to be in the range of 284 to 564 mg/L and all the samples was found to exceed the acceptable limit of IS 10500 standard (200 mg/l) but is within permissible limit of (600 mg/l). Concentration of fluoride in groundwater sample collected from Village Badi was 1.4 mg/l, within the permissible limit of 1.5 mg/l of IS 10500. For other 2 samples it was observed to be within the desirable limits. Value of sulphate in water sample collected from village Bardawada was observed to be 225.2 mg/l, exceeds the acceptable limit (200 mg/l) but is within permissible limits (400 mg/l). Concertation of calcium in water samples collected from village Kawai and Bardawada was found to be 129 mg/l, exceeds the acceptable limit of (75 mg/l) IS 10500 but is within the permissible limit of 200 mg/l. Concentration of magnesium in water samples collected from village Badi and Bardawada was found to be in the range of 51.6 58.1 mg/l and was found to exceed the acceptable limit of IS 10500 standard (30 mg/l) but is within permissible limit (100 mg/l). www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 84 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Number of total coliform found in water sample collected from village Badi and Kawai was 4 and 2, respectively exceeds the standards as per IS 10500. Concentration of metal analysed in the samples comprising of Iron, Lead, Cadmium, Nickel, Copper, Zinc and Manganese was found to be within the acceptable limits. Surface Water Quality To understand the quality of surface water within the project AoI, two (02) surface water samples were collected and analysed against the designated best use classification of Central Pollution Control Board (CPCB) as given in Table 4.20 and the details of water sampling locations are presented in Table 4.21. Samples were taken from water bodies/lakes in and around the villages in the study area. Table 4.20 Water Quality Standards by CPCB for Best Designated Usage Class of Designated-Best-Use water Criteria Drinking Water Source A Total Coliforms Organism MPN/100ml shall be 50 or less without conventional pH between 6.5 and 8.5 treatment but after Dissolved Oxygen 6mg/l or more disinfection 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 C Total Coliforms Organism MPN/100ml shall be 5000 or less conventional treatment and pH between 6 to 9 disinfection Dissolved Oxygen 4mg/l or more Biochemical Oxygen Demand 5 days 20°C 3mg/l or less Propagation of Wild life and D pH between 6.5 to 8.5 Fisheries Dissolved Oxygen 4mg/l or more Free Ammonia (as N) 1.2 mg/l or less Irrigation, Industrial Cooling, E pH between 6.0 to 8.5 Controlled 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 Table 4.21 Details of Surface Water Sampling Locations SN. Location Sample Zone Easting (mE) Northing (mN) Code 1 Village Badi SW1 43R 525844.96 2765907.64 2. Village Kawai SW2 43R 521891.00 2767454.00 Source: The analysis results obtained are shown below: Table 4.22 Surface Water Sampling Results S.N. Parameter Unit SW1 SW2 Physico- chemical Tests 1. - 7.41 7.04 2. Temperature °C 25 25 Chemical Parameters www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 85 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report S.N. Parameter Unit SW1 SW2 3. Total Alkalinity mg/L 110.4 69.6 4. Total Hardness mg/L 122.9 65.3 5. DO mg/L 6.5 6.6 6. Chloride (as Cl) mg/L 37.6 5.8 7. Fluorides as F- mg/L 0.34 0.56 8. Sulphate (as SO4) mg/L 9.67 1.06 9. Nitrite mg/L <0.01 <0.01 10. Nitrate mg/L <0.1 <0.1 11. Total Nitrogen mg/L BDL 2.5 12. COD mg/L <10 <10 13. BOD mg/L <5 <5 14. Phenol mg/L <0.5 <0.5 15. Salinity ppt 0.09 0.04 16. Iron (as Fe) mg/L <0.1 <0.1 17. Silver mg/L <0.05 <0.05 18. Lead (as Pb) mg/L <0.01 <0.01 19. Cadmium (as Cd) mg/L <0.003 <0.003 20. Zinc (as Zn) mg/L <0.05 <0.05 21. Manganese mg/L <0.1 <0.1 22. Sodium (Na) mg/l 11.4 3.5 23. Potassium (K) mg/l BDL BDL 24. Total Phosphorus mg/l <1 1.7 25. Oil and grease mg/l <0.2 <0.2 Microbiological Parameters 26. Total Coliform MPN/100ml 210 84 BDL: Below Detectable Limits Discussion of Results Water sample collected from pond at village Badi have 210 MPN/100ml of total coliform, pH value 7.41 i.e. in the range of 6.5 and 8.5. Dissolved Oxygen 6.5 mg/l i.e. more than 5 and BOD value below detection level of 5 mg/l hence meet the criteria for Class B i.e. Outdoor bathing (Organised) Water sample collected from water body at village Kawai have 84 MPN/100ml of total coliform, pH value 7.04 i.e. in the range of 6.5 and 8.5. Dissolved Oxygen 6.6 mg/l i.e. more than 5, and BOD value below detection limit of 5 mg/l hence meet the criteria for Class B i.e. Outdoor bathing (Organised). 4.2.11 Soil Quality As per the groundwater information booklet for Neemuch District by Central Ground Water Board 2013; the district is generally covered with black cotton soils covering almost three fourths of the area. Remaining area has red-yellow mixed soils and alluvial soils along the river courses. Soil Quality Monitoring & Analysis The soil characteristics within the study area, especially the physical quality and fertility of the soil have been characterized by analysing the soil sample collected from 5 locations within the study area. Table below provides details of soil sampling locations. Soil sampling locations are presented in Figure 4.1. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 86 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Table 4.23 Soil Sampling Locations in the Study Area Location Location Co-ordinates Selection Criteria Code SQ1 Project Site - Unit 1 519757.02 m E Project Site 2765040.96 m N SQ2 Project Site - Unit 2 522448.99 m E 2765231.03 m N SQ3 Forest Area 522141.11 m E Forest land 2768576.85 m N SQ4 Village Badi 526507.13 m E Scrub land 2764879.31 m N SQ5 Village Lardpura 518018.71 m E Agricultural land 2762850.34 m N Source: The soil quality analysis results are presented in Table 4.24 and described in the further subsections. Table 4.24 Results of Soil Analysis S. No Parameter Unit SQ1 SQ2 SQ3 SQ4 SQ5 1 Particle size distribution Sand % 88.4 88.9 84.7 78.8 74.3 Silt % 4.1 3.3 5.3 8.4 14.3 Clay % 7.5 7.8 10.0 12.8 11.4 Loamy Loamy Loamy Sandy Sandy 2 Texture - Sand Sand Sand Loam Loam 3 Bulk Density g/cm3 1.45 1.82 1.75 1.8 1.61 4 pH - 6.48 7.23 6.1 7.21 7.78 mmhos/ 5 Electrical Conductivity 0.292 0.12 0.086 0.1 0.41 cm 6 Moisture Content % 9 2.7 0.01 3.2 6.4 meq/10 7 Cation Exchange Capacity 35.3 31.9 34.6 31.4 56.3 0gm 8 SAR - 1.21 0.23 0.28 0.24 6.74 9 Water Holding Capacity % 44.5 36.4 36.7 35.1 42.6 11 Total Nitrogen mg/kg 153.1 290.6 110.8 126.7 348 12 Sulphate mg/kg 49 16.4 17.1 BDL 60.3 13 Chloride mg/kg 67.3 38.4 38.4 75.3 104.6 14 Sodium (Na) mg/kg 81.5 14 15.2 13.8 415.8 15 Total Potassium (K) mg/kg 598.4 661.8 877.7 718.2 933.7 16 Calcium (Ca) mg/kg 4378.5 4587.8 2284.2 3432.2 1906.8 17 Magnesium (Mg) mg/kg 1313.5 688.2 1370.5 915.2 1144.1 18 Permeability cc/gm 0.02 0.02 0.02 0.03 0.21 Discussion of Results pH: Generally, soil pH in the range of 6.50-7.00 is considered to be best suited for growing most crops. The pH level in soil samples was recorded to be within a range of 6.1-7.78 indicating slightly acidic to slightly alkaline pH. Electrical Conductivity: Electrical Conductivity is used to estimate the soluble salt concentration in soil, and is commonly used as a measure of salinity. The EC value of soil samples were recorded to be within a range of 0.08 micromhos/cm to 0.4 micromhos/cm which can be assessed to be average for germination. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 87 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Sodium Adsorption Ratio (SAR): The sodicity (1) hazard of soil, which affects water infiltration in the soil is expressed as the Sodium Adsorption Ratio (SAR). Soil with high level of exchangeable sodium may cause dispersion of soil particles leading to the replacement of major cations (calcium and magnesium) adsorbed on the soil. This could possibly lead to deterioration of soil structures and water infiltration problems. The SAR value in the soil was observed to be 0.23 6.74 (agricultural land parcel). Total Nitrogen: Value of total nitrogen in the soil samples ranges from 110 to 348 (agricultural land). Total Potassium: Value of total potassium in the samples collected ranges from 598.4 - 933.7 mg/kg. Water holding capacity: Water Holding Capacity in the samples ranges from 35.1-44.5%. 4.2.12 Traffic Monitoring Traffic survey was conducted at the access road of the Neemuch Solar Park within the study area to assess the traffic scenario of the area. Detail of traffic survey locations is given in Table 4.25 below. Table 4.25 Description of Traffic Count Survey Location Sampling Location Distance & Direction w.r.t Justification for Selection of Project Site Location State Highway (SH)- 9A, Bhilwada ~ 2.5 km, South Access road to the project site Modak Road The summarised results of the traffic survey are given in Table 4.26. The percentage composition of different vehicle categories is shown in Table 4.27 and Figure 4.19. Refer Appendix D for detail results of traffic survey. Table 4.26 Existing Traffic (Motorised) Volumes in Study Area Description Access road Total Traffic (Vehicle Nos.)/24 Hours (To & fro) 2208 Average Traffic Flow/Hr 184 Max Traffic Flow (Nos)/Hr 213 Min Traffic Flow (Nos)/Hr 16 Max Traffic Flow (Time- hours) 12:00-13:00 Min Traffic Flow (Time-hours) 04:00-06:00 Table 4.27 Percentage Composition of Vehicles in Study Area Location (%) Percentage Composition Two Wheeler Three Wheelers LMV HMV Non- motorised SH 9A 58 1 16 22 2 Note: Non-Motorised includes cycles, rickshaws, bullock carts, horse carts; Two wheelers include scooters, motorcycles, Mopeds; Three wheelers include auto; Light motor vehicles (LMVs) include passenger cars, metadors, tractors, tempos, jeeps, van.; Heavy Motor Vehicles (HMVs) include buses, trucks, dumpers, tankers and trailers. (1) Sodicity is a term given to the amount of sodium held in a soil. Sodium is a cation (positive ion) that is held loosely on clay particles in soil. It is one of many types of cations that are bound to clay particles in soil. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 88 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.19 Percentage Composition of Different Vehicles Categories Percentage Composition of different Vehicle Category 2 22 58 16 1 TWO WHEELERS THREE WHEELERS LCV,S HCV,S NON MOTORISED Two wheelers contribute to maximum, 58% of the total traffic on the road followed by heavy motor vehicles (22%) and light motor vehicles (16%). Three wheelers and non-motorised vehicles contribute to 1 and 2% respectively. Saturation capacity (V/C ratio) of the road is presented in Table 4.28 below. Table 4.28 Saturation Capacity of the access road S. No Name of the Road No. of Lane Carrying Present PCU V/C ratio Capacity 1 SH 9A 2 lane (two way) 1500 PCU per 177 0.12 hour As shown in table above Saturation capacity (V/C ratio) of the State Highway 9A is 0.12. It indicates that adequate capacity is available and vehicles are not expected to experience significant queues and delays. 4.3 Biological Environment- Flora and Fauna An ecological survey was undertaken from 19 to 21 December 2019 at the proposed Neemuch Project site. The daytime temperatures varied between 28° C and 30° C. The night-time temperatures varied between 14° C and 16° C. No rain events had occurred leading up to the site assessment. A rapid ecological survey was conducted to establish an ecological baseline and identify any sensitive ecological receptors within an Area of Influence (AoI) from the Project. The site assessment was undertaken in the month of December, which represents the peak migratory season in India and several bird species travel from North Asia and Europe to the Indian subcontinent. The site assessment therefore also included an assessment of water bodies in the surrounding region to determine extent of migratory bird activity. 4.3.1 Objectives The ecological surveys were conducted with the following objectives: Flora Identification of sensitive habitats and forest land falling within the Project site and adjoining areas; Classification of flora for any endangered, protected or endemic floral species prevailing in the study area based on the field surveys; and www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 89 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Identification of areas protected under international conventions, national or local legislation and those recognized nationally and internationally for their ecological, landscape, cultural or other related value. Fauna Identification of fauna (specifically birds, mammals, reptiles and amphibians) based on direct sightings, calls, pugmarks, droppings, nests, etc.; Identification and classification of any species recognized as threatened (in accordance with International Union for the Conservation of Nature [IUCN] Red List Version 2019-3) and in accordance to the schedules of the Wildlife (Protection) Act, 1972 and as amended; and Identification of areas which are important or sensitive for ecological reasons including their breeding, nesting, foraging, resting, over-wintering areas including wildlife migratory corridors/avian migratory routes. 4.3.2 Approach and Methodology Study Area The study area of the ecological surveys has been determined as follows: Project footprint: fenced Solar Park housing the modules, control room, SCADA building and open space for future expansions with a total area of 1065.7 ha across the three units. Area of Influence: 5 km radius from the Solar Park that has been identified in past studies1 as a reasonable estimate for bird and bat movement on a regular basis and therefore representation of species that could be affected by the under-construction and operational Solar Park. The study area for the ecological surveys varies from the environmental baseline due to the relatively longer range of biological receptors and to capture movement of the potentially affected species. Secondary Baseline Data Collection The secondary baseline data for the ESIA has been compiled through the following data sources: Sr. Source Purpose Version Link No. 1 WII Envis Centre To identify list of National - http://wiienvis.nic.in/ Parks [NP], Wildlife Sanctuaries [WLS], Conservation Reserves, Biosphere Reserves and Community Reserves in the District/State 2 Important Bird and To identify locations and - http://datazone.birdlife.org/home Biodiversity Areas purpose of various IBAs (IBAs) across the country. 3 UNESCO World To identify proximity to any - whc.unesco.org Heritage Site UNESCO World Heritage Sites 1 ERM has carried out extensive bird and bat studies across India and identified that typical bird pathways (migration, foraging and movement) can be understood through a study across the 5 km radius of a wind/solar project. The 5 km radius allows for the determination of sensitive habitat (e.g. forest land or large reservoirs) in the surrounding region and how spillover from those habitats may occur in the solar compound. If there are sensitive habitats immediately outside the 5 km study area, then the same is considered while undertaking the site assessment to determine presence/absence of threatened or protected fauna. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 90 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Sr. Source Purpose Version Link No. 4 Alliance for Zero To identify proximity to any - https://zeroextinction.org/ Extinction Sites declared Alliance for Zero Extinction Sites 5 IUCN Red List To determine the IUCN Red 2019-3 https://www.iucnredlist.org/ List (threatened) status of various flora and fauna, research more details about the behavior, location and habitat of the species and for spatial distribution maps of the species based on the latest available research information. 6 Forest Working To obtain a district-level list - None; hard copy obtained from Plan of flora and fauna found Neemuch Forest Department. based on Forest Department surveys. Note: all above data sources have been accessed as of 31 May, 2020. Habitat Surveys The various habitats within the study area were identified using Google Earth Pro to determine the types and extent of habitats in the 5 km radius of the Project site. These habitats were marked and visited during the site reconnaissance to identify the quality and level of disturbance at these habitat locations. Floral Analysis The floral diversity of the study area was recorded by visual observations during the site visit, discussions with local communities/stakeholders and review of scientific publications available in the public domain. Faunal Analysis Faunal species were recorded based on direct sightings, indirect evidences (dung, droppings, scat, pugmarks, scratch signs, burrow, nests, etc.) and consultations with local communities. The consultations with local communities was undertaken by displaying pictorial representation of species that are expected in the study are of the Solar Park. The pictorial representation that has been used has been taken from ecology field guides for avifauna 1 and mammals 2. The species occurring within the study area were surveyed using the following methodologies: Amphibians: amphibians are often restricted to natural and constructed ponds during the hottest parts of the day 3. All such water bodies were visited during the late morning-afternoon session to determine presence of amphibians along the shaded ledges of the water body. 1 Grimmet, R. Inskipp, C. and Inskipp, T. 2013. Birds of the Indian Subcontinent - Second Edition. Published by Christopher Helm, 49-51 Bedford Square, London. 2 Menon, V. 2014. Indian Mammals: A Field Guide. Hachette, India. 3 Knutson et. Al. 2005. Agricultural ponds support amphibian populations. Ecological Applications. 14 (3): 669-684. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 91 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Reptiles: reptile presence was determined through the use of intensive time constrained search methods 1 2. The method was adapted for the terrain by targeting rocks and logs located around water bodies or recently dried streams, hedges and along the trunks of dense vegetation. Avifauna: An adapted avifaunal survey method for onshore wind farm assessments was utilized for the purpose of the study 3. The adapted survey method focuses on key habitat features to cover, preferred time of day to ensure maximum bird activity and techniques to determine nocturnal bird activity. Any avifaunal species that was identified by visually sighting or hearing of bird calls was recorded. Birds were identified along motorable roads, around water bodies and in high density vegetation areas during the hottest parts of the day. Binoculars and standard field guides 4 were used for avifaunal identification. Mammals: Mammal surveys were conducted along motorable roads, near water bodies and in grassy terrain. Individuals were identified through indirect methods such as pellets, tracks, paw marks and scat. Species were then identified using standard literature 5 6. 4.3.3 Habitat Mapping The 5 km study area is categorized by a mosaic of agricultural and scrubland but the land parcels for the three units falling within the Neemuch project are largely located on scrubland. The Arnea Block Reserved Forest is located ~ 300m north of the northern boundary of Unit 2 and continued along the northern end of the study at a distance of between 300 m and 1 km from the Neemuch Project site. The breakdown of agricultural land, scrubland and forest land within the 5 km study area has been presented in Table 4.3. The photo-documentation of the key habitats has been presented in Figure 4.20. Figure 4.20 Habitats in the study area Scrubland Forest Land (in the background) 1 Welsh, H.H. jr. 1987. Monitoring herpetofauna in woodlands of north-western California and south west Oregon: a comparative strategy. Pp. 203-213. In. Multiple Pillisbury (eds. Gen. Tech. Regional Environmental Planning. PSW 100) US Department of Agriculture, Forest Service. 2 Welsh H.H. Jr. and Lind, A. 1991. The structure of the herpetofaunal assemblage in the Douglas-fir/hardwood forest of norther western California and southwestern Oregon. Pp 395-411. In: Wildlife and vegetation of unmanaged Douglas-fir forests. (Tech. Coords). L.F. Ruggiero, K.B. Aubry, A.B. Carey and M.H. Huff. Ge. Tech. Rep. PNW-GTR-285. Portland, OR: US Department of Agriculture, Forest Service. 4 Grimmet, R. Inskipp, C. and Inskipp, T. 2013. Birds of the Indian Subcontinent - Second Edition. Published by Christopher Helm, 49-51 Bedford Square, London. 5 Prater, S.H. 2005. The Book of Indian Animals. Bombay Natural History Society and Oxford University Press 12th Edition. Pp 316 6 Menon, V. 2003. A field guide to Indian Mammals. Dorling Kindersley (India) Ltd. New Delhi. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 92 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Dried Canal (natural) Water Body Agricultural Land Water Body Surveys The study area consists of four (04) water bodies with water availability. Each of the water bodies was visited to determine presence of aquatic bird species and understand the migratory bird activity. The list of the water bodies has been presented in Table 4.29. Table 4.29 Water bodies surveyed near the wind farm Sr. Water body Latitude Longitude Availability Distance from Solar Park No. of Water 1 Water Body 25° 00' 09.57" 75° 15' 29.14" Yes Adjacent to the southern end of near Unit 3 N E Unit 3. 2 Brahmi 24° 58' 37.30" 75° 11' 59.19" Yes 1.5 km south of the Unit 1 of the River N E Solar Park at the point closest to the Project site. 3 Kawai Lake 25° 01' 23.90" 75° 13' 07.29" Yes 450m west of the Unit 2 of the N E Solar Park. 4 Mandol 25° 03' 59.36" 75° 16' 27.53" Yes 4.5 km north of Unit 3 of the Solar Dam N E Park. Three of the four water bodies Water body adjacent to Unit 3, Kawai Lake and Mandol Dam were check dam structures that are used for irrigation during the dry seasons. All four water bodies had received significant rain during the previously concluded monsoon season (i.e. September, 2019) and therefore had high water availability during the survey. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 93 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Agricultural Lands The agricultural land consists of rain-fed agricultural crops including soybean (Glycine max), maize (Zea mays) and wheat (Triticum aestivum). Agricultural land is largely found along the southern end of the 5 km study area along State Highway 9A and abutting villages. Scrublands Scrublands are the primary type of vegetation found within the study area and consists of monotypic vegetation composition of dry climate specialists. 4.3.4 Floral Analysis The vegetation profile of the region that indicates the type of vegetation has been presented in Table 4.30. The forest habitat in the area has been classified as tropical dry deciduous forest as per Champion and Seth (1968) Classification1. Table 4.30 Vegetation profile of the Project site Classification Scheme Classification Biogeographical Provinces of India2 4B: Semi-Arid Punjab Plains Agro Ecological Sub Region (ICAR)3 Hot moist semi-arid ecological sub region (5.2) Agro-Climatic Zone (Planning Commission)3 Western Plateau and Hill region (IX) Agro-Climatic Zone (NARP)3 Malwa plateau zone (M P-10) The flora found around the 5 km study area has been presented in Table 4.31. Table 4.31 Flora in the study area S. No. Family Name Scientific Name 1. Anacardiaceae Lannea grandis 2. Apocynanceae Holarrhena antidysenterica 3. Burseraraceae Boswellia serrata 4. Calastraceae Gymnosporia spinosa 5. Combretaceae Anogeissus latifolia 6. Anogeissus pendula 7. Flacourtiaeceae Flacourtia indica 8. Leguminosae Acacia catechu 9. Butea monosperma 10. Cassia fistula 11. Malvaceae Sterculia urens 12. Rutaceae Aegle marmelos 13. Sterculiaceae Helicteres isora 14. Verbenaceae Lantana camara The species identified in the area were largely dry deciduous trees and none of the species had been identified as threatened under the latest IUCN Red List (2020-21). 4.3.5 Faunal Analysis The above search techniques (Section 4.3.2) were used to identify the target fauna herpetofauna (amphibians + reptiles), avifauna and mammal species. The subsequent sections provide the list of observed and recorded fauna in the study area. 1 Champion, H.G. and Seth, S.K. 1968. A revised survey of foret types of India. 404 pp. 2 http://wiienvis.nic.in/Database/HtmlPages/bioprovincemap.htm 3 http://agricoop.nic.in/agriculturecontingency/neemuch www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 94 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Herpetofauna One (01) herpetofauna was observed and three (03) herpetofauna were reported from the study area of the Project. None of the identified species has been threatened under the latest IUCN Red List (Version 2019-3) but one species i.e. Bengal Monitor Lizard (Varanus bengalensis) that has been reported in community consultations is protected under Schedule I of the Wildlife Protection Act, 1972. Table 4.32 Herpetofauna observed/reported in the study area Sr. Common Name Scientific Name IUCN Red List Wildlife Observed/ No. Status (Online Protection Act Reported Version 2019-2) Schedule 1. Oriental Garden Lizard Calotes versicolor -- -- Observed 2. Python Python molurus -- Schedule I Reported 3. Bengal Monitor Lizard Varanus bengalensis LC Schedule I Reported 4. Common Rat Snake Zamenis muscosus - Schedule II Reported Note: LC = Least Concern Reported species have been identified in the Forest Working Plan for Neemuch District. An initial filter has been used for the species identified in the working plan to determine if the habitats found in the Project study are preferred by the species listed. The photo-documentation of the observed herpetofauna has been provided in Appendix A. Avifauna A total of fifty eight (58) bird species were recorded from the study area out of which only ten (10) have been reported and forty eight (48) were observed. Among the observed bird species, two species i.e. Common Pochard (Aythya ferina) and Woolly-necked Stork (Ciconia episcopus) were classified as Vulnerable in the latest IUCN Red List (Version 2019-3). One species Black-headed Ibis (Threskiornis melanocephalus) has been classified as Near Threatened in the latest IUCN Red List. Nine (09) of the 39 observed species that is 19% of the total species observed during the study are migratory. Raptor activity was minimal within the 5 km study area but several individuals of the commonly found and protected species under the Wildlife Protection Act, 1972 - Black Kite (Milvus migrans) and Black-winged Kite (Elanus caeruleus) were observed in surrounding villages. The ten reported species included the protected Shikra (Accipter badius), White-rumped Vulture (Gyps bengalensis), Indian Peafowl (Pavo cristatus), Egyptian Vulture (Neophron percnopterus) and Oriental Honey Buzzard (Pernis ptilorhynchus). Among the protected species, White-rumped Vulture is classified as Critically Endangered and Egyptian Vulture as Endangered under the latest IUCN Red List (Version 2020-1). . The above species have been reported from Menal River and within the Arnea Reserve Forest Block and contiguous forest land that is located at the northern end of the study area (~ 1-5 km north of the Neemuch units). The species has been reported across multiple sources ebird.org, Forest Working Plan for Neemuch District and community consultations. Over the course of the site visit, several livestock carcasses were observed along the access roads to the Project site but no vulture activity was found along these carcasses. The carcasses were largely being scavenged by the common Jungle Crow ( Corvus splendens) and street dogs/cats. There are reports of vulture activity in the area 1 but none was observed or reported in consultations with the local community. 1 Ebird.org, IUCN Red List, India Biodiversity Portal and media articles (e.g. https://indiasendangered.com/more-vultures-in- madhya-pradesh/) www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 95 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Table 4.33 Avifauna observed/reported in the study area Sr. Common Name Scientific Name Migratory IUCN Red Wildlife Observed/ No. Status List Protection Reported Status Act (Online Schedule Version 2019-3) 1. Shikra Accipter badius R LC I Reported 2. Common Myna Acridotheres tristis R LC IV Observed 3. White-breasted R Waterhen Amaurornis phoenicurus LC IV Reported 4. Northern Pintail Anas acuta M LC IV Observed 5. Common Teal Anas crecca M LC IV Observed 6. Indian Spot-billed Duck Anas poecilorhyncha R LC IV Observed 7. Bar-headed Goose Anser indicus M LC IV Observed 8. Great Egret Ardea alba R LC IV Observed 9. Intermediate Egret Ardea intermedia R LC IV Observed 10. Indian Pond Heron Ardeola grayii R LC IV Observed 11. Spotted Owlet Athene brama R LC IV Reported 12. Common Pochard Aythya ferina R VU IV Observed 13. Livestock Egret Bubulcus ibis R LC IV Observed 14. Red-rumped Swallow Cecropis daurica R LC IV Observed 15. Southern Coucal Centropus sinensis R LC IV Observed 16. Woolly-necked Stork Ciconia episcopus R VU IV Observed 17. Black Stork Ciconia nigra M LC IV Observed 18. Common Pigeon Columba livia R LC - Observed 19. Indian Robin Copsychus fulicatus R LC IV Observed 20. Indian Roller Coracias benghalensis R LC IV Observed 21. Jungle Crow Corvus macrorhynchos R LC V Observed 22. Black Drongo Dicrurus macrocercus R LC IV Observed 23. Little Egret Egretta garzetta R LC IV Observed 24. Black-winged Kite Elanus caeruleus R LC I Reported 25. Asian Koel Eudynamys scolopaceus R LC IV Reported 26. Francolinus R Grey Francolin pondicerianus LC IV Observed 27. Eurasian Coot Fulica atra R LC IV Observed 28. Chestnut-shouldered R Petronia Gymnoris xanthocollis LC IV Observed 29. White-rumped Vulture Gyps bengalensis R CR I Reported 30. White-throated R Kingfisher Halcyon smyrnensis LC IV Observed 31. Black-winged Stilt Himantopus himantopus R LC IV Observed 32. Long-tailed Shrike Lanius scach R LC IV Observed 33. Green Bee-eater Merops orientalis R LC - Observed 34. Little Cormorant Microcarbo niger R LC IV Observed 35. Black Kite Milvus migrans R LC I Reported 36. White Wagtail Motacilla alba R LC IV Observed 37. Egyptian Vulture Neophron percopterus R EN I Reported 38. House Sparrow Passer domesticus R LC IV Observed 39. Indian Peafowl Pavo cristatus R LC I Reported www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 96 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Sr. Common Name Scientific Name Migratory IUCN Red Wildlife Observed/ No. Status List Protection Reported Status Act (Online Schedule Version 2019-3) 40. Oriental Honey R Buzzard Pernis ptilorhynchus LC I Reported 41. Great Cormorant Phalacrocorax carbo R LC IV Observed 42. Indian Cormorant Phalacrocorax fuscicollis R LC IV Observed 43. Baya Weaver Ploceus philippinus R LC IV Observed 44. Plain Prinia Prinia inornata R LC IV Observed 45. Rose-ringed Parakeet Psittacula krameri R LC IV Observed 46. Red-vented Bulbul Pycnonotus cafer R LC IV Observed 47. Pied Bushchat Saxicola caprata R LC IV Observed 48. Common Stonechat Saxicola torquatos M LC IV Observed 49. Spotted Dove Spilopelia chinensis R LC IV Observed 50. Little Grebe Tachybaptus ruficollis R LC IV Observed 51. Ruddy Shelduck Tadorna ferruginea M LC IV Observed 52. Threskiornis R Black-headed Ibis melanocephalus NT IV Observed 53. Wood Sandpiper Tringa glareola M LC IV Observed 54. Common Greenshank Tringa nebularia R LC IV Observed 55. Green Sandpiper Tringa ochropus M LC IV Observed 56. Large Grey Babbler Turdoides malcolmi R LC IV Observed 57. Common Hoopoe Upupa epops R LC IV Observed 58. Red-wattled Lapwing Vanellus indicus R LC IV Observed Note: LC = Least Concern, NT = Near Threatened, VU = Vulnerable, CR = Critically Endangered, EN = Endangered, M = Migratory, R = Resident, IV = Schedule IV and I = Schedule I Reported species have been identified in Forest Working Plan for Neemuch District and ebird.org The photo-documentation of the observed avifauna has been provided in Appendix A. As the site assessment was undertaken during the winter migratory season, the presence of flocking behavior among avifaunal species was determined. Several species were observed to be flocking along the northern end of the water body adjacent to Unit 3 and therefore adjacent to the site limits of Unit 3 of the Neemuch Site. The species included the Bar-headed Geese (Anser indicus), Common Teal (Anas crecca), Black Stork (Ciconia nigra), Ruddy Shelduck (Tadorna ferrigunea) and Intermediate Egret (Ardea intermedia). The same flocking behavior was identified in a small watering hole along the way to water body adjacent to Unit 3. Some pictures of flocking behavior have been provided in Figure 4.21. Figure 4.21 Flocking behaviour in Water body adjacent to Unit 3 and a small pond along the way www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 97 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report The water body may support small congregations1 of the Vulnerable Woolly-necked Stork (Ciconia episcopus) as observed at the time of the site visit. The species is known to be either individual or breeding in pairs2 but occasionally displays flocking in areas with large water availability. The presence of several individuals in the study area indicates that the species may be consistently flocking to these water bodies year upon year due to the larger water availability. Mammals Twelve (12) species were identified in the study area of the Project, of which, six (06) were directly observed during the site visit. All six species observed in the study area are not threatened under the latest IUCN Red List (Version 2019-3) or protected under the Wildlife Protection Act 1972. The reported species have been identified based on discussions with the local community and review of the Forest Working Plan for Neemuch District. The reported species are more commonly found in the Arnea Reserve Forest block and contiguous habitat that is located >1 km north of the proposed Project site. Villagers residing within the Badi and Kawai Village have indicated that the reported species are rarely found in the daytime but occasionally seen at the outskirts of the forest land during early morning and evening hours. Table 4.34 Mammals observed/reported in the study area Sr. Common Name Scientific Name IUCN Red List Wildlife Observed/ No. Status (Online Protection Act Reported Version 2019-2) Schedule 1. Nilgai Boselaphus tragocamelus LC III Observed 2. Jackal Canis aureus LC II Observed 3. Sambar Cervus unicolor VU III Reported 4. Five-striped Palm Squirrel Funambulus pennanti LC IV Observed 5. Indian Grey Mongoose Herpestes edwardsii LC II Observed 6. Black-naped Hare Lepus nigricollis LC IV Reported 7. Sloth Bear Melursus ursinus VU II Reported 8. Leopard Panthera pardus VU I Reported 9. Indian Flying Fox Pteropus giganteus LC V Observed 10. Northern Plains Langur Semnopithecus entellus LC II Observed 11. Wild Boar Sus scrofa LC III Reported 12. Bengal Fox Vulpes bengalensis LC II Reported Note: LC = Least Concern, VU = Vulnerable, I = Schedule I, II = Schedule II, III = Schedule III and IV = Schedule IV Reported species have been identified in the Neemuch Forest Working Plan. The photo-documentation of the observed mammals has been provided in Appendix A. . 1 The congregations have not been reported in public domain or across conservation websites (e.g. Bird Life International) to be nationally or regionally significant. 2 https://www.iucnredlist.org/species/22727255/110064997 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 98 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report community consultations. The bat roosting site is located within a temple with several Banyan Trees (Ficus benghalensis) that is approximately 2.2 km south of Unit 1 of Neemuch Project. Approximately 80 individuals were determined to be found in the bat roosting colony as estimated by direct observation and community consultations. 4.3.6 Proximity to areas of ecological significance The areas of ecological significance encompasses legally protected areas (national park, wildlife sanctuaries, conservation reserves, community reserves, nationally protected wetlands and biosphere reserves) as well as internationally recognized biodiversity areas (Important Bird and Biodiversity Areas, Alliance for Zero Extinction Sites and UNESCO World Heritage sites). The closest areas of ecological significance have been provided below: Legally Protected Areas: the closest legally protected area is Gandhi Sagar Wildlife Sanctuary, [IUCN Management Category IV] which is located ~ 50 km southeast of Unit 3. The sanctuary is contiguous with Rana Pratap Sagar Dam, which is located ~32 km southeast of Unit 3. The Gandhi Sagar Wildlife Sanctuary is also declared an Important Bird Area (IBA) and supports significant concentrations of waterbirds (IBA Category A4iii). Internationally Recognized Biodiversity Areas: The closest internationally recognized biodiversity area is Gandhi Sagar Wildlife Sanctuary and reservoir. Unlike the wildlife sanctuary, the Gandhi Sagar IBA includes the Rana Pratap Sagar Dam and is located ~ 32 km southeast of Unit 3. The Rana Pratap and Gandhi Sagar Dams are large water bodies located > 30 km from the Project site and there is no habitat contiguity from the Project site to the dams. Two rivers namely Menal River located 7 km north of the Project site and Brahmi River located 1.8 km south of the Project site do however drain into the Rana Pratap Dam. There appears to be some spillover of bird congregations from the dam reservoirs to the larger water bodies in the study area, as has been observed with the flocking behaviour in water body adjacent to Unit 3 (See Figure 4.21). 4.3.7 Migratory Pathways India lies along the Central Asian Flyway, a global migratory pathway that connects the Palearctic (Europe and Northern Asia) to the Indian subcontinent. The birds that utilize this flyway, travel south to the Indian subcontinent between October-early December depending on the end of the monsoon season and remain in the country till February-March. In the year 2019, the seasons were slightly delayed and therefore the country witnessed rains till late September, potentially delaying the winter migrations by 2-3 weeks. The site visit from 19-21 December therefore represented the early to peak migratory season transition period instead of the peak migratory season.) Bird species travelling along the Central Asian Flyway, utilize several large water bodies across India as congregation sites or rest stops. The number of bird species found during the study had approximately 20% migratory species including congregations of the migratory Bar-headed Geese (Anser indicus) and Common Teal (Anas crecca). The details of the Central Asian Flyway and closest rest stop has been provided in Figure 4.22. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 99 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.22 Central Asian Flyway Source: http://datazone.birdlife.org/userfiles/file/sowb/flyways/7_Central_Asia_Factsheet.pdf The migratory pathways of the two species Bar-headed Geese and Common Teal that is found to be congregating near the Project site has been provided in Figure 4.23. The figure indicates that both species have a non-breeding range that seems to overlap with the Project site. The migratory pathways of both species appears to connect to Gandhi Sagar Dam. Figure 4.23 Migratory pathways of Anser indicus and Anas crecca Source: Balachandran, S., Katti, T. and Manakadan, R. 2018. Indian Bird Migration Atlas. BNHS India. Oxford University Press. Pp 215. 4.3.8 Applicability of natural, modified and critical habitat As indicated in Table 4.32, Table 4.33 and Table 4.34, no species of conservation importance (threatened under the latest IUCN Red List) have been observed in the study area with the exception www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 100 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report of the Vulnerable Common Pochard and Vulnerable Woolly-necked Stork. The terrestrial habitat largely consists of agricultural and scrubland, both of which have signs of development and are not supporting species of conservation value. The Project site and 5 km study area is largely modified habitat but no species of significant biodiversity value have been identified and therefore IFC PS 6 provision of conserving modified habitat of significant biodiversity value is not applicable for the Project site. The Project site and 5 km study area has natural habitat only within the Arnea Reserve Forest Block located ~ 300m north of the proposed site. This forest block is not being directly impacted by the siting of Project components and associated facilities. There might be potential for indirect impact such as human-wildlife conflict, which has been specifically discussed in the impact assessment section (Section 6.3). As there will be no loss of natural habitat, the provisions of conserving natural habitat under IFC PS 6 is not applicable for the Project. There are no species classified as critically endangered or endangered, no determination of restricted-range species identified and no significant congregations or migration rest stops in the area, the criterion 1, 2 and 3 of critical habitat has not been determined to be applicable for any of the terrestrial habitat in the Project site. Two exceptions to the above conclusion were further determined presence of migratory and congregatory species in the water body near Unit 3 and potential critical habitat applicability due to presence of vulture species. These exceptions have been discussed in subsequent paragraphs. The water body near Unit 3 does support migratory and congregatory bird behaviour. The ESIA was undertaken during peak migratory season (December) where migratory bird activity is supposed to be at its highest. Moreover, the site visit was also fortunately undertaken after a very good rainfall season that ensured there was sufficient water availability and possibly food resources for aquatic bird species. There is a likely chance that the numbers will vary year upon year depending on water and food availability, and it is highly probable that years with wek monsoon will support less birds during winter migratory season. The site however during peak migratory season, followed by a good monsoon, does not support bird congregations approaching the threshold limits1 for Critical Habitat criterion 3, as the maximum number of individuals of any one species observed during the site assessment was ~50 (Bar-headed Geese). Further based on discussions with stakeholders there is no indication that the flocking will approach the congregation numbers defined by Bird LIfe International for IBAs or IFC PS 6 definition for critical habitats. Vulture species including the Endangered Egyptian Vulture, Critically Endangered Red-headed Vulture and Critically Endangered White-rumped Vulture has been identified from the nearby forest patches in Arnea Reserve Forest block. Vultures are wide-ranging species and therefore the critical habitat assessment should consider areas of aggregation, recruitment or specific habitat features important to the species [GN 59, 2019]. The applicability of critical habitat for vultures has been separately assessed for the Project site (covered in this ESIA) and the greater landscape incorporating the Arnea Reserve Forest block and adjacent areas (covered in the transmission line ESIA that is separately commissioned). The reason this has been separated is because there is a change in habitat type from the larger forest block with Menal River to the mosaic of scrub/agricultural land in the Project site and immediate surroundings. The habitat in and around the Project site is also modified due to anthropogenic movement and cultivation and therefore may support a lower diversity of species than the natural habitat found in the Arnea Reserve Forest. and immediate surroundings does not seem to meet the requirements to trigger IFC PS 6 critical habitat criterion 1 as shown below: Literature review as well a rapid ESIA does not provide any evidence of breeding colonies, nesting sites or roosting sites within the Project site or immediately adjacent areas; 1 The threshold limits for migratory and congregatory species is (i) areas known to sustain on a cyclical or regular basis, 1% of global population of a species and/or (ii) areas that support 10% of the global population of species during environmental stress. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 101 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report As indicated in Section 4.3.5, there is significant availability of food due to the number of livestock carcasses found across the study area but present survey did not record any vulture activity in the study area; and Th sightings of the species may be considered. Due to the absence of known vulture breeding, foraging, nesting and roosting sites in the Project site, the Project site has not been considered as critical habitat. The above analysis has been undertaken for the Solar Park and proposed access roads only. The Arnea Reserve Forest block however, is located only 400m and the forest block is known for occasional sightings of the species. The Project will need to maintain strict vigilance (e.g. livestock carcass disposal or open waste disposal) to ensure that the vultures occasionally visiting the forest block are not travelling further south to the Project site in search of food. The Project site would also need to be vigilant because the forest block in Arnea may see a higher number of vultures if there is recovery of the population of the species in the surrounding areas. Based on secondary data, it appears that the larger landscape that includes the Arnea Reserve Forest block may meet the requirements of critical habitat defined in IFC PS 6 because of presence of three vulture species White-rumped Vulture, Red-headed Vulture and Egyptian Vulture. The number of individuals and applicability of critical habitat will be undertaken after a more detailed biodiversity study that is being undertaken for the External Transmission Line as part of a separate ESIA report. 4.4 Social Environment The purpose of this section is to provide a general socio-economic profile of the area and the issues relevant to the project area. This section provides an understanding of the administrative set up of the district, the demographic profile of the villages in the study area, the social groups present, the land use pattern in the area, the livelihood profile of the community, common property resources and their use, etc. It also highlights the social and physical infrastructure available to support education, health infrastructure, the water supply for irrigation and drinking purposes, sanitation facilities and connectivity. The social baseline for the project area is based on official data and other secondary information available in the public domain, consultations in the field with key informants and with the communities through focus group discussions. It also includes visual observations made during the site survey. Section 1.3 provides an understanding of the methodology followed for the social baseline data collection. 4.4.1 Socio Economic Setting The project is situated in Singoli tehsil of Neemuch district in Madhya Pradesh. The sections below provide a broad overview and socioeconomic profile of these administrative units. 4.4.1.1 State Profile: Madhya Pradesh Madhya Pradesh, as the name suggests, is located in the centre of the country and is the second largest state in India (in terms of geographical area). It shares a boundary with Rajasthan in north- west, Gujarat in south-west, Maharashtra in south, Chhattisgarh in south-east and Uttar Pradesh in north east. The state administers 3,08,252 sq. km. of area which is 9.37 percent of the total geographical area of the country and its accounts for 6percent population of India, according to the provisional data of Census 2011. The capital of the state is Bhopal. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 102 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.24 Madhya Pradesh and Neemuch District Source: Survey of India The state of Madhya Pradesh is divided into 51 districts, 367 Tehsils, 313 development Blocks and 52,557 populated villages. The state comprises of a population of 72,626,809 individuals, who pre-dominantly live in rural areas from 24.3 percent during the period 1991-2001 to 20.3 percent during 2001 to 2011. The sex ratio in the state is 931, which has increased from 920 in the past decade; however it is still lower than the sex ratio of India, being 940 females per 1000 males. The population density of India is 382 persons/sq. km. while that of Madhya Pradesh is 236 persons/sq. km. The state has the second largest geographical area, of any state in the country. Table 4.35 Madhya Pradesh Demographic Profile Attribute Number Area (sq. km) 3,08,252 (9.37% of India) Total population 7,26,26,809 (6% of India) Males 3,76,12,306 (6.03% of India) Females 3,50,14,503 (5.97% of India) Sex ratio 931 Percentage of rural Population 72.4 Percentage of urban population 25.6 Population density 236 Percentage of SC population 15.6 Percentage of ST population 21.1 Total literacy rate 69.3 Male Literacy rate 78.7 Female Literacy Rate 54.5 Rural Literacy 63.9 Source: Census of India, 2011 The literacy rate of Madhya Pradesh is nearly 70percent (of which the rural literacy stands at 63.94percent) which is lower than that of the country, at 74.04percent. The male literacy rate is relatively higher, at 78.73percent while the female literacy rate is 54.49percent, which is quite low when compared to the national female literacy rate of 65.46percent. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 103 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Madhya Pradesh ranks 1st amongst all States and Union Territories with regards to Scheduled Tribe (ST) population and 12th in terms of Scheduled Caste (SC) population. The proportion of ST population in the state is 21.1percent and SC population is 15.6percent 4.4.1.2 District Profile: Neemuch Neemuch district is located in north- towards the East and it is bound by the state of Rajasthan towards the North. The total area of the district is 3,875 km 2 and it is comprised of 804 inhabited villages. There are a total of 12 towns in the district which includes one municipal corporation i.e. Neemuch, 11 Nagar Panchayats i.e. Athaana, Diken, Jawad, Jiran, Kukreswar, Manasa, Nayagaon, Rampura, Ratangarh, Sarwaniya Maharaj and Singoli.1 Figure 4.25 helps in understanding the various sub-divisions of the district. Figure 4.25 Neemuch District Divisions Source: Neemuch District Census Handbook, 2011 The population density of Neemuch district is relatively lower than that of Madhya Pradesh, as most of the district is rural, with only Neemuch and Khod as urban areas. The Scheduled Caste people form 13.46 percent of the total population in Neemuch, which is marginally lower than the state and the Scheduled Tribe population in Neemuch (8.6 percent) is significantly lower as compared with the state (21.1 percent). The sex ratio of the district (954 females per 1000 males) is slightly higher than child sex ratio in 2011 has reduced to 927 girls per 1000 boys from 932 girls per 1000 boys as per 2001 census data. 1 https://neemuch.nic.in/en/about-district/ www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 104 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report The status of literacy in the district also reflects a slightly better scenario than that of the state, and the female literacy rate is also marginally better at 57.13 percent against the state figures 54.49 percent respectively. Rural population forms the majority in the district, with 79 percent of the population living in the villages. 4.4.1.3 Tehsil Profile: Singoli, Jiran, Manasa and Jawad The Project Area of Influence includes villages spanning four tehsils of Neemuch district i.e. Singoli, Jiran, Manasa and Jawad. These four tehsils comprise of nearly 70 percent of the population of Neemuch district. In terms of SC population, Jiran tehsil has the maximum share at 15.6 percent, while Singoli tehsil has the lowest at 11.3 percent; the other two tehsils have nearly equivalent proportions of SC population at around 12.5 percent. Singoli tehsil has the highest ST population at 18.8%, while Jiran tehsil has the lowest ST population at 6.3 percent. In terms of sex ratio, Jiran tehsil exhibits a relatively higher Sex Ratio at 977, while Jiran tehsil registers the lowest sex ratio at 958. All four tehsils have a higher Sex Ratio than Neemuch district figures. Table 4.36 Demographic Profile of Tehsils Attribute Neemuch Singoli Jiran Manasa Jawad District Tehsil Tehsil Tehsil Tehsil Population 8,26,067 1,05,288 72829 267541 1,40,890 % of District Population N/A 12.7 8.8 32.4 17.1 % SC population 13.46 11.3 15.6 12.5 12.7 % ST population 8.65 18.8 6.3 7.3 11.2 Sex Ratio 954 960 977 972 958 % Total literacy rate 70.8 64.5 70.8 66.2 71.2 % Female literacy rate 57.13 48.8 55.7 51.5 56.6 Source: Census of India, 2011 4.4.2 Study Area The Study Area for the current assessment comprises of the area identified for the project as well as villages which might be impacted directly or indirectly by the project. The use of term Project Villages and Area of Influence. It differs slightly from the manner Study Area is defined for the Environment and Ecology sections. The key terms used for sub-categorization of the Study Area are: Project footprint Project Footprint comprises of the area within the proposed boundary of Neemuch Solar Park, (this has not been finalised at the time of writing this report); Project Villages The three villages of Badi, Kawai, Bardawada from where the land for the Area of influence - Area of Influence comprises of the villages falling within the 5 km radius of the project, apart from Project Villages, that may be directly or indirectly affected. Table 4.37 Land Details for the Solar Park Land Category Unit 1 (ha.) Unit 2-(Ha.) Unit 3 Total land (Ha.) (Hectare) Bardawada Kawai Kawai Badi Badi Government Land 201.8 89.6 156. 1 163.2 351.7 962. 5 (both NRED allotted & identified) Private Land 5.1 4.2 0 1.7 10.4 21.4 Patta Land 50.7 0 22.4 3.6 5 81.7 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 105 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Land Category Unit 1 (ha.) Unit 2-(Ha.) Unit 3 Total land (Ha.) (Hectare) Sum 351.5 347 367 1065.7 Source: Land Data provided by RUMSL, 3rd June 2020 While the project footprint is present only in Singoli tehsil, the Area of Influence spreads across villages spanning four tehsils of Neemuch district i.e. Singoli, Jiran, Manasa and Jawad. In the Study Area, the concentration of villages is higher in Singoli tehsil. It may be noted that the villages Singhpur, Haripur Warla and Nadi that are depicted in the map but could not be located in the Census data of 2011. The Figure 4.26 illustrates the Study Area, which shows the villages present within 5 km radius of the project site. The villages lying in the Project Footprint Area and AoI are also listed below in Table 4.38. Table 4.38 Project Area and Surrounding Area Villages S. No. Project villages S. No. Area of Influence villages 1. Badi 1. Aned 2. Bardawada 2. Anoppura 3. Kawai 3. Arnya 4. Bamni 5. Banediya 6. Chaksodijhar 7. Devipura Abad 8. Dhangaon 9. Dhardi 10. Funsariya 11. Gulsari 12. Haripura 13. Jetpura 14. Jhantala 15. Kadwasa 16. Keri 17. Kewalpura 18. Ladpura 19. Mahupura Molki 20. Mendki 21. Mokhampura 22. Motiyarda 23. Nayagaon 24. Palasiya 25. Rajpura 26. Rastpura 27. Saloda 28. Sawalpura 29. Sehnatalai 30. Thadod 31. Tokra 32. Turkiya Source: Google Earth imagery corroborated with Toposheet www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 106 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL BASELINE Final ESIA Report Figure 4.26 Map depicting villages in the Study Area www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 107 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report 4.4.3 Demographic Profile of Study Area villages, as depicted in Table 4.39. The Project Villages comprise of 440 households with a population of 2,047 individuals. The average size of the households is 5 in the Study Area. Kawai village has the highest sex ratio amongst the Project villages. The AoI has a sex ratio of 950 females per 1000 males, which is nearly equivalent to the district figure and better than the state figure of 931. Table 4.39 Demographic Profile of Study Area No of Populatio Avg HH Sex Village % SC % ST % Lit % F Lit HHs n size Ratio Project Villages Badi 257 1121 4 884 10.8% 22.2% 46.2% 31.9% Bardawada 77 399 5 928 3.5% 5.5% 70.7% 49.4% Kawai 106 527 5 974 2.5% 19.9% 58.0% 42.9% Total 440 2047 5 915 7.2% 18.4% 54.2% 38.5% Area of Influence AoI Total 6023 28378 5 950 15.0% 5.7% 68.2% 51.1% Study Area Total 6463 30425 5 948 14.5% 6.5% 67.3% 50.2% Source: Census of India, 2011 The total literacy in the Study Area is 67.3 percent whereas the female literacy rate by comparison is quite low. Within the Study Area, the female literacy is higher in the AoI than the Project Villages. The proportion of SC population is lower in the Project Villages as compared to the AoI figures, while the proportion of ST population is higher in the Project Villages as compared to the AoI figure, indicating presence of higher numbers of ST households in the Project villages. 4.4.4 Social Stratification The entire population in the Study Area falls in the rural category. The villages comprise majorly of Dhakad, Gujjar and Rajput communities and households belonging to Bhil (ST), Balai and OBC groups. Figure 4.27 Proportion of SC/ST Population in the villages of Study Area vis-à- vis Tehsil/ District 25 20 15 10 5 0 Project Study Singoli Neemuch Madhya AoI Villages Area Tehsil District Pradesh % SC Population 7.2 15 14.5 11.3 13.5 15.5 % ST Population 18.4 5.7 6.5 18.8 8.6 21.1 Source: Census of India, 2011 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 108 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report 4.4.4.1 Scheduled Caste Population The major sub castes of SC population inhabiting the area are Meghwal, Chamar, Balai, Suthar, Nai, etc. The livelihood pattern of SC population does not significantly differ from the General community; however, they reportedly possess smaller landholdings and their dependence is higher on agriculture labour and wage labour due to lack of access to or limited landholdings. The SC population spread across the Project villages comprise 5-7 households in Kawai and Bardawada villages and about 30 households in Badi villages, based on community consultations held in November 2019. 4.4.4.2 Scheduled Tribe Population While Madhya Pradesh has a high proportion of ST population, the presence of ST population is relatively low in the district, and the Study Area; however the Project villages, from where the land for the project has been identified, comprises 18.4 percent ST population, based on the 2011 census data. The ST groups largely consists of people from the Bhil tribe, comprising 5-6 households in Bardawada village, approximately 20 households in Kawai and approximately 45 households in Badi village, as reported during community consultations held in November 2019. There are two prominent groups of Bhil community present in the area - one resident group (living within villages) and one group of Bhil that migrated to the area and live in a hamlet known as Mama Basti. Mama Basti is a settlement on the boundary of three villages (Dhangoan, Badi and Funsariya) near the Dhandgoan ka Talab. The community has migrated from Jhabua District, around 35 to 40 years back. There are in total 30 houses with 30 to 35 families living in Mama Basti. The Bhils have relatively smaller land holdings, approximately 2-4 Bigha each ( approximately 0.4- 0.5 hectare) and there are some landless Bhil households as well; however, there might be encroachments done by some families on government land- this will be confirmed during the RAP survey. The migrant community group has reportedly received houses under the Indira Awas Yojana. Box 4.1 Bhil Tribe The main occupation of the Bhil tribe is agriculture; however, the land holdings amongst the community were reported to be slightly lower (2-3 Bigha average) than that of the general community. The tribe has access to the mainstream education, health and justice system, participates in religious festivals such as Diwali, Holi and Raksha Bandhan and is part of the Gram Panchayat of the village. Nevertheless, the tribe has their own traditional leadership in the form of group elders, who play an important role in decision making and conflict resolution 4.4.5 Literacy and Education The total literacy rate and female literacy rate in the Project villages is the lowest as compared to the AoI, Study Area, Tehsil and district figures. The female literacy rates in the AoI are relatively higher and are comparable to the district and state figures, while in the Project villages, the female literacy rates are quite low. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 109 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report Figure 4.28 Comparative Overview of the Literacy Rate across Study Area, District and State 90.0% 80.0% 70.0% 60.0% 50.0% 40.0% 30.0% 20.0% 10.0% 0.0% Project Singoli Neemuch Madhya AoI Study Area Villages Tehsil District Pradesh % Total Literacy 54.2% 68.2% 67.3% 64.5% 70.8% 69.3% % Female Literacy 38.5% 51.1% 50.2% 48.8% 57.1% 54.5% % Male Literacy 69.2% 84.6% 83.6% 67.8% 81.1% 78.7% Source: Census of India, 2011 In recent years a key change is that reportedly all girls in the Project villages attend schools; however, dropouts take place after primary or middle school level, if the girls have to travel to other villages for continuing education, due to safety concerns and lack of commutation facilities. Additionally, some communities are averse to sending adolescent girls to co-educational schools and prefer all-girls schools. The boys usually complete school education and those belonging to financially secure families go on to complete graduate courses in colleges or join technical courses, while others are pulled into farm based work to support their respective families economically. The proportion of boys , compared to girls, completing education beyond 10th and 12th standards is lesser as the people reportedly do not get gainful employment after attaining higher education. The cost of higher studies, with additional costs of commuting (in several cases), is perceived as a cost with inadequate returns, rather than an investment. Thus, the youth eventually join their family in agriculture and related work. There are reportedly no ITIs in and around Singoli tehsil and those opting for technical courses have to move to other towns/ cities with training options like Neemuch and Mandsaur. 4.4.6 Land ownership and use This section presents an overview of the ownership and use of land in the project area, based on the Census 2011; however it does not include recent aerial imagery based updates, which are underway but not completed at the time of writing this. The area has an agrarian economy and hence the dependence on land, as a resource, is high. The table for land utilization reiterates the heavy dependence of people on agriculture, making it one of the primary sources of their livelihood. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 110 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report 4.4.6.1 Land Category Breakup Table 4.40 Land Use Break Up in the Study Area Perma Land FallowL Area Barre nent Under and under n& Pastur Cultur Curr Total Net Miscella other Fores Non- Un- es & able ent Villages Area Area neous than t Area Agric cultiv Other Waste Fallo (in ha) Sown1 Tree Current ultural able Grazin Crops Land3 ws4 Fallows Uses Land g etc. Area Area5 Land2 Project Villages Badi 1300.4 294.6 111.0 34.9 651.6 74.7 92.3 41.3 0.0 0.0 Bardaw 565.1 181.1 0.0 14.9 295.8 8.7 0.0 19.7 41.6 3.3 ada Kawai 826.5 145.9 100.2 38.0 415.0 41.2 31.2 52.2 0.0 2.8 Total 2692.0 621.5 211.3 87.9 1362.4 124.6 123.5 113.2 41.6 6.1 AoI 13959.0 6953.8 1635.9 1144.1 2196.4 516.7 501.1 771.4 105.0 81.5 Total Study 16,650. 3,558. Area 95 7,575.34 1847.2 1232.0 81 641.36 624.6 884.6 146.6 87.6 Total Source: Census of India, 2011 *The definitions for various categories of land are used from http://mospi.nic.in/45-nine-fold-classification-land-use. The Table 4.40 denotes that approximately 50.6 percent of the land area in the Project Villages is categorised barren and uncultivable land, 23.1 percent is net sown area, out of which 63 percent is unirrigated land and 37 percent is irrigated land. The Project villages have 7.8 percent of the total land area as forest land, 3.3 percent area under non-agricultural use and 4.2 percent as culturable waste land. Additionally, 4.6 percent is land comprising of miscellaneous tree crops, and 4.6% are permanent pastures and other grazing land. Current fallows area and fallow lands other than current fallows comprise of only 1.52 percent and 0.2 percent respectively. This data is a decade old and more recent estimates are currently not available. It is understood from consultations with local communities that with the availability of reliable electricity in recent years, more people have invested in installing bore wells and have brought more land into agricultural use. This includes privately owned land, patta land, and even government land (by squatting or encroachment). This land that is now 1 Net sown area is the total area sown with crops and orchards, counting area sown more than once in the same year, only once. 2 All grazing lands whether they are permanent pastures and meadows 3 All lands available for cultivation whether not taken up for cultivation or taken up for cultivation once but not cultivated during the current year and the last five years or more in succession for one reason or the other. Such lands may be either wholly or partly covered with shrubs and jungles, which are not put to any use. Land once cultivated but not cultivated for five years in succession would also be included in this category 4 Current fallow area is the Cropped area which are kept fallow during the current year but was cultivated in the previous year. For example with any seeding area is not cropped in the same year, it may be treated as current fallow. 5 Fallow land other than current fallow land are lands, which are taken up for cultivation but are temporarily out of cultivation for a period of not less than one year and not more than five years , i.e., equal or greater than one year but less than or equal to five years. The reasons for keeping such lands fallow may be one or more of the following: i) Poverty of the cultivator ii) Inadequate supply of water iii) Malarial climate iv) Silting of canals and rivers and v) Un - remunerative nature of farming www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 111 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report being used for agriculture, may be drawn from the land use previously categorised barren, uncultivable and culturable waste as noted below. Figure 4.29 Proportion of Land Use in Study Area Project VillagesNet Sown Area (in Hectares) 1% 0% Forest Area (in Hectares) 4% 5% Area under Non- 5% 23% Agricultural Uses Barren & Un- cultivable Land 8% Land under Miscellaneous Tree 3% Crops (in Hectares) 51% AoI Net Sown Area (in Hectares) Forest Area (in Hectares) 1% 0% Area under Non- 4% Agricultural Uses 4% 5% Barren & Un- cultivable Land Land under Miscellaneous Tree 16% Crops (in Hectares) 50% Permanent Pastures & Other Grazing Land 8% Culturable Waste Land Area 12% Source: Census of India, 2011 In the AoI, approximately 50 percent of the land is categorised as net sown area, out of which 48 percent is unirrigated land that is rain fed and 52 percent is irrigated land, with some form of irrigation arrangements. Approximately 15.8 percent of total land area is barren and uncultivable land, 11.8 percent is forest area, 8.2 percent land is under non-agricultural uses, 5.5 percent is culturable wasteland, 3.6 percent is land comprising of miscellaneous tree crops, and 3.7 percent comprise of permanent pastures and other grazing land. Fallow lands other than current fallows comprise of 0.8 percent and 0.6 percent respectively in the AoI. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 112 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report 4.4.6.2 Land Ownership and Occupation (Squatting/Encroachment) Community consultations suggest that grazing, agriculture and firewood collection are undertaken as year round activities, growing more intense in certain months Firewood collection is done after monsoon in the months of July to January. Agriculture is usually done in the Kharif season (to utilise the monsoon rain) and open grazing is year round. According to discussions with the local community, most households own agricultural land; in the form of private land parcels or government allotted patta land (these land types are defined in Section 2.5.1). As per the 2011 Census data, all households have at least 0.1-0.2 ha (1-2 bigha) of agricultural land and majority of households in the project villages fall in the category of Marginal Farmers. The household belonging to Dhakad community largely fall in the category of Small to Semi- Medium farmers as per Census definition 1, having landholdings ranging from 10-25 Bigha (1 Ha 2.5 Ha). Those households who were landless, especially belonging to SC and ST categories, were, over the past decades, allotted patta land parcels (typically of 1 ha each) by the government. The last patta land allotment was done in 2001. Most of the patta land parcels have been with the patta landholders for more than 20 years. There are however, a few households which remain landless. This is mainly due to the reasons stated below: The households have split since the last allocation without dividing the existing land holdings and thus there are certain new households who do not own land; There were landless households who were not present in the village at the time of the patta allocation and thus did not receive any pattas from the government; Some households that were allotted Patta land have sold them, without the official paperwork, as the sale of Patta land is not allowed as per legal provisions. So, the land remains in the name of original patta holders on papers, but they in reality have no or much smaller portion of land. The patta land in the project footprint is used for agricultural purposes and grazing (in non- agricultural season). Several patta holders are reported to be SC and ST category. According to the discussion with the community, at the time of patta allotment, the land was barren, with poor top soil and was thus was not usable for cultivation. However, the patta holders undertook significant land improvements, including clearing the land of stones and bringing, or purchasing and adding top soil from outside. Some have even installed bore wells for irrigation while others made small improvements like installing stone slab fencing to keep animals out. These stone slabs are quarried and available locally and purchased for boundary demarcation. Water is generally available at 400-500 ft depth and Borewell construction takes up to INR 60,000 even if there is no water availability. In case water is found in the borewell, the cost of construction goes up to INR 1.5 lacs, which includes the cost of installing the motorised pump. There are instances 1 Agriculture Census 2010-11: Schedules and Instructions for Land Record S. No Size Class (ha.) Farmer Category 1 Below 0.50 ha. 01 Marginal Farmers 2 0.50 ha. 0.99 ha. 02 3 1.00 ha. 1.99 ha. 03 Small Farmers 4 2.00 ha. 2.99 ha. 04 Semi Medium 5 3.00 ha. 3.99 ha. 05 6 4.00 ha. 4.99 ha. 06 Medium 7 5.00 ha. 7.49 ha. 07 8 7.50 ha. 9.99 ha. 08 9 10.00 ha. 19.99 ha. 09 Large Farmers www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 113 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report of borewells running dry during some summer months however, the water availability is restored to varying extents in the area after the monsoon. The private land in the project footprint is used for agricultural and grazing purposes (in non- agricultural season, as with patta land. The trend of using bore wells and irrigation channels for improving agricultural productivity of the land has also been noted on private land. Use of Government Land: Grazing The Government land in the Project Footprint is used for livestock grazing, fire wood collection and stone quarrying (very few licenced quarries remain currently, as per November 2019 consultations). Livestock ownership in the Project villages is higher among the Gurjar community (cows and buffaloes), while Bhil community is reported to possess a higher number of goats. The livestock census data from 2019 is presented in the table below. Table 4.41 Livestock Census data for project villages Villages in the Unit Livestock Buffalo Sheep Goat Total Bardawada 262 237 0 197 696 Kawai 501 150 0 232 883 Badi 1433 343 0 825 2601 Project villages Total 2196 730 0 1254 4180 Source: Livestock Census 2019 In Badi village, the number of livestock owned by the residents is about 2600, while the livestock holdings in Bardawada and Kawai villages are relatively lower. During consultations, the residents of Badi explained that the Gurjar community (present in higher numbers in this village) are proficient in livestock rearing and invest their surpluses in buying more milch cows. Livestock grazing takes place as open grazing on government land and the men of the household are responsible for livestock grazing while the women are responsible for domestic caretaking responsibilities of the livestock, comprising stall feeding, cleaning of livestock and their sheds, making dung cakes, milking, etc. The men transport the milk for sale. The availability of grazing land near the project villages is reported to be limited, as reported during the community consultations, since the number of livestock is more and the available area for grazing has reduced in recent years due to squatting/ encroachment and agricultural activities, also on government land. Government land occupied for agriculture has tended to be in areas that were also good grazing areas and are now unavailable. It was reported that there land encroachments have been done by a social group that is known to be good at agriculture (Dhakar community). As a result, a few private fodder lots have been constructed, also on encroached government land by village residents, who ensure that the area within the fodder lot (bounded by stone slab boundary walls) has good year-round availability of better quality fodder. For this, they charge INR 1000 per cow/buffalo per year, for open grazing within the fodder lot. These needs are driven by the reduction in grazing area and the need for improved fodder for milch livestock and buffalos as families also draw better incomes from dairying activities. Given these circumstances, people were concerned about further reductions to grazing lands, especially for the livestock owning communities who have further invested in procuring more livestock to benefit from dairying work. Use of Government Land: Agriculture Areas within the 968.8 ha Government land within the project footprint is currently used for agriculture (squatted upon or encroached land by villagers). There are significant encroachments/squatting for www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 114 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report agriculture, on the government land; however the details on the extent were neither available on record at the Tehsil office, nor with the Patwari. An assessment will be made during RAP surveys planned later in the month September/October 2020 and this information will be included in the RAP document. The patta holders and private land holders from the adjoining plots have extended their boundaries to include larger land parcels for cultivation. In addition to this, the local community has also done boundary marking on government land, to demarcate grazing areas for an individual household or a these encroachments or squatters are reported to be at least 20-30 years old, or as reported going back two generations. The local community stated that they deposit fines for encroachment/squatting and cultivation on Government lands; however, the fines are paid only for a small fraction of the actual encroachment, and are not paid every year. The payment of fines for a fraction of encroached land helps the households get their names in the Government records while avoiding the payment of actual sum of fines, which would be much higher in most cases. Usually the penalty amount and the method for calculating the fine varies from one village to another. In some places it is reported to be calculated based on the reference ency of these checks across farms in the villages as understood through consultations. People see benefit in remaining on this list (of squatters/encroachers), even if regularisation of their claims on government land. This understanding was not confirmed by relevant government officials. However, this seems to act as an extra-legal, proxy, claims establishment system, where families and generations continue to cultivate, year after year, and appears to be Other uses on Government Land Quarrying activities usually occur on Government land present near the Project Footprint area, during the months of October- November. It has been reported by the village residents that the mining activity is conducted on a reduced scale than the earlier activity level with very few licenses still active. Quarrying (for construction material), requires a local permit from the panchayat, and is usually conducted immediately after the monsoon season, due to collection of water in the pits (July to September). The villagers use these stones to make the boundaries around their owned as well as squatted/encroached land. These stones are in high demand and wall making is a source of livelihood for some people. 4.4.7 Occupational Profile The Study Area is categorized by nearly 53.4 percent working population, where majority of the 1 , i.e. being employed for more than 6 months in a year. The Project Villages have nearly 56percent Main workers of the total working population. The employment of both men and women in the project villages is in agriculture, where men mostly work as cultivators2 while women take up paid or unpaid work as agricultural labourers 3. The details of the types of paid employment are presented in 4.4.7.1 and 4.4.7.2. The table below depicts that women are equal contributors to the Main Working Population as men in Kawai and Bardawada village, whereas the women participation as Marginal Workers4 is higher in these two villages. 1 Main Workers are those workers who had worked for the major part of the reference period (i.e. 6 months or more); 2 A person is classified as cultivator if he or she is engaged in cultivation of land owned or held from Government or held from private persons or institutions for payment in money, kind or share. Cultivation includes effective supervision or direction in cultivation 3 A kind or share is regarded as agriculture labourer. He or she has no risk in ct on which she or he works 4 Marginal Workers are those workers who have not worked for major portion of reference period (i.e. less than 6 months) www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 115 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report The Table 4.42 and Figure 4.30 below presents the worker participation in the Project Villages, during the previous decade, obtained from the 2001 Census of India. It is observed that the overall worker work participation has decreased from 2001 Census to 2011 Census, thereby bringing about an increase in the proportion of Non-Working population, especially in the female category. This change may be a result of number of factors, some of them being increasing landlessness or sub- optimal land holdings, women dropping out of the workforce to take on household work (for economic and cultural reasons), increasing unemployment over the decade as more youths spend longer time studying in adulthood, and waiting to join jobs rather than join the agricultural workforce, etc. Figure 4.30 Decadal comparison of Working trends in the Project villages 80.0% 70.0% 60.0% 50.0% 40.0% 30.0% 20.0% 10.0% 0.0% WPR Main (% of WPR) Marg (% of WPR) Non Work (% of Total Population) 2001 2011 Source: Census 2001 and 2011 data A similar trend is also observed for the proportion of marginal work decreased over the decade whereas the proportion of Main Workers has remained nearly the same. It is also observed that there is a decrease of proportion of Female workers, both Main and Marginal from 2001 to 2011, indicating that either the engagement levels of females has decreased over the decade due to socio-cultural reasons or the growth in employment opportunities for females is not at par with the female population growth over the decade. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 116 ENVIRONMENTAL AND SOCIAL BASELINE CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report Table 4.42 Working Population in the Study Area as per Census 2011 Main 1 Main M (% of Main F (% of Marg2 (% of Marg M (% Marg F (% of Non Work (% of Villages WPR (% of WPR) WPR) WPR) WPR) of WPR) WPR) Total Population) Project Villages Badi 56.3% 54.5% 57.0% 43.0% 1.8% 60% 40% 43.7% Bardawada 62.2% 61.7% 49.6% 50.4% 0.5% 0% 100% 37.8% Kawai 56.9% 55.2% 50.9% 49.1% 1.7% 44% 56% 43.1% Project Villages Total 57.6% 56.1% 53.8% 46.2% 1.5% 52% 48% 42.4% AoI Total 53.1% 45.7% 59.6% 40.4% 7.4% 38% 62% 46.9% Study Area Total 53.4% 46.4% 59.2% 40.8% 7.0% 38% 62% 46.6% Source: Census of India, 2011 Table 4.43 Proportion and Break-up of Working Population in the Study Area (as per Census 2001) Main Main M (% of Main F (% of Marg (% of Marg M (% Marg F (% of Non Work (% of Villages WPR (% of WPR) WPR) WPR) WPR) of WPR) WPR) Total Population) Project Villages Badi 69.6% 48.4% 67.6% 32.4% 21.1% 28% 72% 30.4% Bardawada 57.2% 56.6% 47.8% 52.2% 0.6% 100% 0% 42.8% Kawai 74.7% 52.3% 51.7% 48.3% 22.4% 46% 54% 25.3% Project villages Total 68.5% 51.3% 58.3% 41.7% 17.2% 35% 65% 31.5% Source: Census of India, 2001 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 117 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS STAKEHOLDER IDENTIFICATION, INFORMATION Final ESIA Report DISCLOSURE, CONSULTATION AND PARTICIPATION Out of the Main Working Population, majority of the population can be categorized as Cultivators 1 or Agricultural Labourers2, endorsing the fact that the region has an agrarian economy. As per Census data, nearly 5.7% population in Project Villages and 18.3% population in the AoI report being engaged in other work3, like construction labourers, working in the stone quarries in Rajasthan, in shops near Singoli, etc. The proportion of Household workers4 is negligible across the Study, as depicted in Figure 4.31 below. It can be observed as per Census 2011 data, that men account for majority of the main workers in the Study Area, at 59.2 percent while women account for majority of the marginal workers at 62% of the total working population. Figure 4.31 Distribution of Main Working Population in the Study Area 120.0 100.0 80.0 60.0 40.0 20.0 0.0 Project Villages AoI Study Area % HH 0.0 0.7 0.6 % OT 5.7 18.3 17.4 % AL 17.0 19.1 18.9 % CL 77.3 61.9 63.0 Source: Census of India, 2011 The following categories comprise the main occupational activities within the Study Area: Farm Based Activities (cultivators, agricultural labourers and livestock rearing); Non-farm based activities (contractual labour for construction, stone quarries, etc.) 4.4.7.1 Farm Based Livelihoods As can be seen from Figure 4.31 approximately 94.3% of the main working population in the Project Villages and 81% of the main working population in the AoI is dependent upon farm-based activities for their livelihood. The farm based activities comprise of agriculture, agricultural labour and livestock rearing. The area has a lower water table with varying water availability of 400-800 ft at the farm lands and most of them are reported to have seasonal water availability, which is influenced by rainfall. There are a few tubewells located in the proximity of surface water bodies, which are reported to provide water to the community throughout the year. Wells, tube-wells as well the supply of electricity for a period of 6-10 hours per day for irrigation, form the major sources of irrigation across villages 3All workers i.e. those who have engaged in some economic activity during the last one year, but are not cultivators or agriculture labourers or in househol 4 Household industry is defined as an industry being run by one or more member of a household at home or within village in rural areas and only within the precincts of the house where the household lives in urban areas. The larger proportion of workers in the household industry consists of members of household. The industry is not run on the scale of a registered factory which would qualify or has to be registered under the Indian Factories Act. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 118 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS STAKEHOLDER IDENTIFICATION, INFORMATION Final ESIA Report DISCLOSURE, CONSULTATION AND PARTICIPATION June to September, which is indicative of low replenishment of water in surface and groundwater High Section 4.2.10.1. The current dependence on land and livestock rearing in the area is higher in absence of less rainfall leading to sub-optimal agricultural activity in the area. Dependence on Agriculture in the Project Villages Villagers cultivate on their own (private) land parcels, Patta land parcels and there is understood to be Government land being encroached/squatted upon by the villagers which, they reported, has been made productive by putting in some investment and effort and there is potential for converting more such land, for agricultural usage, though this is not permitted. The extent of encroachment and squatting on Government land could not be determined because of the reluctance of the community in providing these details. The extent of encroachment and squatting would emerge during the RAP surveys and be detailed in the RAP report. Before starting cultivation on any land, the land improvement work like removing stones and other levelling work has to be done, for which the average cost comes out to be about INR 23,000 to 25,500 per bigha (0.11 Hectare). The villagers say that they have known about the upcoming Solar Park project and that is why some of them have not made further investment in encroached/squatted upon land parcels for cultivation. This may be contradictory to reports of recent investments in all types of agricultural land, to increase productivity through bore well irrigation. The land holdings in the villagers are relatively higher amongst Dhakad community, who fall in the category of Small to Semi Medium farmers (land holdings ranging from 1 ha to 2.5 ha), which is reported to be relatively better off and with traditional skills in bringing barren land into cultivation. It is also anecdotally reported that this community may have a greater share of encroached/squatted upon land, given their skills with agriculture. Most of the encroachment in the villages is reportedly done in the last 20 years. Approximately 10-15 percent households in the Project Villages are reported to be landless or with sub-optimal/marginal land holdings, falling in the category of Marginal farmers. An increase in government land occupied for agriculture is also a reduction in grazing area, thus creating further stress for livestock owning households, largely from a different community from the agriculturalists. Crops and cropping pattern in the Study Area The primary crops in the region comprise of Maize, Pulses (Urad, Moong), Gram, Groundnut, Cotton and Soybean amongst Kharif crops and Wheat, Mustard, Coriander, Isabgol, Fenugreek, Garlic and Opium (licensed) being the Rabi crops. In addition, some households also cultivate vegetables for self-consumption. The dependence on monsoons for agriculture is high, especially during the summer months of May and June. Table 4.44 Productivity and related costing of major crops in AoI Crop Agricultural Costing per Production Price per quintal Season Hectare (INR) Soybean June-October 40,000-50,000 20 quintals 3000 approx. Wheat November-April 50,000 60,000 50-60 quintals 1600-1700 Maize June-October 65000 50 quintals 1500-1600 Pulses June-October 50,000 20-25 quintals 8,000- 9,000 Gram October- April 25,000 5 Quintals 4500 Isabgol November-April 40,000 15 Quintals 8000- 9000 Mustard October- April 30,000 20-25 Quintals 3500-4000 Groundnut March July 25000 20 Quintals 4500 Cotton March July 20,000 6-8 Quintals 4500 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 119 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS STAKEHOLDER IDENTIFICATION, INFORMATION Final ESIA Report DISCLOSURE, CONSULTATION AND PARTICIPATION Crop Agricultural Costing per Production Price per quintal Season Hectare (INR) Opium October- April 5 lacs 10 Quintals Poppy 450000/ Q for poppy seeds; seeds 55 kg opium 150000/ Q for opium Source: Community Consultations undertaken by ERM India in November 2019 The community consultations revealed that Wheat cultivation in the area has been good in the last year due to good rainfall. The vegetables like tomatoes, chillies, etc., have higher cost of labour and maintenance while the productivity dwindles, as there is higher probability of infection. Jow is a less water intensive crop and is grown in areas receiving scanty rainfall. Some of the villagers have diversified their farming and have started cultivating Oranges, Guava, Pomegranate, etc. Opium crop needs Government license for cultivation and fetches proceeds from sale of Poppy seeds, the flower and the case; thus leading to more profits. The people retain a part of the crop produce for self-consumption while the excess is sold in Singoli Mandi to local traders. The farmers sell their agricultural produce to individual traders and not in the Government Mandis due to flexibility in terms of time of sale, lack of documentation required, preference for getting cash payments, against the less preferred practice of receiving cheques for sale in Mandis. People from Kawai village reportedly sell through Mandi as they are affluent. The government Minimum Support Price (MSP) for Maize is INR 1700 to 1800 per Quintal while the private selling price is reported to be aro MSP, if the crops are cultivated on Encroached land parcels, which is verified by visits of Patwaris to individual land parcels and records of encroachment maintained by them. Box 4.2 Process of determination of Minimum Support Price as per APMC consultations The process for deciding the MSP in the Government Mandis is described below. Farmers have to make the registration on government list for selling their crops on the government portal; Declaration of crops have to be done by the farmers at the beginning of cultivation period; As per the crop and the total land on the name of the farmers, the government estimate the total production of the crop; Rates are determined on the basis of quality of crops, the crops with higher water content are sold at relatively lower prices; The rates of crops in the area are published in newspapers as well as an online portal Agmanet; The government only will buy the estimated crop on MSP, not above the limit decided by the government. agriculture is not solely sufficient for sustenance and is supplemented by other activities like livestock rearing, migration of youth to nearby cities during agriculturally leans periods, etc. There has also been damage to crops due to excess rainfall in the last year in certain areas and compensation has been paid by the Government for the damage, approx. INR 20,000-25,000 per hectare. Compensation for damage to the crops due to excess rainfall was decided based on Section 6, sub- section 4 of RBC (Revenue Board Circular). Consultations in the Project villages highlight that the role of women in agriculture comprises activities such as sowing, weeding, cutting and watering and during harvesting season. In terms of remuneration, women are paid INR 100 - 200 /day while men are paid INR 200 - 300 /day. However, women of the household undertake agricultural work for the agricultural fields owned by their family, which is not accounted for as economic work. Their primary responsibilities are household work, caretaking of children and the elderly, tending to www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 120 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS STAKEHOLDER IDENTIFICATION, INFORMATION Final ESIA Report DISCLOSURE, CONSULTATION AND PARTICIPATION livestock, cleaning their sheds, collection of fodder, and fuelwood in addition to agriculture work in the fields. Livestock rearing In addition to agriculture, livestock holdings play an important part in the livelihoods of the community, in terms of supplementing household income from agriculture and other sources. The livestock also plays a key role in meeting the nutritional intake of the household as well as the animal by-products also serve as a steady source of fuel for the domestic needs like cooking, in addition to the LPG. The main livestock holdings in the area comprise of Cows, Buffaloes, Goats and Sheep. While there are no reported household maintaining livestock holdings for solely commercial purposes, most of the household are reported to be engaged in the sale of surplus milk to the neighbouring villages and Singoli. Singoli has a private and a Government dairy and milk from the project villages is also sold door to door in colonies (in Singoli town) by the residents of the Project Villages. The Bhil community largely has Goats and Sheep while the Gurjars and Dhakads have cows and buffaloes, where Gurjar households has the maximum livestock ownership, going as high as 15-20 buffaloes per household. There are reported to be grazing areas (fodder lots) set up on the encroached land parcels where livestock are allowed to graze against a payment of INR 1000 per livestock head per year. In terms of gender roles, women take care of stall feeding of livestock, cleaning of livestock and their sheds, preparation of dung cakes, milking, etc.; but are not responsible for grazing of livestock outside the household premises. Male members of the household are responsible for livestock grazing near the villages, sale and purchase of livestock, livestock feed and by products. 4.4.7.2 Non- Farm Based Livelihoods As can be seen in Figure 4.31, the non-farm based livelihoods act as a supplementary source of income to the families in the area. The non-farm based livelihoods in the area primarily comprise of male casual labour involved in construction of houses in nearby villages and Singoli, working as labourers in stone quarries in nearby villages of Rajasthan, working in shops and enterprises in and around Singoli, etc. The stakeholder consultations also suggested migration of males, either alone or with family, to the nearby cities of Bhilwada, Chittorgarh, etc. The migration is both seasonal as well as long term depending on the area of employment and skill set of the individual. The migrated workforce is largely engaged as daily wage labourers in the construction projects in nearby towns and cities or are engaged in manufacturing sector. In cases where only males migrate, females of the family stay in the villages and take part in cultivation of agricultural fields of the family. Seasonal and long term migrant workers may have returned to their villages as part of the overall flows induced by lock-downs related to the COVID 19 pandemic. Given that this is a developing situation, these aspects will need to be assessed during the RAP survey, and also later, periodically. 4.4.8 Physical Infrastructure 4.4.8.1 Water Supply and Sanitation The household level supply of water is also done through the bore wells (400-500ft deep), by an infrastructure set up by Panchayat that has piped connections to some common water access points in the village as well as to some households as well. None of these sources was reported in the Project Villages, as a community source of drinking water. Only private sources for irrigation were reported in the project villages. Drinking water is reported to be easily available in the Project villages, with some water scarcity problems reported during summer seasons. Women have the responsibility to carry water from the community water points to their www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 121 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS STAKEHOLDER IDENTIFICATION, INFORMATION Final ESIA Report DISCLOSURE, CONSULTATION AND PARTICIPATION respective households while some families depend on other families for water through bore wells, against payment for the same. As discussed in 4.2.10.1, the Project villages fall in the region of extremely high baseline water stress and high risk of baseline water depletion. The quality of drinking water available at lower depth is reported to be good while higher salt concentration is found in water from deeper levels. There are issues of drying of borewells reported in the summer months. The DPR has identified the ground water as project water source, which will further cause stress on ground water resources of the area (Refer Section 4.2.10 and 6.2.3 for details). Open Drains are present in the Project villages, as observed during community consultations in November 2019. In Kawai village the provision of drains was missing in certain parts with water logging and flowing on the road. In terms of toilets, construction has been completed for a lot of toilets at household level in the Project villages; however, a good proportion of the population, especially the older folks still practice open defecation. 4.4.9 Social Infrastructure 4.4.9.1 Education Infrastructure According to Census of India, Primary Schools provide education from class 1st to 5th, Middle Schools cater to children studying from classes 6th to 8th, Secondary School provides education to students of classes 9th and 10th and similarly, senior secondary school teaches children studying in classes 11th and 12th. One interesting fact here is that, a composite school with classes 1st to 12th, will be treated as four separate units and will be counted separately as a Primary, Middle, Secondary and Senior Secondary school. The AoI is characterised by the presence of co-educational primary schools across all the villages lying in the AoI, with the exception of Anooppura and Mokhampura village. However, as pointed out during community consultations, all-girls schools are preferred by the community for adolescent girls. There is a dearth of Middle, Secondary and Senior Secondary schools in the Study Area, with 2 Middle schools, no Secondary or Senior Secondary Schools in the Project Villages (comprising of three villages) and 14 Middle Schools, 5 Secondary Schools and 3 Senior Secondary Schools in the AoI (comprising 32 villages). Table 4.45 Availability of Schools in the Study Area Government Government Government Senior Government Middle Villages Primary school Secondary School Secondary school school (M) (P) (S) (SS) Project Villages Badi 1 1 0 0 Bardawada 1 0 Kawai 1 1 0 0 PFA Total 3 2 0 0 AoI Total 34 14 5 3 Study Area Total 37 16 5 3 Source: Census of India, 2011 The lack of village level facilities at the middle and higher levels of education forms one of the primary reasons of children dropping out of schools. 4.4.9.2 Health Facilities and Health Seeking Behaviour The health facilities in the Study Area follow a three-tier health infrastructure system, as also applies to the state of MP. The health facilities available at the village level comprise of Primary Health Sub Centres and Public Health Centres (PHC). While the sub centres cater to a population of 5,000 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 122 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS STAKEHOLDER IDENTIFICATION, INFORMATION Final ESIA Report DISCLOSURE, CONSULTATION AND PARTICIPATION individuals, the PHCs are for a population of 10,000-30,000 individuals. While the PHCs are mostly for OPD (Out Patient Department) and basic IPD (Indoor Patient Department) cases, sub centres usually have a delivery room and two resident nurses (one male and one female). Each PHC has 5-6 sub centres under them. In turn, a cluster of 6-10 PHCs come under a CHC (Community Health Centre), which caters to a population exceeding 1 lakh, and also provides emergency services. The CHCs in turn report to the public hospitals at the district level. The villages of the Study Area have access to 2 Primary Health Centres, one each in Nayagaon and Jhantala villages. Four AoI villages of Dhangaon, Dhardi, Funsariya and Kadwasa, have a Primary Health Sub Centre in their village. 4.4.10 Energy Use The population in the Study Area is understood to use both LPG as well as dung cakes (as fuel source) to meet their daily domestic energy requirements. While LPG adoption and availability across the villages has improved over the past few years because of Pradhan Mantri Ujjwala Yojana; firewood and burning dung cakes as fuel continues to be the main domestic fuel for cooking requirements. This usage/dependence also goes up to form the overall economics of livestock rearing in the area. 4.4.11 Gender: Role in Society The Project Villages exhibit lower adult sex ratio and child sex ratio as compared to the AoI, tehsil, district and the state figures of sex ratio (both adult and child). The probable reason for the trend can be attributed to higher infant mortality rates among girls or cultural preference of male children, possibly leading to sex selective abortions, which causes an imbalance in the gender composition in the region. The practice of differential treatment of boys and girls could not be gauged through the consultations conducted in the project area villages. The consultations suggest that in particular social and caste groups in the villages, there is lower participation of women in agricultural activities or any activities outside the house, there is also lower participation in household or economic decision making and women possess fewer independent economic means. Figure 4.32 Comparison of Adult and Child Sex Ratios across Study Area, Tehsil and District 1200 1000 800 600 400 200 0 Project Study Singoli Neemuch Madhya AoI Villages Area Tehsil District Pradesh Adult Sex Ratio 915 950 948 960 954 931 Child Sex Ratio 750 892 880 923 927 965 Source: Census of India, 2011 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 123 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS STAKEHOLDER IDENTIFICATION, INFORMATION Final ESIA Report DISCLOSURE, CONSULTATION AND PARTICIPATION 4.4.11.1 Gender Roles in a household The consultations suggest that in a household, women from most social and caste groups, take equal ownership and responsibilities of working on agricultural fields owned by their household, taking care of domestic chores of cooking, cleaning, fetching water from community water points to their respective houses, caretaking of children and elderly as well as tending to livestock owned by the family. Men are largely responsible for management of financial resources, sale and purchase of goods, agriculture related work in the fields, including sale of produce, etc. and their contribution to domestic chores of cleaning, cooking, caretaking is limited. The occupational profile of the community is detailed in Section 4.4.7 options primarily comprise working as cultivators, agricultural labours, construction labours,. There have not been any cases reported for women working as construction labourers or in any enterprise outside their respective villages. 4.4.11.2 Gender Roles in Livestock management and Agriculture Women take care of stall feeding of livestock, cleaning of livestock and their sheds, preparation of dung cakes, milking, etc.; but are not responsible for grazing of livestock outside the household premises. Male members of the household are responsible for livestock grazing near the villages, sale and purchase of livestock, livestock feed and by products. The women from Rajput community are a little different from the rest, as they are only responsible for household chores and have restrictions on their movement outside the house, therefore, do not do any agricultural work in the fields. On the agricultural fields, women are involved in cutting, sowing, threshing, watering, and collecting fuel wood. The women engaged as agricultural labourers are paid an amount of INR 100-200 per day where as men are paid INR 200-300. The tasks that are taken care of by men include sale and purchase of agricultural inputs, sale of crops in markets and Mandis and other farm based activities. 4.4.11.3 Gender profile in Asset ownership The exposure of women outside the realms of their villages was observed to be limited as few travel outside other than for functions or religious events. There are no Self Help Groups reported to be active in the project villages, in the village consultations. The ownership of land and assets by women is also understood to be minimal and in cases where women own land legally, the management of the same in terms of sale, purchase or usage is decided by the men in the family, with limited or no consultations with women. The proceeds from sale of land and its usage is also usually discussed within households but the final decision on usage of money is taken by male members of the household. The men have more social exposure and access to cash and linkage to banking services, understanding of financial and legal instruments, etc. which makes them the natural decision making authority in a household. Women are restricted in their movement outside villages due to socio- cultural practices and safety issues and in spite of being equal contributors to the household (which forms unpaid work); have less access to cash and resources for discretionary spending. Women Headed Household There are some women headed households in the project villages; however in most cases these Women Headed families are provided financial support and security by other members of their extended family, as part of the prevalent joint family and living systems. However, women headed households that are living independently from their extended families, have to fend for themselves, by working as labourers on agricultural fields. These Women headed households (both joint as well as independent) face additional risks of not being included in negotiations, or other key meetings due to prevailing cultural norms and may not www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 124 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS STAKEHOLDER IDENTIFICATION, INFORMATION Final ESIA Report DISCLOSURE, CONSULTATION AND PARTICIPATION therefore receive the benefits and advantages compared to those who do participate. Thus they become a little more vulnerable in cases of sale of land for the project, where there is a chance that the proceeds from sale of land do not reach them. 4.4.11.4 Gender Roles as community leaders women in interacting with the general public due to cultural practices. One (of the many) such case observed in Badi village is presented below. Box 4.3 Role of Women as Elected Representatives In Badi village, a woman was elected as the Sarpanch of the Badi Panchayat on a seat reserved for women. However, during community consultations Sarpanch-pati solely participating in discussions and reporting on village statistics. The female Sarpanch did not consultation, the female Sarpanch spoke about general issues, but was not aware of a lot of details as reportedly she did not visit any of the villages in her constituency and those responsibilities were carried out by her husband solely. While reservation of seats has ensured that more women are elected, functional participation and leadership still transfer by proxy to their husbands. Source: ERM Site visit in November 2019 Section 5 discusses the various categories of stakeholders that are present in the Study area for this assessment and presents their profiles, expectations from and influence on the project. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 125 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS STAKEHOLDER IDENTIFICATION, INFORMATION Final ESIA Report DISCLOSURE, CONSULTATION AND PARTICIPATION 5. STAKEHOLDER IDENTIFICATION, INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION 5.1 Stakeholder Identification and Categorization A stakeholder is defined as 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 . During the ESIA process, a stakeholder identification and prioritization was conducted for identifying the key stakeholders of the project, while keeping in mind the nature of the project and its setting. Furthermore, consultations were conducted with these identified stakeholders through a participatory approach. The table below presents the key stakeholders of the project. Table 5.1 Stakeholder Group Categorisation Stakeholder Groups Primary Stakeholders Secondary Stakeholders Community Private Land Owners from Bardawada, Fence Line Communities Kawai, Badi villages from other villages in the Patta Holders from Bardawada, Kawai, Badi vicinity villages Non- Squatters and Encroachers Agricultural Labourers the patta based on a verbal Graziers agreement with the original Vulnerable Social Groups in other villages in (and registered) patta the vicinity holder; Contractors Potential unskilled labourers to be engaged for the construction phase of the project Owners of land required for temporary occupation or use Local Community from Project villages. Institutional Gram Panchayats of Dhardi (for Bardawada Local Political Groups Stakeholders village) and Badi (for Kawai and Badi Civil Society/ Local NGOs villages); Singoli Tehsil officials Government Regulatory Authorities comprising the Bodies/Regulatory following: - MP Pollution Control Board; Authorities - Central Pollution Control Board (CPCB) - Ministry of Environment Forest and Climate Change (MoEFCC) - Local Fire Authority; - Ministry of Road Transport and Highways - State Transport Authority; - District Collector and Revenue Department; - Central Electrical Authority through C.E(P&D) Jabalpur; - Department of Telegraph Communication, Govt. of Madhya Pradesh; - Department of Panchayati Raj, Madhya Pradesh; - Labour Department; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 126 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS STAKEHOLDER IDENTIFICATION, INFORMATION Final ESIA Report DISCLOSURE, CONSULTATION AND PARTICIPATION Stakeholder Groups Primary Stakeholders Secondary Stakeholders - Wildlife Warden, State Forest Department; - District and State Forest Department, MoEFCC. District Administration 5.2 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 stakeholder group and urgency/likelihood of the impact associated with the particular stakeholder group in the project context. The magnitude of stakeholder impact/influence is assessed taking the power/responsibility and proximity 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 on a scale of low, medium and high. The overall significance of the stakeholder group is assessed as per the matrix provided in table below. Table 5.2 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 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 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. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 127 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR STAKEHOLDER IDENTIFICATION AND PARKS ENGAGEMENT Final ESIA Report Table 5.3 Stakeholder Analysis Relevant Profile/ Status Impact/Influence of the Impact/Influence of the Expectations, Opinions Key Overall Stakeholders project on this Stakeholder Stakeholder Group on Concerns of Stakeholders Rating of Group the project Stakeholder Influence Primary Stakeholder Private Land Private Land Owners The project will be set up The stakeholder Concerns regarding land High Owners and comprise of those on 35.488 ha. of private being procured by the Project, Patta Holders households, whose land land and 87.734 ha Patta the project is because there has been from parcels are falling within land parcels across the pertinent to smooth significant cost and effort Bardawada, land footprint of the Solar three villages; land availability and expended in the preparation Kawai, Badi Park. The dependence on land its support is key for of the land for making it villages Patta holders comprises of for agriculture and the smooth cultivable; households that were livestock in the area is functioning of the Adequate payment for the assigned land (Patta), by high, as depicted in the project related land being procured for the dint of their landlessness (or Census data and reported activities in the area. project activities, including for other vulnerabilities), in during consultation; those without any formal 1950s- 60s to 80s, under The purchase of land for recognized ownership various schemes. the project development documents, who may have The criteria and terms for activities will affect this allotting Patta land were stakeholder group leading verbal agreement; different as this was done at to reduced land holdings; Minimal disturbance to the different times, for different Additionally, if this community with regards to purposes. The Tehsil office stakeholder group is access issues, pollution, reported that these provided with an alternate health and safety risks and documents were lost over land parcel, the quality of influx of migrant workers time and are not available; alternate land parcels and This Stakeholder group may This group is dependent on the effort and investment expect income generating their land parcels for their required to make it fit for activities or employment as livelihood needs; cultivation, is also of key construction labourers, This includes the land concern, as there are masons, drivers, etc. during owners in the RoW of the certain rocky patches of the construction phase of the Transmission Line routes for land existing in and around Project. the project. the project area. The exact number of land owners for the project is not currently known. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 128 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR STAKEHOLDER IDENTIFICATION AND PARKS ENGAGEMENT Final ESIA Report Relevant Profile/ Status Impact/Influence of the Impact/Influence of the Expectations, Opinions Key Overall Stakeholders project on this Stakeholder Stakeholder Group on Concerns of Stakeholders Rating of Group the project Stakeholder Influence Encroachers/ This stakeholder group This stakeholder group has The influence of this The key concern of this Medium occupiers/ comprises of households been using the land for stakeholder group stakeholder group is of losing squatters (for that have illegally livelihood activities; though present in project villages the land parcels which they agriculture) encroached/occupied does not have legitimate on the project is have been using for Government Landin the claims or ownership of the moderate, considering agriculture; project area and around. land. In fact, they are well they do not have legal This group reports that they Encroachment of aware of their illegal status; rights on the land; have spent considerable Government land is a The project would be set however, they have amount of effort and money to general practice in the area, up on the encroached land influence in the village by make the land cultivable and where certain households and would lead to virtue of their economic all this effort will be wasted start using Government land disruption of economic power (they are all land after the project comes on this for agriculture, without any activities and incomes to owners and employers of land; legal ownership of the land these households, and agricultural labour). They Additionally, their concern is parcel. those employed by them have previously held for the proportion of land In Neemuch, it has been on these lands (usually agitations and protests parcels under their reported that the practice of seasonally). (in 2019) as they do not possession which are encroachment is usually want to part with their undeclared; undertaken in the project encroached land parcels, The Revenue inspector and area by the relatively well-off given that they have his team, which undertook the households, that already made several land mapping exercise did not own land; improvements to it and note the encroached land When the encroachment made this land parcels (as this was not his related practices are productive. There have mandate) and thus this identified by the Government been some media stakeholder group is officials, this group is willing reports recently that have concerned that they may not to pay small fines against highlighted community receive any compensation or the use of Government land; protests for land take in benefits; however, in such scenario, Solar parks. This Stakeholder group may the Encroachers do not expect income generating disclose the exact activities or employment as encroachment and only construction labourers, declare a fraction of the masons, drivers, etc. during actual encroached land to, in the construction phase of the their understanding, get Project. some sort of sanction to continue to informally occupy and use the land. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 129 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR STAKEHOLDER IDENTIFICATION AND PARKS ENGAGEMENT Final ESIA Report Relevant Profile/ Status Impact/Influence of the Impact/Influence of the Expectations, Opinions Key Overall Stakeholders project on this Stakeholder Stakeholder Group on Concerns of Stakeholders Rating of Group the project Stakeholder Influence This practice helps them to make official records of their dependence on the land, simultaneously saving the fines for the actually encroached land, which would be significantly higher. To make it productive, most occupiers have made improvements to the land, including installing bore wells and improving the soil quality through use of manure and repeated cultivation and tilling. Agricultural This stakeholder group The land procurement for The influence of this This Stakeholder group may Low Labourers comprises of those the project will be group on the project expect employment as households that have impacting their income is limited, given that construction labourers, marginal or limited land sources, thereby leading to they do not have any masons, drivers, etc. during holdings and members of a deterioration of the legal claims on the the construction phase of the their families work as household income. land; Project. Agricultural labourers in the This group can be land parcels falling in the used during the area identified for project construction phase across all three categories- of the project as private land, patta land (that unskilled labour with is being cultivated), and priority hiring and encroached land under may additionally be agriculture included in Livelihood Restoration initiatives; Graziers The Government land in the The procurement of The influence of this The key expectations of this Low people from the Project Footprint is reported Government land that is group (including stakeholder group is to allow Project villages to be used by the community being used shall reduce those who have for provision of adequate www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 130 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR STAKEHOLDER IDENTIFICATION AND PARKS ENGAGEMENT Final ESIA Report Relevant Profile/ Status Impact/Influence of the Impact/Influence of the Expectations, Opinions Key Overall Stakeholders project on this Stakeholder Stakeholder Group on Concerns of Stakeholders Rating of Group the project Stakeholder Influence who use the for grazing of livestock of the amount of land created and use grazing land in the project government land nearby villages. There are available for grazing near private fodder lots on area for livestock grazing- as open grazing approx. 4000 heads of the project villages; occupied ensuring quality and access; area for their livestock (comprising Cows, This land procurement may government land,) Easements shall be provided livestock Buffaloes, and Goats) in the also lead to impact on on the project is through project design three project villages. easement or access to limited, given that elements to have minimal The livestock ownership in other areas available for they do not have any impact on this stakeholder the Project villages is higher livestock grazing. legal claims on the ities. amongst Gurjar community land; (Cows and Buffaloes), while Livestock forms an Bhil community is reported important part of the to possess a higher number of Goats. and energy source The local community has and may impact also done boundary marking availability of food on government land, to (milk, meat, etc.) demarcate grazing areas for during construction an individual household or a phase, to some group of households, by extent is affected badly. livestock from the village is fed commercially, by charging INR 1000 per livestock per year. Vulnerable This stakeholder group is The influence of project on The involvement of Priority in economic benefits Medium comprised of this group is similar in this stakeholder and development social groups groups/households that are nature as the entire fence group is expected to opportunities created by the such as women considered to be vulnerable line community, as it is a be as part of the project; headed due to their social, political subset of the same. larger local Minimal disturbance to the households, or economic status in the community; community in regards to society. This stakeholder access issues, grazing land, BPL and For the project, the group should be pollution and influx of migrant Landless vulnerable groups are specifically workers. households identified as women & consulted to ensure women headed households, adequate provisions elderly, physically in the RAP and LRP www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 131 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR STAKEHOLDER IDENTIFICATION AND PARKS ENGAGEMENT Final ESIA Report Relevant Profile/ Status Impact/Influence of the Impact/Influence of the Expectations, Opinions Key Overall Stakeholders project on this Stakeholder Stakeholder Group on Concerns of Stakeholders Rating of Group the project Stakeholder Influence handicapped, landless and for the differential those with less than 1 ha of impacts expected on land and families in the this group Below the Poverty Line Category. Indigenous While the project is not The influence of project on The involvement of Priority in economic benefits High located in a scheduled V this group is similar in this stakeholder and development People area, the local community is nature as the entire fence group is expected to opportunities created by the comprised of ST population. line community, as it is a be as part of the project; The largest proportion of ST subset of the same. larger local Minimal disturbance to the population is in the Project community; community in regards to Villages of the Neemuch In keeping with the access issues, grazing land, Solar Park. requirements of the pollution and influx of migrant The utilization of IFC PS 7, the project workers. Government land and loss of will require to obtain Common Property resources Free Prior Informed in the area, that are used by Consent from this STs is critical and triggers stakeholder group FPIC prior to the initiation of project activities. EPC/ This stakeholder group The project provides this This stakeholder Continued economic High Construction comprises of the EPC group contractor-ship group is critical for opportunities and work Contractors, contractors and other opportunities and steady the smooth generation; sub-contractors contractors/ sub-contractors flow of income. functioning and Clarity in terms of scope of involved in the Project for timely work, expectations, key various tasks, like access implementation of performance indicators, roads construction, laying the Project; responsibilities and timelines down of Transmission Line This group may also towers, civil and electric play an important for the project; works for the Solar Park, role in the formation Timely and adequate etc. of public opinion disclosure of information to towards the project allow the project activities to be carried out; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 132 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR STAKEHOLDER IDENTIFICATION AND PARKS ENGAGEMENT Final ESIA Report Relevant Profile/ Status Impact/Influence of the Impact/Influence of the Expectations, Opinions Key Overall Stakeholders project on this Stakeholder Stakeholder Group on Concerns of Stakeholders Rating of Group the project Stakeholder Influence Fair business opportunities and contract closure; Undertake project activities in keeping with the contractual agreements and applicable regulations in place. Unskilled This group is comprised of If local labour is used, it will This stakeholder Concerns pertaining to Low labourers to be skilled and semi-skilled help create goodwill locally group will be critical wages, benefits, working workers, who will be and the project related for the smooth engaged for the involved in the project on a opportunities would be functioning and hours and working conditions, construction contractual basis. shared with the local timely etc.; phase of the Labour may be local, population. implementation of Health and safety involved project regional or migrant (from the project; with the construction phase other regions) and is likely to This group may also be comprised of skilled play an important Working hours at the worker and any number of role in the formation construction site semi-skilled or unskilled of public opinion Timely disbursement of workers This decision will be towards the project. wages; on their requirements. Access to the GRM established for the project Owners of land Some of the project The short term leasing of This stakeholder The expectations of this Medium required for components would require land by the project may group is critical for stakeholder group is clear temporary short term leasing of land bring in additional income availability of land occupation available, largely from from lease, if the land is parcels that are communication of lease terms or use Private and/ or Patta land not being used for any conveniently located and amount and timely owners; other commercial from the project payments, as necessary; This requirement would be purposes; footprint (based on better understood during the The project related the needs) and are Restoration of land to its time of initiation of activities on these land available without original state, or better, at the construction activity. parcels may be for disturbances or time of handing it back to the purposes of storage, set up issues during the of labour camps, etc. and lease period. owners. may result in change in www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 133 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR STAKEHOLDER IDENTIFICATION AND PARKS ENGAGEMENT Final ESIA Report Relevant Profile/ Status Impact/Influence of the Impact/Influence of the Expectations, Opinions Key Overall Stakeholders project on this Stakeholder Stakeholder Group on Concerns of Stakeholders Rating of Group the project Stakeholder Influence land use due to construction or storage activities, contamination issues, etc. Gram This stakeholder group is The influence of project on This group has the Involvement of this group in Low Panchayats comprised of Sarpanch, this stakeholder group is ability to influence decision making process for (GPs) of Dhardi ward member and Gram minimal due to limited the perception of the the project, especially related (for Bardawada Sewak of Panchayats of control that the project can community in to the land taking process village) and Badi Dhardi (for Bardawada exert on the functioning of regards to the Involvement in the formulation (for Kawai and village) and Badi (for Kawai this group. There may be Project and its and implementation of the Badi villages) and Badi villages). higher influence of this activities community development group just before the local activities for the project; elections Adequate communication of project information, in terms of timelines of key activities and their potential impacts. Singoli Tehsil/ This group is comprised of The project should be in This stakeholder Developmental activities in High the regulatory authorities at compliance with the group is high in the project area; Neemuch district the tehsil and district level requirements stated and priority as this group Smooth operations of the officials (District that are responsible for land the processes governed by provides the land project related activities by demarcation, allotment of this stakeholder group. demarcation and causing minimal impacts on office) patta land, for the project Their involvement for permits and licenses the community; and for various permits and resolution of patta land essential for the Adherence to regulations and licenses pertaining to the related issues will be functioning of the maintenance of law and order project. essential project; The decisions regarding They will be required to Noncompliance to whether to provide alternate provide support for law and conditions laid down order for the smooth and in permits issued by peaceable functioning, of this group sale, and how other matters construction activities, and stakeholders group pertaining to patta land may to resolve grievance that can result in be resolved also require may be escalated to them. penalties and fines www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 134 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR STAKEHOLDER IDENTIFICATION AND PARKS ENGAGEMENT Final ESIA Report Relevant Profile/ Status Impact/Influence of the Impact/Influence of the Expectations, Opinions Key Overall Stakeholders project on this Stakeholder Stakeholder Group on Concerns of Stakeholders Rating of Group the project Stakeholder Influence their participation and final being levied on the decision. Project. Regulatory This stakeholder group is The main concerns of the The ability of the comprised of the central, Regulatory Authorities from project to comply regulatory requirements; Authorities at state and district level the Project Proponents is with the various Timely disclosure of state and central regulatory authorities; abidance to all applicable applicable rules and information and provisioning levels These authorities influence guidelines, policies and regulations may play of updated through the life of the project in terms of laws. a role in the timely the project establishing policy, granting implementation of This stakeholder group is also permits and approvals for the project. critical for various the project, monitoring and permits/clearances required enforcing compliance with for the commissioning of the the applicable rules and project regulations. Secondary Stakeholders Fence Line This stakeholder group is The project will use land This stakeholder Adequate provisions of High comprised of the local which is currently being group shall play a easements while designing Community population in the three used by this stakeholder critical role in the various project features in villages, coming under the group in accessing their smooth functioning order to ensure minimal project boundaries that are farms, lakes and other of the Project. access restriction for this not directly impacted by the common areas, grazing group; Project activities as well as their livestock, etc.; Minimal disturbance to this population residing in other Some of the community group due to various activities villages in the Study area of members also use this of construction, operation and the project; land for cultivation (through decommissioning phases, encroachments) or work on including plying of vehicles for the farm lands as transportation purposes, using agricultural labourers, etc. the roads near these villages. These activities will be disrupted after the project related activities commence on the identified land www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 135 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR STAKEHOLDER IDENTIFICATION AND PARKS ENGAGEMENT Final ESIA Report Relevant Profile/ Status Impact/Influence of the Impact/Influence of the Expectations, Opinions Key Overall Stakeholders project on this Stakeholder Stakeholder Group on Concerns of Stakeholders Rating of Group the project Stakeholder Influence Local Political This stakeholder group is The project will have This stakeholder The main expectation and Low comprised of the political minimal or no influence on group is expected to concern of the stakeholder Groups parties and local politicians this stakeholder group play a critical role in group from the project active in the region; the development of This group might be active in the public opinion the development of the area the area and may play an towards the project, in keeping with the broader important role in the especially in light of agenda of the projects and polarisation of public opinion the current political keeping the constituents and towards the Project. environment in the loyalists of the parties at the country. forefront. Civil This stakeholder group The level of influence of project The stakeholder The main expectations and Medium on this stakeholder group is group may play an concerns of the stakeholder Society/Local comprises of NGOs and Civil limited as it does not affect the important role in the group from the project is likely NGOs Society Organizations of a functioning of this group. development of to include the development of national, state and local level public opinion for the the project, in keeping with who may be active in the area. project; the applicable regulations and This stakeholder with minimal impacts on the Most of the NGOs and CSOs group may also be local population, while working in the region are state involved in the contributing towards the level NGOs, involved in literacy, implementation of overall development of the water management, WASH and the community area gender equality some of the key development plans The interest of this stakeholder group primarily NGOs and CSOs working in the pertains to the roles of the region include the following: project in implementing Water Aid community development Neemuch Gabli Educational activities in the area; & Social Welfare Society Involvement in the formulation Seema Mahila Mandal, and implementation of the Neemuch community development Gramya Evam Bal Utthan activities for the project; and Samiti Timely disclosure of Grask Gramin Rojgar Evam information pertaining to the Samaj Kalyan Samiti Samiti project. Dewas Guru Shaheb Public Education Society www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 136 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR STAKEHOLDER IDENTIFICATION AND PARKS ENGAGEMENT Final ESIA Report Relevant Profile/ Status Impact/Influence of the Impact/Influence of the Expectations, Opinions Key Overall Stakeholders project on this Stakeholder Stakeholder Group on Concerns of Stakeholders Rating of Group the project Stakeholder Influence Gurudev Samaj Kalyan Samiti Ashoknagar Gyanmanu Mahila Mandal www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 137 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report 6. ENVIRONMENTAL AND SOCIAL IMPACTS This section assesses the manner in which the Project will interact with elements of the physical, ecological or social environment to produce impacts to resources/ receptors. It has been organized as per the phases of the project i.e. pre-construction, construction and operational phases of the project life cycle to understand the risks and impacts associated with each phase. 6.1 Impact Assessment Methodology The ESMF for Solar Park (Feb 2017) states that sub-projects shall be appraised based on a step-by- step process beginning with screening stage. The overall process as depicted in the ESMF is reproduced here and followed in the study. Figure 6.1 Impact Assessment Process Source: Developed based on ESMF process as per ESMF for Solar Park, Feb 2017, page-27 and ERM IA Standards This section describes the impact assessment steps and methodology followed in this report which complies to the impact identification process and methodology (Section-4) of the ESMF for Solar Park. 6.1.1 Screening and Scoping An Environmental and Social Scoping Study for the entire 1500 MW Project had been previously undertaken during September 2018- March 2019. The earlier identified impacts has been revisited during the ESIA study to confirm/validate the scoping study outcome. The screening checklist provided in ESMF for Solar Park (page 29) is used to identify relevant components to be investigated in detail during this study. The results of this screening are provided in table below. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 138 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Table 6.1 Screening for Impacts Environmental and Status/Availability in and around site ( Justification for Expectation of Potentially Social features study area) Significant Impacts Physical Environment Land use and Land The current land use of the In the construction phase, temporary land cover proposed project site is agricultural use changes will occur at contractor land, grazing land, and scrub land facilities and labour camps, material with some trees storage areas; Some are is under water features During construction phase, there will be like natural drains, ponds permanent change of the land use within the land parcels where the Solar Park and pooling substation will be established. Topography and The Project site area is fairly flat Impact on topography of the Project site Slope percentage land; due to site levelling activities. The high gradient area, i.e. area > 7o is nil. Soil Environment Changes in soil quality: Soil in the area is black cotton soil; Any use of controlled explosives in rocky No major anthropogenic activities strata that leave trace amounts of chemicals; are carried out in the area which Use of drilling fluids (natural, oil-based or may lead to soil contamination. synthetic) that can leave trace amounts of There are stone quarrying activities chemicals; occurring on the site, mainly in Unit Improper waste disposal; 3 area. Discharge from contractor facilities, labour camps and site office; Soil contamination due to accidental leaks and spills of oil, lubricants, or fuel from construction equipment. Compaction of soil during excavation, transportation of construction material & tower components, foundation work, backfilling, tower erection and stringing; During operation phase, soil environment will mainly be impacted due to disposal of municipal solid waste, improper storage and disposal of broken solar panels, , accidental spill of transformer oil (Fresh and used oil) and waste water from site office. Generation of hazardous waste during operation of Solar Park. Ambient Air Quality As per baseline monitoring Dust emissions due to movement of conducted for the Project, ambient machinery and vehicles; air quality parameters (PM10, PM2.5, Fugitive dust emissions due to site SO2, NOX) were within the clearance activities, excavation and back prescribed CPCB limits. filling activities etc.; Air emissions due to operations of D.G. sets. Ambient Noise As per baseline monitoring Noise generation due to construction Quality conducted for the Project, the noise levels during day and night time machineries, D.G. sets, movement of were observed within the CPCB vehicles and heavy earth moving prescribed limits. However, at two machineries. ; locations day time noise levels are www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 139 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Environmental and Status/Availability in and around site ( Justification for Expectation of Potentially Social features study area) Significant Impacts at the edge of prescribed limit of 55 Local communities may get disturb due to dB for daytime. higher than anticipated noise. Water Resources and Stress on local water resources due to The Quality water requirement for the foundation block (Jawad Block) as per CGWB; activities, establishment of substation, Water bodies present in the study labour camp during construction phase are mostly rainfed and are used for and domestic water use , module cleaning domestic purposes as washing of during operations; clothes and for domestic animals. Surface water and ground water contamination due to improper disposal of sewage at site and labour camp; Impact on surface water quality due to runoff from storage area during monsoon; Soil erosion and sediment transport to nearby water bodies. Drainage Project site have water bodies and Any changes to topography in the area will 3rd or 4th order dendritic drainage advertently impact the drainage channels channels within the site area. and might result in water logging in adjoining areas of the Project site. Biological Environment Ecology Habitats in the study area include The Project site is located on scrub land agricultural land, open scrub, water and clearance of vegetation may affect the bodies and open forest areas (no local ecology through the loss of shelter, forest area within Project footprint); foraging resources, shade and roosting sites; The closest legally protected area is A water body is adjacent to the south of Gandhi Sagar Wildlife Sanctuary, Unit 3. This water body supports migratory [IUCN Management Category IV] bird activity and flocking behaviour among which is located ~ 50 km southeast 2-3 winter migrants; and of Unit 3; The Project is located close to Arnea The closest internationally Reserve Forest and its contiguous forest recognized biodiversity area is land leading into Rajasthan. The forest land Gandhi Sagar Wildlife Sanctuary supports some high conservation species and reservoir which is located ~32 including leopard, sloth bear and vulture km southeast of Unit III3. This is species (some sightings). also declared an Important Bird and Biodiversity Area (IBA) and supports significant concentrations of water birds (IBA Category A4iii); Four species of herpetofauna, 58 species of avifauna and 12 species of mammals were recorded/reported from the study area during site visit. Occupational health Occupational health hazards; and safety Safety risk due to wrong handling of construction machinery, working at height, etc.; Exposure of workers to Electromagnetic Field (EMF) while working in proximity to charged electric power lines during www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 140 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Environmental and Status/Availability in and around site ( Justification for Expectation of Potentially Social features study area) Significant Impacts construction and operation and maintenance. Social Environment Demographics The project footprint falls in three The EPC contractor or its sub-contractors Project villages, while the AoI will bring in skilled migrant labour during comprises 32 villages. The Project construction phase of the project that is villages comprise of 440 households expected to last for about 21 months; while with a population of 2,047 for most of unskilled and semi-skilled individuals (as per 2011 Census works, preference will be given to local data while the current figure is people. Displacement of local people is not expected to have increased envisaged for the proposed Solar Park significantly). however there are chances of migration of The average size of the households members of land selling households to is 5 in the Study Area cities in search of wage labour jobs, in light of lesser or limited land holdings available in the village. Economy and The population is currently engaged Solar Park will generate employment Employment in agriculture, animal husbandry and opportunity for local people mostly during jobs as agricultural labourers construction phase as well as for select activities (and in smaller numbers) like module cleaning, grass cutting and security related jobs during operation phase. Land based Impacts The population is currently engaged Land based livelihood may be hampered in agriculture, animal husbandry and due to procurement of Private, Patta and jobs as agricultural labourers Government land for the project. The residents of the project villages are engaged in cultivation in and around the land identified for the project footprint; There are understood to be more than 600 Project affected people due to land procurement related impacts. The setting up of project would lead to loss or reduction of agricultural income for Private land owners, patta land holders, squatters and encroachers on Government land, agricultural labourers, Graziers, etc. Community health Proposed Project site have Setting up of labour camps in the proximity and safety settlements in proximity of the communities and use of village roads for transportation of material and labour is likely to induce negative impacts such as road accidents, air pollution, noise pollution, potential conflict between the local community and labourers, increased risk of gender based violence, etc. Transportation of construction materials and increased vehicular movement will lead to traffic hazards for community residing close to the access roads. Indigenous People There is presence of Bhil (ST) This group is present and is understood to households across the three villages be working as agricultural laborers in of the project; however, extent of private and patta land parcels (perhaps impact by the project needs to be also on encroached Government land www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 141 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Environmental and Status/Availability in and around site ( Justification for Expectation of Potentially Social features study area) Significant Impacts determined through focused parcels) and thus will be economically consultations displaced due to project related land procurement 6.1.2 Impact Matrix In addition to the screening checklist, various project features and activities that could reasonably act as a source of impact were identified, and these have been listed down the vertical axis of a potential interactions matrix. The resources/receptors in the environment have been listed across the horizontal axis of the matrix. The interaction matrix enables a methodical identification of the potential interactions each Project activity may have on the range of resources/receptors within the Area of Influence i.e. the study area for the Project. The completed Potential Interactions Matrix for Project activities and likely impacted resources/ receptors is presented in Table 6.2. The matrix consists of a list of resources/receptors that could be affected against a list of activities for the proposed Solar Park. Entries in the matrix cells are colored to indicate whether: An interaction is not reasonably expected (white); An interaction is reasonably possible and the resulting impacts are likely to lead to low effects (grey); or The interaction is reasonably possible and at least one of the resulting impacts is likely to lead to medium or high effect (black). www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 142 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Table 6.2 Activity Receptor Interaction Matrix Resources/Receptors Project Activities Land use and land classification Soil Environment Ambient Air Quality Ground Water Resources and Quality Surface water Resources and Quality Topography and Drainage Noise and Vibrations Occupational health and Safety Community Health and Safety Electromagnetic field Traffic Terrestrial Ecology Aquatic Ecology Land based Livelihoods/ Economic Displacement Labor Welfare Social Infrastructure and Services Indigenous People Cultural Heritage Pre- Construction/Planning Phase Site Survey Project designing and planning Land use change for Solar Park and substations site Construction Phase Widening/ strengthening of access roads Transport of equipment, machinery, materials and labour Establishment of material storage area Establishment of contractor facilities and labour camps Site Clearance Site preparation and levelling Operation of Batching Plant, if any Operation of D.G. set Excavation, foundation and construction works for Solar Park, substations and internal TL Installation of PV modules and other electrical equipment at park and substation www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 143 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Resources/Receptors Project Activities Land use and land classification Soil Environment Ambient Air Quality Ground Water Resources and Quality Surface water Resources and Quality Topography and Drainage Noise and Vibrations Occupational health and Safety Community Health and Safety Electromagnetic field Traffic Terrestrial Ecology Aquatic Ecology Land based Livelihoods/ Economic Displacement Labor Welfare Social Infrastructure and Services Indigenous People Cultural Heritage Operation Phase Cleaning of PV modules Operation and maintenance of Solar Park and associated facilities Operation and maintenance of Substation Grass Cutting = = Represents interactions reasonably possible but none of the outcome will lead to significant impacts = Represents interactions reasonably possible with one of the outcomes leading to potential significant impact www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 144 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report 6.1.3 Prediction of Impacts Prediction of impacts is carried out with an objective to determine what is likely to happen to the environment as a consequence of the Project and its associated activities. From the potentially significant interactions identified in scoping, the impacts to the various resources/receptors were elaborated and evaluated. The list of impacts which were identified from this for detailed assessment for different stages of the project is as follows: Phase Impact/Potential Impact Title Planning Phase Impact due to Private Land Purchase Impacts due to Patta land Purchase Impacts due to LUPA of Government land Planning and Land use and Land cover Construction Phase Soil environment Topography and Drainage Water resources and quality Ambient air quality Ambient noise quality Occupational health and safety Habitat Modification and Loss Impacts due to construction Activities Ecosystem Services Impacts due to temporary occupation of land for construction activities Impact on Community Health and Safety Stress on community resources Impact on Employment and Entrepreneurship opportunities Impact on women Operation Phase Soil Environment Water resources and quality Health and safety Collision and Electrocution risks Community health and safety Impact on employment Impact on Indigenous Communities/Vulnerable groups Impact on women 6.1.4 Evaluation of Impacts- Impact Significance Each impact was described in terms of its various relevant characteristics (e.g., type, scale, duration, frequency, extent). The terminology used to describe impact characteristics is as shown in Table 6.3. Table 6.3 Impact Characteristic Terminology Characteristic Definition Designation Type A descriptor indicating the relationship of Direct the impact to the project (in terms of Indirect cause and effect) Induced Extent Local to a small area around the Project National Footprint, projected for several Global kilometres, etc.) www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 145 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Characteristic Definition Designation Duration The time period over which a resource/ Temporary receptor is affected. Short-term Long-term Permanent Scale The size of the impact (e.g., the size of [no fixed designations; intended to be a the area damaged or impacted, the numerical value or a qualitative description fraction of a resource that is lost or affected, etc.) Frequency A measure of the constancy or periodicity [no fixed designations; intended to be a of the impact. numerical value or a qualitative description] The definitions for the type designations are given in Table 6.4. Definitions for the other designations are resource/receptor-specific. Table 6.4 Impact Type Definitions Type Definition Direct Impacts that result from a direct interaction between the Project and a resource/ receptor Indirect Impacts that follow on from the direct interactions between the Project and its environment as a result of subsequent interactions within the environment Induced Impacts that result from other activities (which are not part of the Project) that happen as a consequence of the Project. The above characteristics and definitions apply to planned and unplanned events. An additional characteristic that pertains only to unplanned events is likelihood. The likelihood of an unplanned event occurring was designated using a qualitative scale, as described in Table 6.5. Table 6.5 Definitions of Likelihood Designations Likelihood Definition Unlikely The event is unlikely but may occur at some time during normal operating conditions (probability less than 20%) Possible The event is likely to occur at some time during normal operating conditions (probability greater than 20% and less than 50%) Likely The event will occur during normal operating conditions (probability greater than 50% typically a function of a combination (depending on the resource/receptor in question) of the following impact characteristics: Extent Duration Scale Frequency www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 146 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Magnitude essentially describes the intensity of the change that was predicted to occur in the resource/receptor as a result of the impact. As discussed above, the magnitude designations themselves are universally consistent, but the descriptions for these designations vary on a resource/receptor-by-resource/receptor basis. The universal magnitude designations are: Positive Negligible Small Medium Large considered sufficient for the purpose of the IA to indicate that the Project was expected to result in a positive impact, without characterising the exact degree of positive change likely to occur. In the case of impacts resulting from unplanned events, the same resource/ receptor-specific ctor was considered, together with the other impact characteristics, when assigning a magnitude designation. In addition to characterising the magnitude of impact, the other principal impact evaluation step was definition of the sensitivity/ vulnerability/ importance of the impacted resource/receptor. There are a range of factors that was taken into account when defining the sensitivity/ vulnerability/ importance of the resource/receptor, which may be physical, biological, cultural or human. Other factors were also considered when characterising sensitivity/ vulnerability/importance, such as legal protection, government policy, stakeholder views and economic value. The sensitivity/ vulnerability/importance designations used herein for all resources/receptors are: Low Medium High Once magnitude of impact and sensitivity/ vulnerability/ importance of resource/ receptor have been characterised, the significance was assigned for each impact as below: Negligible: An impact of negligible significance is one where a resource/ receptor (including people) will essentially not be affected in any way by a particular activity or the predicted effect is Minor: An impact of minor significance is one where a resource/ receptor will experience a noticeable effect, but the impact magnitude is sufficiently small and/or the resource/receptor is of low sensitivity/ vulnerability/ importance. In either case, the magnitude should be well within applicable standards/ guidelines. Moderate: An impact of moderate significance has an impact magnitude that is within applicable standards/guidelines, but falls somewhere in the range from a threshold below which the impact is minor, up to a level that might be just short of breaching a legal limit. Clearly, to design an activity so that its effects only just avoid breaking a law and/or cause a major impact is not best practice. The emphasis for moderate impacts is therefore on demonstrating that the impact has been reduced to a level that is as low as reasonably practicable (ALARP). This does not necessarily mean that impacts of moderate significance have to be reduced to minor, but that moderate impacts are being managed effectively and efficiently. Major: An impact of major significance is one where an accepted limit or standard may be exceeded, or large magnitude impacts occur to medium valued/sensitive resource/receptors or www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 147 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report medium magnitude impacts occurs to highly valued/sensitive resource/receptors. An aim of IA is to get to a position where the Project does not have any major residual impacts, certainly not ones that would endure into the long-term or extend over a large area. However, for some aspects there may be major residual impacts after all practicable mitigation options have been exhausted (i.e. ALARP has been applied). An example might be the visual impact of a facility. It is then the function of regulators and stakeholders to weigh such negative factors against the positive ones, such as employment, in coming to a decision on the Project. Critical: An impact of critical significance is one where an accepted limit or standard may be exceeded, or large magnitude impacts occur to highly valued/sensitive resource/receptors. However, for some aspects there may be critical residual impacts after all practicable mitigation options have been exhausted (i.e. ALARP has been applied), which needs to be offset. Figure 6.2 Impact Significance Matrix Receptor Sensitivity Impact Magnitude Negligible Small Medium Large Low Negligible Negligible Minor Moderate Medium Negligible Minor Moderate Major High Negligible Moderate Major Critical It is important to note that impact prediction and evaluation takes into account any embedded controls (i.e., physical or procedural controls that are already planned as part of the Project design, regardless of the results of the IA Process). 6.1.5 Identification of Mitigation and Enhancement Measures Once the significance of an impact has been characterised, the next step was to evaluate what mitigation and enhancement measures are warranted. For the purposes of this IA, ERM adopted the following Mitigation Hierarchy: Avoid at Source, Reduce at Source: avoiding or reducing at source through the design of the Project. Abate on Site: add something to the design to abate the impact. Abate at Receptor: if an impact cannot be abated on-site then control measures can be implemented off-site. Repair or Remedy: some impacts involve unavoidable damage to a resource (e.g. agricultural land and forestry due to creating access, work camps or materials storage areas) and these impacts can be addressed through repair, restoration or reinstatement measures. Compensate in Kind, Compensate Through Other Means: where other mitigation approaches are not possible or fully effective, then compensation for loss, damage and disturbance might be appropriate (e.g., planting to replace damaged vegetation, financial compensation for damaged crops or providing community facilities for loss of fisheries, access, recreation and amenity space). The priority in mitigation was to first apply mitigation measures to the source of the impact (i.e., to avoid or reduce the magnitude of the impact from the associated Project activity), and then to address the resultant effect to the resource/receptor via abatement or compensatory measures or offsets (i.e., to reduce the significance of the effect once all reasonably practicable mitigations have been applied to reduce the impact magnitude). www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 148 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report 6.1.6 Preparation of Environmental and Social Management Plan The final stage in the IA Process is the definition of the basic management and monitoring measures that are needed to identify whether: a) impacts or their associated Project components remain in conformance with applicable standards/ guidelines; and b) mitigation measures are effectively addressing impacts and compensatory measures and offsets are reducing effects to the extent predicted. The mitigation measures recommended in individual impact assessments were compiled for project construction and operation phases. The ESMP prepared has also taken organization structure of RUMS and context of the project (sectoral, regional, and socio-cultural external environment) to determine practical and effective mitigation measures. 6.2 Impacts on Physical Environment The proposed Project site is located in a rural setup with no major industrial/ anthropogenic activities. This section outlines the potential impacts on the physical environment due to project activities planned during different phases of the Project lifecycle. 6.2.1 Assessment Criteria ERM has defined impact assessment standards based on internal parameters that identifies the significance value of the impacts as a matrix between resource/receptor sensitivity or vulnerability and impact magnitude. The internal impact assessment standards for impacts on physical environment has been provided in Table 6.6 and Table 6.7 below. Once magnitude of impact and sensitivity/ vulnerability/ importance of resource/ receptor have been characterised, the significance was assigned for each impact. Impact significance is designated using the matrix shown in Figure 6.2. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 149 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Table 6.6 Criteria for Resource/ Receptor Sensitivity or Vulnerability Environmental Sub criteria Low Medium High Attributes Land use and Land Land use not of relevant use Land use of local use by communities e.g. Land use of regional importance. by Community grazing, agriculture, but no major Change would impact Land use cover Negligible visual change. dependence classification of the area. Visual Change but common feature Land use of major dependence of local people for agriculture, livestock grazing, settlement etc. Visual Change aesthetically affecting locals. Soil Environment Environment The soil quality does not The soil quality supports diverse habitat or The soil quality supports The extent to which the soil and its support diverse habitat or population of flora and fauna and supports economically important or quality plays an ecosystem role in populations and/or supports habitats commonly available in the study area biologically unique species or terms of supporting biodiversity. This habitat or population of low provides essential habitat for such includes its role as in supporting a quality species lifecycle stage Social The soil quality has little or The soil has local importance in terms of The soil is wholly relied upon The extent to which the soil and its no role in provisioning of provisioning services as agricultural services locally, with no suitable technically quality provides a use (agricultural services as agricultural uses but there is ample capacity and / or adequate or economically feasible use) to the local communities and for the local community. opportunity for alternative sources of alternatives, or is important at a businesses, or is important in terms comparable quality i.e. ready availability regional level for provisioning of national resource protection across the study area. services. objectives, targets and legislation Topography Flat topography Undulating topography Hilly area Water Resources - Environment The water resource does not The water resource supports diverse The water resource supports Surface water and The extent to which the water support diverse aquatic populations of flora and / or fauna but economically important or ground water resource plays an ecosystem or habitat or populations, or available in the surface water bodies in the biologically unique aquatic species (quality/quantity) amenity role in terms of supporting supports aquatic habitat or region or provides essential habitat for biodiversity either directly or population that is of low such species indirectly, particularly with respect to quality. dependent ecosystems. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 150 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Environmental Sub criteria Low Medium High Attributes Social The water resource has The surface water resources have local The surface water resources The extent to which the water little or no role in terms importance in terms of provisioning are wholly relied upon locally, of provisioning services services but there is ample capacity and with no suitable technically or resource provides or could provide a as agricultural water / or adequate opportunity for alternative economically feasible use (drinking water, agricultural uses, source, other domestic sources of comparable quality. alternatives, or is important at washing and other domestic or uses as washing, The groundwater resource is an a regional or transboundary industrial, use as waterways) to the bathing, industrial use important water supply, and is currently watershed level for local communities and businesses, or and waterways for the used, but there is capacity and / or provisioning services. is important in terms of national local community. adequate opportunity for alternative The groundwater resource is resource protection objectives, The groundwater sources of comparable quality. wholly relied upon locally, with resource is not currently The ground water block is categorized as no suitable technically or targets and legislation abstracted and used in economically feasible the vicinity of the alternatives, or is important at Project, but is of a regional or national level for sufficient quality and water supply or contribution to yield to be used for that groundwater dependent purpose in the future ecosystems (e.g. (and there is a transboundary rivers). reasonable potential for The ground water block is future use). The ground water block CGWB. by CGWB Ambient Air Quality Human Receptor Locations where human Few Receptors (settlements) within 500 m of Densely populated exposure is transient.1 the Project site receptors(settlements) within 500 m of Project site Ecological Receptor Locally designated sites; Nationally designated sites. Internationally designated sites. and/or areas of specific ecological interest, not subject to statutory protection. Ambient Noise Human Receptor Industrial area Residential and Recreational place Educational/ Religious/ Medical Quality Facilities 1 As per the NAAQS and World Bank/IFC guidelines, there are no standards that apply to short term exposure, e.g., one or two hours, but there is still a risk of health impacts, albeit less certain. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 151 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Environmental Sub criteria Low Medium High Attributes Ecological Receptor Locally designated sites; Nationally designated sites. Internationally designated sites. and/or areas of specific ecological interest, not subject to statutory protection (for example, as defined by the Project ecology team). Table 6.7 Criteria for Impact Magnitude Magnitude Criteria Negligible Small Medium Large Land use and Land An imperceptible, barely Subtle changes in land use A noticeable change in land use A clearly evident, frequently cover or rarely perceptible character over a wide area of character, frequently perceived or perceived and continuous change change in land use a more noticeable change continuous and over a wide area; or a in land use characteristics characteristics. The either over a restricted area clearly evident change over a affecting an extensive area. The change may be short or infrequently perceived. restricted area that may be change may be long term and term. The change may be short infrequently perceived. The change would not be reversible term to long term and is may be medium to long term and may reversible. not be reversible Soil compaction Qualitative-No perceptible Perceptible change from Clearly evident (e.g. perceptible and Major (e.g. order of magnitude) and erosion or readily measurable baseline conditions but likely readily measurable) change from change in comparison to baseline change from baseline to easily revert back to baseline conditions and/or likely take conditions and/or likely difficult or conditions earlier stage with mitigation time to revert back to earlier stage may not to revert back to earlier Scale-Localized area as Scale- -Project site, activity with mitigation stage with mitigation Particular activity areas areas and immediate vicinity Scale- Project site, activity areas and Scale- Regional or international; Time-Short duration (few not impacting any sensitive immediate vicinity impacting sensitive Permanent change days) or one time as receptor receptor/s temporary Short term-Only during Long term-Spread across several particular activities or phase phases of the Project lifecycle (few of the Project lifecycle as civil years) works or construction phase (few months) www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 152 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Magnitude Criteria Negligible Small Medium Large Soil contamination Well within Dutch Well within Dutch standard Exceeds Target Value but well within Exceeds Interventional Value and standard1 Interventional Value needs intervention. Topography An imperceptible, barely A subtle change in A noticeable change in topographic A clearly evident, frequently or rarely perceptible topography character over a character, frequently perceived or perceived and continuous change change in topographical wide area or a more continuous and over a wide area; or a in topographic characteristics characteristics. The noticeable change either clearly evident change over a affecting an extensive area. The change may be short over a restricted area or restricted area that may be change may be long term and term infrequently perceived. infrequently perceived. The change would not be reversible. The change may be short may be medium to long term and may term to long term and is not be reversible. reversible. Water Resources - There is likely to be The Project will consume The Project will consume surface The Project will consume surface Surface water and negligible (less than 1% surface water, but the water, and the amounts abstracted are water, and the amounts ground water of lean season flow) or no amounts abstracted are likely likely to be significant in comparison to abstracted are likely to be very (quantity/availability consumption of surface to be relatively small in the resource available at the time of significant in comparison to the ) water by the Project at comparison to the resource use (i.e. taking into account seasonal resource available at the time of any time. available at the time of use fluctuation) use (i.e. taking into account There is likely to be (i.e. taking into account The Project will consume seasonal fluctuation) negligible or no seasonal fluctuation) groundwater or discharge to abstraction, use of or The Project will consume groundwater, and the amounts The Project will consume discharge to the groundwater or deliver abstracted / discharged are likely to groundwater or discharge to groundwater by the discharge to groundwater, be significant in comparison to the groundwater, and the amounts Project at any time. but the amounts abstracted / resource available at the time of use abstracted / discharged are likely discharged are likely to be (i.e. taking into account seasonal to be very significant in relatively small in fluctuation). comparison to the resource comparison to the resource available at the time of use (i.e. available at the time of use taking into account seasonal fluctuation). 1 Dutch Target and Intervention Values (Soil remediation Circular 2009-2012 Revision), https://zoek.officielebekendmakingen.nl/stcrt-2012-6563.pdf. The assessment of potential impacts to soil and sediment has been considered as per the Dutch Standard as Bangladesh does not have any local standards for soil or sediment quality. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 153 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Magnitude Criteria Negligible Small Medium Large (i.e. taking into account seasonal fluctuation). Water Quality Discharges are expected Discharges are expected to Occasional breach(es) of statutory Repeated breaches of statutory to be well within statutory be within statutory limits. discharge limits (limited periods) discharge limits (over extended limits Groundwater quality be expected. periods) expected. Abstractions from or within ambient levels or Groundwater quality exceeds discharge to aquifer(s) allowable criteria or may Groundwater quality exceeds ambient ambient levels or allowable are unlikely to cause exceed for 1-2 parameters levels or allowable criteria for key criteria. water quality issues which is common occurrence parameters. due to geological regime of Abstractions or discharge to the area. Abstraction or discharge to aquifer(s) aquifer(s) are expected to cause are expected to cause potential potentially severe effects on Abstraction or discharge to localized effects on groundwater groundwater quality which are aquifer(s) may cause small quality which are likely to be fairly long likely to be long-lasting (e.g. years but local changes in water lasting and / or give rise to indirect or permanent) and / or give rise to quality in the aquifer system. ecological and / or socio-economic indirect ecological and / or socio- These can be considered impacts economic impacts. potential short-term localized effects on groundwater quality which is likely to return to equilibrium conditions within a short (months) timeframe. Ambient Air Quality Soil type with large grain Soil type with large grain size Moderately dusty soil type (e.g. silt); Potentially dusty soil type (e.g. size (e.g. sand); and/or (e.g. sand); and/or and/or clay, which will be prone to No emissions/dust suspension when dry due to small generation due to Project Limited emissions/dust Dust generation and emissions from particle size); and across all phases. generations for short Projects for long duration Existing ambient air duration Significant process emissions quality of the area is well Existing ambient air quality of the area from Project for the entire Project below the Prescribed Existing ambient air quality of is within the Prescribed NAAQ limits cycle. NAAQ limits the area is well below the but with only deferential of 10- 20 Prescribed NAAQ limits. microgm/m3 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 154 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Magnitude Criteria Negligible Small Medium Large Existing ambient air quality of the area is exceeding the Prescribed NAAQ limits. Ambient Noise Predicted noise levels are Predicted noise levels are 3 Predicted noise levels are between 5 Predicted noise levels are more Quality at or less than 3 dB (A) to less than 5 dB (A) above and 10 dB (A) above the relevant than 10 dB (A) above the relevant above the relevant limits / the relevant limits / limits / thresholds. limits / thresholds. thresholds. thresholds Medium Term Exposure (1 to 6 Long term exposure (> 6 months) Short term exposure months) (Few hours in a day and not continuous) www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 155 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report 6.2.2 Planning and Construction Phase 6.2.2.1 Impact on land use and land cover For the purpose of assessment of impacts on land use of the area, following Project activities leading to an alteration in land use of the area during construction phase were considered: Construction/ upgradation of access roads (internal); Establishment and operation of temporary structures such as temporary site office (portable cabin) and store yard; Vehicular movement; Establishment of PV modules and associated transformer yard; and Construction of Central Monitoring Station, Switching Yard. Context and Receptor Sensitivity The proposed Project site is located in a rural setup with no major industrial/ anthropogenic activities. The current land use of the proposed project is mostly scrub land, used for grazing with parcels of agricultural land, some of which are a result of encroachment. In the pre-construction phase, permanent change will occur to the land use (grazing and agriculture) where the project boundary will be established, to prepare for the next phases (construction and operations). In the construction phase, temporary land use changes will occur at contractor facilities and labour camps, material storage areas and there will be a long term change of the land use within the land parcels where the Solar Park and pooling substation will be located. Receptor sensitivity is envisaged to be medium considering the land use will change to industrial. It is understood that some avoidance of agricultural areas will be achieved but other areas will need the land use to be changed. All remaining scrub, currently available for grazing will be converted within the project boundary, affecting the dependence of the community on this area, though, it is understood, that some land for grazing will be set aside. . Embedded/In-built Controls Construction activities will be restricted to within the acquired land and immediate surroundings only. Post construction activities, any land taken for a temporary basis for storage of material would be restored to their extent possible as acceptable to land owners to minimise impacts to land use. Existing roads will be used to the extent possible. Impact Magnitude The establishment of the Solar Park will convert scrub land and agricultural land to industrial use for the long term (at least 25 years). The total land area of 1065.7 ha will undergo land use change, out of which 968.838 Ha is government land. Short term changes in land use are also envisaged from the establishment of the associated facilities such as storage yard, site offices, labour camp and switch yard. However, the impact on land use will only be within the Project boundary and will not affect any of the neighbouring areas. Furthermore, the changes to land use will be reversible. Thus, magnitude of the impact has been assessed to be medium. Impacts on land use during construction phase due to establishment of temporary facilities like labour camp, storage area, will be for a shorter period of time. Impact Significance As per the impact significant assessment matrix (refer Figure 6.2) a combination of medium impact magnitude with medium receptor sensitivity results in impact significance as moderate. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 156 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Additional Mitigation Measures Construction activities should be restricted to designated area; On completion of construction activities, land used for temporary facilities such as Contractor office, batching plant (if any), stockyard, labour camp should be restored to the extent possible; The land use around permanent Project facilities should not be disturbed; and The land should be restored back to the original state to the extent possible after completion of life cycle of the Project and in case there are plans not to continue further at the site. Residual Impact Significance The residual impact significance is envisaged to remain moderate as changes in land use will be for long term for majority of the Project component (installation of PV modules, access roads, central monitoring station, and switching yard). Impact Changes in Land use and land cover Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale Limited to Project site and associated facilities Impact Magnitude Positive Negligible Small Medium Large Resource /Receptor Low Medium High Sensitivity Negligible Minor Moderate Major Impact Significance Significance of impact is considered moderate Residual Impact Positive Negligible Small Medium Large Magnitude Residual Impact Negligible Minor Moderate Major Significance Significance of impact is considered moderate 6.2.2.2 Soil Environment Following Project activities during construction phase are envisaged that may impact the soil environment: Construction/strengthening of access roads; Vegetation clearance and top soil removal; Storage of oil and lubricants onsite; Storage of construction materials; and Disposal of different type of waste generated during construction activities, from the temporary site office and labour camp. The Project site has agricultural land, scrub land and barren land. The uncultivated land parcels with rocky strata were also observed during site visit. As reported during consultation with local www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 157 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report community, it takes huge cost, time and efforts to undertake agriculture activity on the land parcels with rocky strata. In addition, there are agricultural land parcels in the surroundings of the Project site. Village Bardawada towards south-west, Banediya towards south and agricultural land towards east adjacent to Unit 1. Unit 2 also has few agricultural fields just adjacent to the boundary towards west and south- east. Unit 3 has agricultural fields just adjacent to the boundary towards north. Village Badi is present adjacent to Unit 2 towards west. The site clearance activities, excavation and levelling of ground will cause disturbance of the soil strata and impact on soil quality. The Project will also undertakes the soil compaction activity to ensure soil stability during the site levelling at site. Hence, the receptor sensitivity has been assessed as medium. Soil Erosion and Compaction The project will undertake the soil compaction activity to ensure soil stability during the establishment of storage areas, labour camp, access road, installation of batching plant, establishment of substation, SCADA building etc. During construction activities, there would be compaction of soil in the Project area during movement of vehicles/ construction machinery and work force movement. In addition, laying of electrical wires in the agricultural field during erection of internal electrical lines will also lead to the compaction of agricultural soil to certain extent. Embedded/In-built Controls Vehicles will utilize existing roads to access the site. Existing roads will be widened/ strengthened to have the width and turning radius to accommodate the necessary vehicles for the Project. Impact Magnitude The site clearance, excavation, drilling for foundation and access road construction will largely affect the top layers of the soil. Compaction of soil during excavation, transportation of construction material & project components, foundation work, backfilling, erection of structures will lead to temporary effects on natural infiltration of rainwater, but these impacts were temporary and for short term. Further, site clearance will be restricted only in the Project site. Land close to the Project site will not be disturbed. Vehicles will be encouraged to utilize the existing roads with minor strengthening. The usage of existing roads by vehicles and minimal access road construction will reduce the impact from soil compaction in the area. Based on the above, the Impact Magnitude has been assessed to be small. Impact Significance As per the impact significant assessment matrix (refer Figure 6.2) a combination of small impact magnitude with medium receptor sensitivity results in impact significance as minor. Additional Mitigation Measures The topsoil present in the construction shall be removed and stock pilled in separate area; The stock pile should be protected from natural elements to prevent from erosion and also degradation; Topsoil to be reused on site for landscaping purpose; Defined routes for transportation and construction vehicles, workers etc. to minimize soil compaction; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 158 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Good drainage as per the natural slope condition should be provided to reduce surface runoff and associated erosion; Back filling and revegetation of the area disturbed will be undertaken phase wise immediately after the completion; and Site clearance, piling, excavation and access road construction will not be carried out during the monsoon season to minimize erosion and run-off. Residual Impact Significance The significance of residual impacts will lower down to negligible taking into account the recommended mitigation measures. Impact Soil Erosion and Compaction Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale Limited to Project areas Impact Magnitude Positive Negligible Small Medium Large Resource/ Receptor Low Medium High Sensitivity Negligible Minor Moderate Major Impact Significance Significance of impact is considered Minor. Residual Impact Positive Negligible Small Medium Large Magnitude Residual Impact Negligible Minor Moderate Major Significance Significance of impact is considered Negligible. Waste Generation and Soil Contamination due to leaks and Spills General construction waste generated onsite will comprise of concrete, steel cuttings/filings, packaging materials or plastic. Municipal solid wastes consisting of food waste, plastic, glass and waste paper will also be generated by the construction workforce at canteen facility/ labour camp. A small proportion of the waste generated during construction phase will be hazardous and will include waste fuel, grease, broken modules, paints, chemicals and waste oil containing rags. If improperly managed, solid waste could create impacts on soil quality. Embedded/In-built Control Spill control measures such as the storage and handling of chemicals and fuel in concrete areas with secondary containment will be implemented to minimize impacts in the event of a spill; The EPC contractors will have control over the amount and types of waste (hazardous and non- hazardous) produced at the site; The hazardous wastes to be stored onsite temporarily at separate designated covered area provided with impervious flooring and secondary containment and to be disposed in accordance with Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016; and www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 159 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Workers will be strictly instructed/ trained about random disposal of any waste generated from the construction activity. Impact Magnitude The construction contractors will have control over the amount and types of waste (hazardous and non- hazardous) produced at the site. The municipal waste from the labour camp will only be routed through proper collection and handover to local municipal body for further disposal. The hazardous wastes will be temporarily stored in labelled drums on impervious surface at designated area onsite and will be disposed off through approved vendors in accordance to Hazardous Wastes Rules, 2016The impact magnitude has therefore been assessed as small. Impact Significance As per the impact significant assessment matrix (refer Figure 6.2) a combination of small impact magnitude with medium receptor sensitivity results in impact significance as minor. Additional Mitigation Measures Construction and Demolition Waste should be stored separately and disposed through approved facility/landfill; All waste should be stored in a shed that is protected from the elements (wind, rain, storms, etc.) and away from natural drainage channels; A log book should be maintained for quantity and type of hazardous waste generated; Designated areas should be provided for Solid Municipal Waste and daily collection and period disposal should be ensured; EPC Contractor should ensure that no unauthorized dumping of used oil and other hazardous waste is undertaken at the site; Hazardous waste to be disposed through MPPCB authorised vendors; In case of accidental/unintended spillage, the contaminated soil should be immediately collected and stored as hazardous waste; The guidelines and procedures shall be prepared and followed for immediate clean-up actions following any spillages; Damaged/ discarded solar panels to be disposed with the help of authorised recycling vendors/ module installation contractors/ supplier; and Other wastes such as e-waste, used discarded batteries shall be disposed off in accordance to E- waste rules and batteries management and handling rules. Residual Impact Significance The significance of impacts due to waste generation after implementation of mitigation measures has been considered as minor. Impact on soil environment due to waste generation (hazardous and non- Impact hazardous) Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale Limited to Project area www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 160 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Frequency Occasionally Impact Magnitude Positive Negligible Small Medium Large Resource/Receptor Low Medium High Sensitivity Negligible Minor Moderate Major Impact Significance Significance of impact is considered minor. Residual Impact Positive Negligible Small Medium Major Magnitude Residual Impact Negligible Minor Moderate Major Significance Significance of impact is considered minor. 6.2.2.3 Impact on Topography and Drainage Context and Receptor Sensitivity The proposed Project site mainly exhibits flat topography. The topographic elevation at the Site was observed in the range of 396- to be~ 25 m/km. Slope in general, was observed to be ranging from very gentle to gentle category and there is no high gradient area (slope >7 o) within the Project area. The study area have small seasonal water streams which finally discharge into Brahmani River running in the South of the Project site. A natural seasonal water channel delineates the border between Kawai and Badi Villages. The canal was dry during the site visit despite the assessment being immediately after the monsoon season. The water channel may pass through Unit 2 and/or Unit 3 after the Solar Park is constructed. The study area also have two large water bodies- water body near Unit 3 in East and Bardawada pond in South of Unit 1 which receives runoff from site. Any changes to topography in the area will advertently impact the drainage channels and might result in water logging in adjoining areas of the project site. Being a fairly flat land with gentle slope on site and water channels passing between Units, the receptor sensitivity has been assessed to be medium. Embedded/In-built Control Design of the Solar Park will follow the natural topography, efforts will be taken to make limited change the topography. Project designing shall be done in a way to utilize existing topography to maximum; Impact Magnitude There will be a very limited change in the topographic character of the area within the project footprint. This change will long term and may not be reversible. The alteration in surface drainage pattern of the area due to construction activities will be limited to smaller areas located in project footprint. The natural flow of storm water will not be altered on contiguous larger area. Further, care will be taken to maintain the natural drainage in the area so that rain water can take its path without any restriction by the constructions at site. Hence impact magnitude is assessed to be small. Impact Significance As per the impact significant assessment matrix (refer Figure 6.2) a combination of small impact magnitude with low receptor sensitivity results in impact significance as minor. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 161 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Additional Mitigation Measures Project shall ensure to avoid any unnecessary changes in the topography especially during the preconstruction and construction phase; Micro drainage channel should be particularly avoided when constructing access roads or planning the Transmission Line pathway in order to ensure no change to the topography of the area; Storm water drains must be designed in line with the natural topography and eventually drain into the natural seasonal streams in the Site area .Significance of Residual Impacts The residual impact significance will be minor after implementing above mentioned mitigation measures. Impact Change in topography and drainage Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale Limited to Project site and access road Impact Magnitude Positive Negligible Small Medium Large Resource/ Receptor Low Medium High Sensitivity Negligible Minor Moderate Major Impact Significance Significance of impact is considered Minor. Residual Impact Positive Negligible Small Medium Large Magnitude Residual Impact Negligible Minor Moderate Major Significance Significance of impact is considered Minor 6.2.2.4 Water Resources and Availability Context and Resource Sensitivity During construction phase, water will be primarily required for foundation works for installing solar panels, electrical installations at PSS at Solar Park. Besides this, civil construction activities such as construction of control room, security guard room, utilities, labour camp will also have water requirement. As detailed in the baseline section (Section 4.2.10), the overall water resource sensitivity was evaluated as High based groundwater and surface water risk. Groundwater risk was estimated based on Block Categorization and Hydrogeology while surface water risk was estimated based on Inter Annual Variability, Seasonal Variability, Availability Index and Total Annual Rainfall. Baseline Water Stress and Baseline Water Depletion were evaluated as risk factors common to both groundwater and surface water risk. For the site, total water risk was evaluated based BWS and BWD while groundwater and surface water risks were evaluated based on the aforementioned individual factors. High resources, high risk from BC and high risk based on stakeholder consultations. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 162 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Surface Water resource sensiti High and TAR. Embedded/in-built control Nil Impact Magnitude Approximate 250 - 300 KLD of water would be required for civil works and 80- 100 KLD domestic water will be required during peak construction stage. The water requirement will be met through tanker water supply. The construction phase will be of duration of 21 months with peak construction period of 6-8 months. Hence, the magnitude of impact is assessed as medium. Impact Significance As per the impact significant assessment matrix (refer Figure 6.2) a combination of small impact magnitude with high receptor sensitivity results in impact significance as major. Additional Mitigation Measures Following mitigation measures are proposed for conservation of water resources of the area: No ground water abstraction for construction phase; Tanker water supply shall be only through authorized sources; Construction labour deputed onsite to be sensitised about water conservation and encouraged for optimal use of water; Regular inspection for identification of water leakages and preventing wastage of is necessary for efficient utilisation of water; As part of project designing, SPD shall consider the rainwater harvesting ponds in the open area depending on the topography, slope, natural drainage etc. Accordingly infrastructure such as drains/ piping system/ size of pond etc. shall be designed. Similarly, in case water is sourced from surface water bodies, infrastructure requirements shall be identified and planned in project design. (Refer Appendix F for Water Management Plan and section 6.2.3.2 for details) Residual Impact Significance After implementation of mitigation measures, the significance of residual impacts for construction activities will be major to moderate Impact Water resources Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale Limited to Project areas Impact Magnitude Positive Negligible Small Medium Large Resource/Receptor Low Medium High Sensitivity Impact Significance Negligible Minor Moderate Major www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 163 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Significance of impact is considered major. Residual Impact Positive Negligible Small Medium Major Magnitude Residual Impact Negligible Minor Moderate Major Significance Significance of impact is considered major to moderate 6.2.2.5 Water Quality Context and Receptor Sensitivity Major source of wastewater generation during construction phase is labour camp, site office to be established for Solar Park. Approximately 54 KLD of sewage will be generated during construction activities. There is a potential for contamination of surface and groundwater resources resulting from improper management of sewage. The Project footprint does not have any water body, whereas, Area of Influence has few large water bodies receiving storm water in the area. Kawai Lake and Arnya Lake are present at a distance of ~ 700 m from unit 2 (west), and ~ 3 km (north-west of Unit 1) respectively. There is a water body near Unit 3 in the East- South East and Bardawada pond is present in the South of Unit 1. The quality of water in the nearby water bodies could be affected due to surface runoff from contaminated soil (soil contamination due to oil/ fuel spillage and leakages) especially during monsoon season. The surface runoff carrying the loose top soil will lead to increased sedimentation in the receiving water bodies. Based on the topographical conditions, the general surface water flow direction in the Project area is anticipated from North to South. Hence, Bardawada pond and water body near Unit 3 may receive surface runoff from the site. The water of these water bodies is used by local villagers for washing, cleaning and irrigation purposes. Hence, receptor sensitivity is assessed as medium. Embedded/ in-built control Provision of septic tank and soak pits onsite and in labour camps and at site office for treatment and disposal of sewage, thereby minimizing the impacts of wastewater discharge. Impact Magnitude There is no surface water body located within the project foot print area which could get direct impact due to construction activities. As part of the site preparation stage, a drainage and sewerage system will be constructed for the site office and labour camp. The sewerage system will consist of soak pits for the collection of wastewater from the kitchen and washing areas and Office facility. Sewage from the toilets will be discharged into lined septic tanks. Further, there is no direct discharge of wastewater in the ground water aquifer of the area. However, ground water quality of the area may get indirectly impacted due to soil contamination. Hence magnitude of impact is assessed as small. Impact Significance As per the impact significant assessment matrix (refer Figure 6.2) a combination of small impact magnitude with medium receptor sensitivity results in impact significance as minor. Additional Mitigation Measures Ensure proper cover and stacking of loose construction material at site to prevent surface runoff and contamination of receiving water body; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 164 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Open defecation and random disposal of sewage will be strictly restricted; Planning of toilets, soak pits and septic tanks, waste collection areas away from natural drainage channels; Provision of number of toilets across with easily accessible location as the project site is spread across large area of 3 units; Use of licensed contractors for management and disposal of waste and sludge; Labourers will be given training towards proactive use of designated areas/bins for waste disposal and encouraged for use of toilets; Provision for impervious storage area, especially for fuel & lubricant, hazardous waste, etc. will be made onsite; and Spill/ leakage clearance plan to be adopted for immediate cleaning of spills and leakages. Residual Impact Significance Residual significance of impacts during construction phase will be minor. Impact Water Quality Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale Limited to Project area Frequency Both Construction and Operation Phase Likelihood Likely Impact Magnitude Positive Negligible Small Medium Large Resource Sensitivity Low Medium High Negligible Minor Moderate Major Impact Significance Significance of impact is considered minor Residual Impact Positive Negligible Small Medium Large Magnitude Residual Impact Negligible Minor Moderate Major Significance Significance of impact is considered minor 6.2.2.6 Ambient Air Quality Context and Receptor Sensitivity Ambient Air quality impacts in the construction phase will be largely due to the following sources: Fugitive dust emissions from site clearance, piling work, handling of construction materials, emission due to movement of vehicles on unpaved roads, plying of vehicles, etc. Vehicular emissions due to increased traffic movement on site and on the approach roads; Exhaust emissions from construction machinery and other equipment such as batching plant, if any; and Emissions from diesel generators required to be run for construction power purposes www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 165 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report The proposed Project site is located in a rural setup. The human receptors for dust emissions are located between Unit 2 and 3, i.e. Badi village and ~ 450 m towards East from Unit 1 (Kawai village). There are no ecologically protected areas in vicinity of the site. The receptor sensitivity is assessed as medium. Embedded/in-built control Suppression of fugitive dust emissions by spraying water, wetting of the stockpile; Pre-identified proper locations of material stockpiles, especially sand; and Screening or providing wind breaks for stockpiles, covering of trucks with tarpaulin sheets during transportation of material. Impact Magnitude The major source of emissions in the construction phase is the fugitive dust emissions from construction activities. In addition, operation of DG sets will also cause gaseous emissions. There will be some impacts due to plying of vehicles on the access roads which runs across settlement area. The ambient air quality analysis reveals that the air shed is unpolluted and the air pollutants- PM (PM10 and PM2.5), SO2, NOx and CO are well below the prescribed CPCB and WHO guidelines. The construction activities will occur for a period of time (~21 months) whereas dust emitting activities such as site clearing, civil construction etc. will be of short duration. The impact magnitude has been categorized as small because the soil type is loamy sand and dust emission will be limited to construction phase only for shorter duration. Impact Significance As per the impact significant assessment matrix (refer Figure 6.2) a combination of small impact magnitude with medium receptor sensitivity results in impact significance as minor. Additional Mitigation Measures The construction site shall be barricaded; Keeping areas of open excavation to a minimum; Minimising stockpiling by coordinating excavations, spreading, re-grading, compaction activities; Cease or phase down work if excess fugitive dust is observed, investigate source and take suppression measures; Speed of vehicles on site to be limited to 10-15 km/hr; The emissions from diesel generator shall be by optimised operations, orientation at the site and providing adequate stack height for wider dispersion of gaseous emissions Switch off machinery and equipment when not in use; Prevent idling of vehicles and equipment; and Vehicle engines will be properly maintained and will have a valid Pollution under Control (PUC) to ensure minimization in vehicular emissions. Residual Impact Significance The significance of residual impact will be minor to negligible after implementing mitigation measures. Impact Ambient Air quality Construction phase www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 166 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale Project area and vicinity Impact Magnitude Positive Negligible Small Medium Large Resource Sensitivity Low Medium High Negligible Minor Moderate Major Impact Significance Significance of impact is considered Minor. Residual Impact Positive Negligible Small Medium Major Magnitude Residual Impact Negligible Minor Moderate Major Significance Significance of impact is considered Minor to Negligible. 6.2.2.7 Ambient Noise Quality Context and Receptor Sensitivity The sources of noise in the construction phase include construction activities, operation of , drilling, D.G. sets and movement of vehicles. The construction machinery used for the construction activities could be the major sources of noise at site whereas increased noise levels are also envisaged as a result of increased material movement in the area. It is to be noted that the proposed project site has habitats in close proximity. Village within 500 m of the project site and access road includes Badi, Kawai and Bardawada which may get impacted due to high noise levels during construction activities and project related vehicular movement through village roads, especially fence line community. Therefore receptor sensitivity is considered as medium. Embedded/in-built control Normal working hours of the contractor will be defined (preferable 8 am to 6pm). If work needs to be undertaken outside these hours, it would be limited to activities which do not generate noise; and Avoid unnecessary honking. Impact Magnitude The operation of construction machinery, DG set will generate noise. Construction works are expected to last for 21 months and construction activities will be limited to daytime only. The increase in traffic volumes during construction activities will also increase noise levels in the area. The baseline noise monitoring results reveals that the equivalent ambient noise level for day time (Leq day) and night time (Leq night) at Badi and Kawai villages was within the corresponding prescribed limits of CPCB and WHO for residential area. Hence, the magnitude of impact on ambient noise levels is assessed as medium considering the construction period of the project to last for approximately 21 months and proximity to the villages and the construction activities may lead to exceedance of prescribed noise day time limits at receptors. Impact Significance The impact significance has therefore been assessed as moderate. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 167 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Additional Mitigation Measures Ensure safe distance of project related activities from schools, hospitals, etc.; Only well-maintained equipment to be operated on-site; If it is noticed that any particular equipment is generating too much noise then lubricating moving parts, tightening loose parts and replacing worn out components to be carried out to bring down the noise. It is to be ensured that such machinery are kept far away from the households; Machinery and construction equipment that may be in intermittent use to be shut down or throttled down during non-work periods; Low noise equipment shall be used as far as practicable; The number of equipment operating simultaneously shall be reduced as far as practicable; Install enclosures around construction area, in order to reduce the extent of noise emanating due to project related activities; DG set with acoustic enclosures shall be used; Vehicular movement through village roads should be planned to avoid traffic jam and inconvenience to local residents; Equipment noise should be 85 dB (A) at 1 m from the source in line with WB/IFC EHS guidelines; Minimal use of vehicle horns needs to be encouraged; Limit construction related activities to day time in order to restrict the noise related nuisance in the evenings, where permissible noise threshold is lesser; Provision of Grievance Redressal Mechanism to all the key stakeholders in order to raise and register their grievances pertinent to noise and dust related issues. Residual Impact Significance Significance of residual impact is assessed to be minor taking into consideration above mentioned mitigation measures. Impact Ambient Noise Quality Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale Project area and vicinity Impact Magnitude Positive Negligible Small Medium Large Resource Sensitivity Low Medium High Negligible Minor Moderate Major Impact Significance Significance of impact is considered to be Moderate. Residual Impact Positive Negligible Small Medium Major Magnitude Residual Impact Negligible Minor Moderate Major Significance Significance of impact is considered Minor www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 168 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report 6.2.2.8 Occupational Health and Safety Context and Receptor Sensitivity The proposed Project will involve several higher risk activities as shown below: Construction of support structure for PV module would require operation of pile drivers. The installation of solar module will involve operation of cranes and other mechanical lifting equipment. Laying of interconnecting cable with require digging. The commissioning of the inverter rooms and Transmission Line will also involve live power lines. Working on live wires carrying power has dangers of electric shock and electrocution. Construction and commissioning of PSS and associated structures will involve multiple hazards i.e., working at height, use of cranes and mechanical lifting equipment, working with high voltage power; Besides this, there could be slip and trip hazards especially during monsoon season; and The area experiences extreme winter and summer condition. Working during very high and low temperature could cause health hazards. The Project site also needs to implement proper measures for fire safety, structural safety and any for emergency situations. There are two existing Transmission Lines of 400 kVA and 220 kVA passing through the Project site. Any construction activities nears these Transmission Lines will have safety risks. The occupational health and safety concerns mentioned above would be consistent across the Project life cycle and therefore the impacts would be similar in nature. During construction phase, it is anticipated that on average 500-600 workers will be deployed at site. The installation of solar panels and associated infrastructure will be done through experienced and trained workers. However, construction of other components will involve local workers who may not have earlier experience. Hence, there will be greater vulnerability for accidents. Therefore, receptor vulnerability is assessed as Medium. Embedded/In-built Controls All construction activities should be carried out during daytime hours and vigilance should be maintained for any potential accidents; Project specific Health and Safety Management Plan will be put in place; Personal Protective Equipment (PPEs) including safety shoes, helmet, goggles, ear muffs , face shield, insulating (rubber) gloves with leather protectors, insulating sleeves, and flame-resistant (FR) clothing and face masks; Use of permit to work system (hot work, electrical, work at height) Cranes and other lifting equipment are operated by trained and authorised persons; Excavated areas should be temporarily fenced to avoid access to outsiders and wildlife; An up-to-date first aid box should be provided at all construction sites and a trained person should be appointed to manage it; Electrical and maintenance work should not be carried out during poor weather and during lightning strikes. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 169 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Impact Magnitude As mentioned above, the majority of activities such as installation of solar panels and associated infrastructure will be done through experienced and trained workers and unskilled workers will be mainly involved in building construction activities. With above embedded controls, the magnitude of impacts will be small. Impact Significance As per the impact significant assessment matrix (refer Figure 5.2) a combination of small impact magnitude with medium receptor sensitivity results in impact significance as minor. Additional Mitigation Measures Health & safety training to be provided during both construction and operation phase; Prior to start of work, workers should be informed about the related safety risks and precautions to be taken through tool box meetings; Manual lifting by adult men to be less than 55 kg and for women it should be less than 30 kg; Adequate PPEs to be provided for all activities at site including for welding, cutting or similar operations which may cause hazard to eyes; All persons performing construction work to wear safety shoes and helmets confirming to national standard; Every worker engaged in handling sharp objects which may cause injury to hand shall be provided suitable hand gloves; While working in hot conditions, measures such as work break at regular intervals, keeping hydrated by drinking water and liquids, covering face with damp cloth etc. shall be used; Obtain and check safety method statements; Monitor health and safety performance and have an operating audit system; Permitting system should be implemented to ensure that cranes and lifting equipment is operated by trained and authorized persons only; Appropriate safety harnesses and lowering/raising tools should be used for working at heights; All equipment should be turned off and checked when not in use; Emergency contact numbers and route to the nearest hospital to be displayed at the construction site; The local/ host community to be kept at safe distance from construction site; Site specific safety or emergency response plan should be in place to account for natural disasters, accidents and any emergency situations; Site specific/ activity specific Hazards Identification and Risk Assessment (HIRA) should be developed prior to start of the activities at site; and Provide H&S achievement information to employees. Residual Impact Significance After implementation of additional mitigation measures, significance of residual impact will remain minor. Impact Occupational health and safety www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 170 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International The construction work involves construction of Solar Park along with Impact Scale construction of internal cabling and O&M activities Impact Magnitude Positive Negligible Small Medium Large Low Medium High The construction of Solar Park and erection of internal cabling will be done Vulnerability of Receptors through experienced and trained workers. However, construction of other components will involve local workers who may not have earlier experience. Hence, there will be greater vulnerability for accidents. Negligible Minor Moderate Major Impact Significance Considering the overall impact magnitude and vulnerability of social receptors, the impact significance is assessed as minor. Residual Impact Magnitude Positive Negligible Small Medium Large Residual Impact Negligible Minor Moderate Major Significance Significance of impact is considered Minor. 6.2.3 Operation Phase The list of activities during operation and maintenance phase considered for the assessment of impacts on physical environment includes: Routine cleaning of PV modules; Control of vegetation viz. weeds, bushes etc. within the site and those immediately surrounding it; Routine inspection of all PV modules and associated structures viz. cables, transformers, inverters, mounting structures etc.; Operation and maintenance of pooling substation; and Inspection and maintenance of internal site pathways/access roads 6.2.3.1 Soil Environment Context and Receptor Sensitivity During operation phase 225 employees/workers will be deployed at site. Operation phase will generate small amount of municipal waste from site office and waste such as broken solar panels. The hazardous waste generated at substation include used/spent oil, oil soaked cotton and filter waste, waste containers/tins of paints, used lead acid batteries, nonferrous scrap, insulated aluminium and copper wires/cables, waste dry chemical residues etc. which needs proper storage and disposal. During operation phase, the large area of the Project site will remain non concrete (beneath solar panels) and will have soil contamination risk due to improper waste management. Further the agricultural land existing in the surroundings may also get impacted due to random disposal of waste in the surroundings. The receptor sensitivity is assessed as medium. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 171 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Embedded/In-built Control Spill control measures such as the storage and handling of chemicals and fuel in concrete areas with secondary containment will be implemented to minimize impacts in the event of a spill; The O&M contractors will have control over the amount and types of waste (hazardous and non- hazardous) produced at the site; The hazardous wastes to be stored onsite temporarily at separate designated covered area provided with impervious flooring and secondary containment and to be disposed in accordance with Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016; and Workers will be strictly instructed/ trained about random disposal of any waste generated from the O&M activities. Impact Magnitude The quantity of waste generation will be negligible and O&M contractors will have proper waste management plan for implementation on site. The municipal waste from the site office will only be routed through proper collection and handover to local municipal body for further disposal. There will be only periodic generation of hazardous wastes during any repair and O&M activity. The waste will be disposed off through approved vendors in accordance to Hazardous Wastes Rules, 2016. The solar panels contains antimony containing glass, hence, improper disposal of used/broken solar panel may cause harm to environment. The impact magnitude has therefore been assessed as small. Impact Significance As per the impact significant assessment matrix (refer Figure 6.2) a combination of negligible impact magnitude with medium receptor sensitivity results in impact significance as minor. Additional Mitigation Measures SPD shall prepared SOP for storage and disposal of broken solar panels and tie up with an authorized dismantling agency for disposal of panels. MNRE had prepared a concept note for storage and disposal of used solar panels. The recommendations such as recycling of glass, storage of discarded panels in cover shed etc. shall be adopted in the Project; (1) The broken solar panels shall not be mixed with normal glass. RUMSL shall prepare a waste audit checklist as part of their routine site monitoring and auditing plan during operation phase for monitoring of waste management at site. Residual Impact Significance After implementation of additional mitigation measures, significance of residual impact will remain minor. Impact on soil environment due to waste generation (hazardous and non- Impact hazardous) Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale Limited to Project area (1) http://164.100.94.214/sites/default/files/webform/notices/DraftBluePrintAntimony.pdf www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 172 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Frequency Occasionally Impact Magnitude Positive Negligible Small Medium Large Resource/Receptor Low Medium High Sensitivity Negligible Minor Moderate Major Impact Significance Significance of impact is considered minor. Residual Impact Magnitude Positive Negligible Small Medium Large Residual Impact Negligible Minor Moderate Major Significance Significance of impact is considered minor. 6.2.3.2 Water Resources and Availability Context and Receptor Sensitivity During operation phase, total water requirement for the Neemuch Solar Park is estimated as below 308 KLD per annum for solar panel cleaning; 10 KLD domestic water, assuming 225 no. of O&M staff and 45 LPCD; 7 KLD for green belt maintenance (as per DPR); 32 KL for firefighting and miscellaneous The water requirement for the project will be mainly fulfilled through ground water abstraction and nearby surface water bodies. As described in Section 4.2.10.1, the resource sensitivity for ground water and surface water resources is assessed as high. Embedded/In-built Controls Nil Impact Magnitude The total domestic water requirement during operation phase is estimated as ~ 10 KLD. It is understood that total domestic water requirement will be met by ground water abstraction and bottled mineral water. The quantity of ground water required for cleaning of solar panels during operation phase is evaluated to be ~11 ham (assuming 2.5 litre per sqm and 12 cleaning cycles in a year, as per DPR). As per a report of Central Ground Water Board, Ministry of Water Resources 2017 (1), the status of ground water in the district is as below: Table 6.8 Status of Ground water in Project District S. No. Particulars Details 1. District Neemuch 2. Annual Extractable Ground Water Resources (ham) 40882.44 3. Annual Ground Water Draft for all uses (ham) 35748.52 4. Projected Demand for Domestic uses upto 2025 (ham) 1876.26 (1) http://cgwb.gov.in/GW-Assessment/GWRA-2017-National-Compilation.pdf www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 173 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report S. No. Particulars Details 5. Ground Water Availability for future use (ham) 4738.5 6. Stage of Ground Water Extraction (%) 87.44 7. Stage of Ground Water Extraction (%)- Jawad Block 96.10 8. Estimated water requirement for solar panel cleaning (ham) ~11 Source: http://cgwb.gov.in/GW-Assessment/GWRA-2017-National-Compilation.pdf The primary source of water in the area is ground water. Presently, annual ground water extraction for domestic purposes is 1480.84 ham, which is assumed to increase upto 1876.26 ham by 2025. The Jawad Block falls under Critical category for ground water abstraction. The stage of ground water development in Jawad Block is deteriorated from 2013 (Semi critical) to 2017 (Critical). If ground water is abstracted for Project, there will be additional groundwater abstraction of 281 ham over period of 25 years of operational phase of the Project. As it is evident from the above table, the stage of ground water extraction is on higher side with 96.10% in Jawad Block, the utilization of ground water for operation phase of the project may compromise with competitive users (drinking water requirement of villages and irrigation purposes) in the district based on ground water availability. Hence, magnitude of stress on ground water resources is assessed as high. Impact Significance As per the impact significant assessment matrix (refer Figure 6.2) a combination of medium impact magnitude with high receptor sensitivity results in impact significance as major. Additional Mitigation measures Conserving Water Resources Dry robotic cleaning of modules to be explored as recommended by MNRE (1); Alternate sources of water shall be explored Ground water abstraction shall be done in accordance to CGWB guidelines. Implement rainwater harvesting and/or groundwater recharge and replenishment opportunities within Site premises especially near the low-lying and gently sloping area. Optimising water usage in the SCADA building by application of water conservation measures such as sensor based taps, low flush urinals etc.; Maintain logbook for water consumption; Implement groundwater and wastewater monitoring vis-à-vis quality/quantity; Adopt less water consuming module cleaning methods; The surface runoff from during solar panel cleaning shall be diverted to a settlement tank for settlement of suspended solids. The overflow shall be treated in water treatment unit and recycled in the Project. Use of water from multiple sources to avoid dependency on one particular source (groundwater or surface water). This also includes tapping of rainwater received during the monsoons for the long-term and uninterrupted operations. The Project should implement principles of water stewardship to ensure water security not just for the site, but also for other stakeholders within the watershed. Some of the water stewardship (1) MNRE had issued a letter dated 3 June 2019 to Principal Secretaries of States and Solar Association of all States regarding optimal utilization of water and preferably use Robotic technology for cleaning of modules. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 174 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report frameworks/ standards that can be adopted are UN Global Compact's CEO Water Mandate or AWS Standards. Identify stakeholders directly impacted by the groundwater use at the Project site and develop long- term stakeholder engagement plan particularly focused on stakeholders near site to develop positive perception towards Project and its operations. Rain Water Harvesting In order to comply with CGWB guidelines for ground water abstraction, ground water recharge is mandatory in the Project. RUMSL shall plan to provide rainwater harvesting provision at site. For this purpose, rainwater harvesting pond shall be provided at site. In addition, groundwater recharge shall be undertaken within the Site to replenish the shallow aquifer zones. Piezometers to be installed to monitor the groundwater level changes in the aquifer trapped by the abstraction wells at Project site. Water Quality Ensure proper cover and stacking of loose construction material at site to prevent surface runoff and contamination of receiving water body; Open defecation and random disposal of sewage will be strictly restricted; Planning of toilets, soak pits and septic tanks, waste collection areas away from natural drainage channels; Provision of number of toilets across with easily accessible location as the project site is spread across large area of both the Units; Use of licensed contractors for management and disposal of waste and sludge; Labourers will be given training towards proactive use of designated areas/bins for waste disposal and encouraged for use of toilets; Provision for impervious storage area, especially for fuel & lubricant, hazardous waste, etc. will be made onsite; and Spill/ leakage clearance plan to be adopted for immediate cleaning of spills and leakages. Other Management Aspects Preparing an inventory of water consumption during construction and O&M activities and all pollution sources from the Project activities is essentially the first step towards managing the impacts. The Management Plan will involve preparation of an up to date inventory of all areas of water consumption and wastewater discharge sources based on the latest Project activity related information. This inventory will helps in formulating the following management approaches: Source reduction Resource recovery options Recycle options Optimal treatment strategies and technologies Post-treatment, resource recovery and recycle options Ultimate disposal considering the local environmental sensitivities The inventory database of discharge sources shall be kept as a living document and updated as and when any new sources are cited at any point in time of the Project period. Any intermittent water requirement and discharge sources shall also be identified and included in the inventory. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 175 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report A Water Management Plan is provided as Appendix F. Residual Impact Significance Residual significance of impacts will be major to moderate. Impact Water resources Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale Limited to Project areas and surroundings Impact Magnitude Positive Negligible Small Medium Large Resource/Receptor Low Medium High Sensitivity Negligible Minor Moderate Major Impact Significance Significance of impact is considered major. Residual Impact Positive Negligible Small Medium Major Magnitude Residual Impact Negligible Minor Moderate Major Significance Significance of impact is considered major to moderate 6.2.3.3 Occupational Health and Safety Context and Receptor Vulnerability During operation phase, it is anticipated that on average 225 employees/ workers will be deployed at site. The staff will be well experienced and qualified for their work. The pooling substation will be managed by RUMSL/ PGCIL through O&M contractor having Health and safety team, whereas the Solar Project Developer will be responsible for O&M of Solar Park area and have to deploy qualified H&S team. Receptor vulnerability is assessed as medium. Embedded/In-built Controls Project specific Health and Safety Management Plan will be put in place. Personal Protective Equipment (PPEs) including safety shoes, helmet, goggles, ear muffs , face shield, insulating (rubber) gloves with leather protectors, insulating sleeves, and flame-resistant (FR) clothing and face masks; Use of permit to work system (hot work, electrical, work at height) Cranes and other lifting equipment are operated by trained and authorised persons; An up-to-date first aid box should be provided at all construction sites and a trained person should be appointed to manage it; Electrical and maintenance work should not be carried out during poor weather and during lightning strikes; Fire fighting measures will be maintained at substation. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 176 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Impact Magnitude As mentioned above, the O&M activities will be carried out by qualified team. With above embedded controls, the magnitude of impacts will be small. Impact Significance As per the impact significant assessment matrix (refer Figure 6.2) a combination of small impact magnitude with medium receptor sensitivity results in impact significance as minor. Additional Mitigation Measures Periodic Health & safety training to be provided to team; Activity specific Hazards Identification and Risk Assessment (HIRA) should be conducted and accordingly SOPs shall be prepared for all O&M activities. The lock in-lock out system will be followed during maintenance/ repair activities at substation and Transmission Line; Records of incident/ accidents shall be maintained; Root cause analysis shall be carried out for any incident/ accident All persons performing maintenance/repairing work to wear safety shoes and helmets confirming to national standard; Appropriate safety harnesses and lowering/raising tools should be used for working at heights; All equipment should be turned off and checked when not in use; Emergency contact numbers and route to the nearest hospital to be displayed at the construction site; The local/ host community to be kept at safe distance from construction site; Site specific safety or emergency response plan should be in place to account for natural disasters, accidents and any emergency situations; Provide H&S achievement information to employees. Residual Impact Significance Residual significance of impacts during construction phase will be minor to negligible. Impact Occupational health and safety Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale O&M activities Impact Magnitude Positive Negligible Small Medium Large Low Medium High Vulnerability of Receptors The O&M activities shall be carried out qualified and experienced staff/workers Negligible Minor Moderate Major Impact Significance Considering the overall impact magnitude and vulnerability of social receptors, the impact significance is assessed as minor www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 177 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Residual Impact Magnitude Positive Negligible Small Medium Large Negligible Minor Moderate Major Residual Impact Significance Significance of impact is considered minor to negligible. 6.2.4 Photovoltaic Heat Island Effect (PVHI) (UHI), because it is generally described for the surface structure and overlying atmospheric layers of big cities and metropolitan areas. PV modules are produced by the electrical assembly of PV cells which provides electricity generation. The most widely-used and commercial PV cells are manufactured from crystalline silicon (c-Si). Because the final products of these cell and module types have the physical and electrical properties that can bring limited conversion efficiencies (15-30%), dark-colored surfaces, packing density and/or arrays with gaps etc., a possible PVHI can be induced in a similar way to UHIs. The large Solar Parks cover the big and untouched areas in a rural environment. After a large-scale deployment, the large number of PV arrays and the corridors between these arrays may disturb the incoming solar radiation and outgoing IR radiation amounts of the previous land surface by landscape albedo change and alteration(1). This land use change may induce a heat island effect and increase the local temperatures which is termed as Photo Voltaic Heat Island Effect (PVHI). The localized increase in ambient temperature by 3-4oC in Solar Park area could be due to following reasons(2) (3) : PV installations shade a portion of the ground and therefore could reduce heat absorption in surface soils; PV panels are thin and have little heat capacity per unit area but PV modules emit thermal radiation both up and down, and this is particularly significant during the day when PV modules Vegetation is usually removed from PV power plants, reducing the amount of cooling due to transpiration; and PV panels reflect and absorb upwelling longwave radiation, and thus can prevent the soil from cooling as much as it might under a dark sky at night. The research studies (4) (5) (6) reported that The degree of PVHI effect varies depending on the season, likely because of changing sun angles and background temperatures; Though the PVHI effect are detectable in the day, the real significant warming occurs in the evening hours, partially because these large photovoltaic installations took longer to cool down in the night time hours; (1) https://www.researchgate.net/publication/327838950_Impacts_of_a_PV_Power_Plant_for_Possible_Heat_Island_Effect (2) 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); https://www.nature.com/articles/srep35070 (3) https://pvbuzz.com/photovoltaic-heat-island-effect/ (4) https://assets.cleanenergycouncil.org.au/documents/events/event-docs-2019/SIF-2019/Presentations/03-Bronte-Nixon.pdf (5) 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); https://www.nature.com/articles/srep35070 (6) https://pvbuzz.com/photovoltaic-heat-island-effect/ www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 178 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report The increase in localized temperature may cause discomfort to the habitation and wildlife in the vicinity of Solar Park; The heating effect may dissipate after 300 m distance from Solar Park. It is to be noted that the PVHI is still a less studied aspect for assessing the impact of large Solar Parks on micro climate change and requires further in depth research. Limited empirical data exists regarding the heat island effect resulting from the installation of large scale Solar Parks. Recommendations Based on limited above understanding, following recommendations are proposed: The existing ground vegetation in the Solar Park area shall be disturbed to minimum extent; Ground vegetation shall be planted in the buffer areas/open areas available in the Solar Park; The feasibility of mixed land use development in the Solar Park shall be explored. 6.2.5 Natural hazards- Flood Likelihood Assessment ERM has adopted a qualitative risk based categorization to identify potential risks and vulnerabilities associated with flooding, inundation and waterlogging. The risks are defined considering the likelihood of their occurrence and potential severity of the impact broadly following the risk matrix presented in the table below. Refer Appendix E for detailed Flood Likelihood Assessment. Risk = Likelihood of an impact occurring x Potential severity of the impact. Probability of Occurrence Low Medium High Low Potential Impact Medium High Note: The study was carried out to evaluate and understand the likelihood of flood impact on the Site only. Risk categorization has been adopted merely for providing broad level perspective on the potential for impact from floods / inundation / water logging on the Site and to emphasize specific areas for further evaluation prior to developing Site specific mitigation measures only. A likelihood analysis of potential flooding event in and around the Site has been undertaken. The same has been presented in the Table 6.9 below. Table 6.9 Likelihood of flood evaluation Likelihood Attributes High Medium Low Site Setting Unit-1 is in close proximity of S1, S2 and Bardawada Pond, Unit-2 is in close proximity of Kawai Pond, S2 and S3 and Unit-3 is in close proximity of Badi Pond, S3 and S4; The Site Units are located along the left bank of Brahmani River. Brahmani River is located at distances of ~1.6 km, ~3.1 km and ~3.3 km to the South of the Unit 1, Unit 2 and Unit 3 respectively; Site Units are located ~30 km north-west from the confluence of Brahmani River with Chambal River; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 179 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Likelihood Attributes High Medium Low Two major dams namely Rana Pratap Sagar (~35 km south-west of the Site units) and Gandhi Sagar (~50 km south-west of the Site units) are built across Chambal River at the upstream of the Site. Watershed Characteristics The Site lies within the Brahmani River Basin. The Site is located at the central portion of the basin and ~30 km north-west from the confluence of Brahmani River with Chambal River at Bhainsrorgarh Village, in Rajasthan. The Site is located along the left bank of the Brahmani River and the predominant gradient in the region is along the north to south vector; The Site units is located in a rural setting surrounded primarily by scrub land followed by forest land, agricultural land, residential settlements and water bodies. Historical Flooding and Inundation Events Per community consultation, it was found that Brahmani River breached its banks in the years of 2019, 2016, 2010 and 1994 due to excessive rains causing widespread inundation in settlements along the river and SH 9A which is the primary access to the Site; The extent of flooding due to overflow of Brahmani River along its left bank has never exceeded beyond SH 9A (~ 1.3, ~2 km and ~2.5 km south of the unit-1, unit-2 and unit-3); During September 2019, Brahmani River was overflowing due to backflow associated with high water levels in Chambal River. Therefore, the seasonal streams draining the Site area were not able to quickly discharge into Brahmani River. Minor effects of backflow were observed in the Site area and ponds. Per community consultation, no history of widespread flooding/ inundation due to overflow from Brahmani River, nallas and/or embankment ponds was reported on-Site. However localized inundation in low-lying areas within Site was reported. Hydro-meteorological Data Average annual rainfall for period of 1980-2018 for Neemuch was 824 mm with the highest annual rainfall of 1,352 mm recorded in 2016; Maximum daily probable rainfall for 25, 50, and 100 year return periods in Neemuch District are <220 mm, <240 mm, and <280 mm respectively; Hydrological and Geomorphological Data Catchment Analysis The Site and its immediate surroundings were observed to have very flat to gentle slopes with slopes varying between 0 10%. In the Site area, the general slope of the Site area was observed to be from north to south. Continuous gradient of 6.3 m/km, 7.1 m/km and 7.3 m/km were observed to be along the north to south vector in Unit-1, Unit-2 and Unit-3 respectively. Most of Unit-1 area falls in the elevation range of 390-400 m amsl. South-western and south-eastern portions lying near Barwada Pond and S2 respectively were the lowest points varying between 390-400 m amsl within Unit-1. Unit-2 area falls in the elevation range of 390-400 m amsl. South- eastern portion along the S3 were the lowest points varying between 370-390 m amsl. Similarly, Unit-3 area falls in the elevation range of 370-400 m amsl. South-western portion comprising of areas near S4 and Badi Pond and south-eastern portion were the lowest points varying between 390-400 m amsl within Unit-3. Based on the topography and slope maps, the Site area does not logging and flooding during rainy season which may be attributed to very gentle slopes. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 180 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Likelihood Attributes High Medium Low Secondary Data Review Flooding and Inundation Per the District Disaster Management Plan Neemuch District, the district is prone to floods. It was found the Site is not prone to flooding due to overflow from Gandhisagar Dam (40 km south-east of the Site, along Chambal River). Per the global estimated risk index for flood hazard map developed by UNEP/GRID-Europe, the Site is not prone to flooding; Per the global flood hazard map developed by FM Global, the Site is not prone to high or medium flood risk; Based on global flood hazard frequency and distribution map developed by Data Basin, the Site and its surroundings is not prone to flooding. Based on the observations from the above-mentioned table, it appears that the overall likelihood of flooding event and its impact in and around the Project site may be considered as The main high probability attributes are as follows: The Site Units are located along the left bank of Brahmani River. Brahmani River is located at distances of ~1.6 km, ~3.1 km and ~3.3 km to the South of the Unit 1, Unit 2 and Unit 3 respectively. The Site Units are located ~30 km north-west from the confluence of Brahmani River with Chambal River; Unit-1 is in close proximity of S1, S2 and Bardawada Pond, Unit-2 is in close proximity of Kawai Pond, S2 and S3 and Unit-3 is in close proximity of Badi Pond, S3 and S4; Per community consultation, it was found that Brahmani River breached its banks in the years of 2019, 2016, 2010 and 1994 due to excessive rains causing widespread inundation in settlements along the river and SH 9A which is the primary access to the Site; The extent of flooding due to overflow of Brahmani River along its left bank has never exceeded beyond SH 9A. The SH 9A is located ~ 1.3, ~2 km and ~2.5 km south of the unit-1, unit-2 and unit-3; During September 2019, Brahmani River was overflowing due to backflow associated with high water levels in Chambal River. Therefore, the seasonal streams draining the Site area were not able to quickly discharge into Brahmani River. Minor effects of backflow were observed in the Site area and ponds. Per community consultation, no history of widespread flooding/ inundation due to overflow from Brahmani River, nallas and/or embankment ponds was reported on-Site. However localized inundation in low-lying areas within Site was reported per community consultation, it was found that Brahmani River breached its banks in the years of 2019, 2016, 2010 and 1994 due to excessive rains causing widespread inundation in settlements along the river and SH 9A which is the primary access to the Site; The extent of flooding due to overflow of Brahmani River along its left bank has never exceeded beyond SH 9A (~ 1 km south of the Site); During September 2019, Brahmani River was overflowing due to backflow associated with high water levels in Chambal River. Therefore, the seasonal streams draining the Site area were not able to quickly discharge into Brahmani River. Minor effects of backflow were observed in the Site area and ponds. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 181 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Per community consultation, no history of widespread flooding/ inundation due to overflow from Brahmani River, nallas and/or embankment ponds was reported on-Site. However localized inundation in low-lying areas within Site was reported. Per the District Disaster Management Plan Neemuch District, the district is prone to floods. It was found the Site is not prone to flooding due to overflow from Gandhisagar Dam (40 km south- east of the Site, along Chambal River). Per the global estimated risk index for flood hazard map developed by UNEP/GRID-Europe, the Site is not prone to flooding; Per the global flood hazard map developed by FM Global, the Site is not prone to high or medium flood risk; oding hazard zone; Based on global flood hazard frequency and distribution map developed by Data Basin, the Site and its surroundings is not prone to flooding. As per the 1-D mapping where maximum water levels at Brahmani River Bridge corresponding to Aug-Sep 2019 flooding event were mapped over the DEM, it was found that the Site is not prone to flooding from Brahmani River. Considering the above mentioned attributes, the Site is moderately susceptible to flooding. Recommendations Based on the broad level assessment, following measures are recommended to protect the assets at Undertake an assessment to estimate the High Flood Level (HFL) at the Site. This will help in estimation of the risks of flooding and inundation to the Site. Installation of solar panels and other critical infrastructure above the HFL will greatly reduce disruptions and losses to the Park; Enhance structural stability of banks of all seasonal streams such as S1, S2, S3 and S4 which are in close vicinity of the Site units and provide robust erosion protection to withstand flood water; Storm water drains must be designed in line with the natural topography and eventually drain into the natural seasonal streams in the Site area; the natural seasonal streams; Provide sluice/ flap gates at the SWD outfall to prevent backflow during a backflow event; Make provisions for pumping infrastructure within the Site to ensure rapid evacuation of water in case of high flow/backflow associated with ponds and seasonal streams ; Implement an effective flood monitoring and disaster management system in place for effective mitigation of floods at a Site level; Coordinate with the district and local disaster management cells to update on flood early warning notifications. 6.3 Impacts on Biological Environment The list of ecological impacts that have been scoped into this ESIA has been provided below: www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 182 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Table 6.10 Identified interactions that can result in an impact to ecological resources Potential Impacts Causes for Impacts Permanent and/or temporary loss/modification Clearance of vegetation across the Project site land of habitat (terrestrial and aquatic) during the parcels; Site preparation, levelling, excavation and foundation site clearance and preparation process of the construction that will affect the soil chemistry and construction phase subsequently the floral and faunal composition; and Sedimentation of water bodies due to erosion and construction materials input into nearby water bodies. Disturbance and displacement of ecology due Noise and vibrational impacts from anthropogenic and to construction activities (noise pollution, light vehicular movement and construction equipment noise; Increased stress on resident fauna due to Project-related pollution, anthropogenic movement, etc.) work causing disturbance in the existing habitats; Hunting, trapping, road kills and injuring risk due to increased influx of labour and demography into the Project site and surrounding regions; and Displacement of fauna from the Project site because of the Solar Park construction. Loss of resources including the potential for The barrier effect wherein fauna cannot access foraging barrier effects and loss of ecosystem services and roosting resources because of the walling of the Solar Park; and Loss of ecosystem services including food resources, climate regulation, erosion control, fire regulation, aesthetic value and nutrient cycling. Collision and electrocution risk Potential for lake effect wherein birds mistake the reflection of solar rays of the solar panels as a lake and it increases the risk of collision; and Electrocution risk with birds roosting along the solar modules and electrical components within the Solar Park. 6.3.1 Assessment Criteria ERM has defined impact assessment standards based on internal parameters that identifies the significance value of the impacts as a matrix between habitat/species sensitivity and impact magnitude. The internal impact assessment standards for biodiversity impacts has been provided in Table 6.11 and Table 6.12. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 183 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Table 6.11 Habitat Impact Assessment Criteria Habitat Sensitivity/ Value Magnitude of Effect on Baseline Habitats Negligible Small Medium Large Effect is within the Affects only a small Affects part of the Affects the entire normal range of area of habitat, such habitat but does not habitat, or a variation that there is no loss threaten the long-term significant portion of viability/ function of viability/ function of the of it, and the long- the habitat habitat term viability/ function of the habitat is threatened. Negligible Habitats with negligible interest for biodiversity. Not significant Not significant Not significant Not significant Low Habitats with no, or only a local designation / recognition, habitats of significance for species listed as of Least Concern (LC) on IUCN Red List of Threatened Species, habitats which are common and Not significant Not significant Minor Moderate widespread within the region, or with low conservation interest based on expert opinion. Medium Habitats within nationally designated or recognised areas, habitats of significant importance to globally Vulnerable (VU) Near Threatened (NT), or Data Deficient (DD) species, habitats of significant importance Not significant Minor Moderate Major for nationally restricted range species, habitats supporting nationally significant concentrations of migratory species and / or congregatory species, and low value habitats used by species of medium value. High Habitats within internationally designated or recognised areas; habitats of significant importance to globally Critically Endangered (CR) or Endangered (EN) species, habitats of significant importance to endemic and/or globally restricted-range species, habitats supporting Not significant Moderate Major Critical globally significant concentrations of migratory species and / or congregatory species, highly threatened and/or unique ecosystems, areas associated with key evolutionary species, and low or medium value habitats used by high value species. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 184 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Table 6.12 Species Impact Assessment Criteria Baseline Species Sensitivity/ Value Magnitude of Effect on Baseline Species Negligible Small Medium Large Effect is within the Effect does not Effect causes a Affects entire population, normal range of cause a substantial substantial change in or a significant part of it variation for the change in the abundance and/or causing a substantial population of the population of the reduction in distribution decline in abundance species species or other of a population over and/or change in and species dependent one, or more recovery of the on it generations, but does population (or another not threatened the long dependent on it) is not term viability/ function possible either at all, or of that population within several dependent on it. generations due to natural recruitment (reproduction, immigration from unaffected areas). Negligible Species with no specific value or importance attached to them. Negligible Negligible Negligible Negligible Low Species and sub-species of LC on the IUCN Red List, or not meeting Negligible Negligible Minor Moderate criteria for medium or high value. Medium Species on IUCN Red List as VU, NT, or DD, species protected under national legislation, nationally restricted range species, nationally important numbers of migratory, or congregatory species, species not Negligible Minor Moderate Major meeting criteria for high value, and species vital to the survival of a medium value species. High Species on IUCN Red List as CR, or EN. Species having a globally restricted range (i.e. plants endemic to a site, or found globally at fewer than 10 sites, fauna having a distribution range (or globally breeding range for bird species) less than 50,000 km2), internationally Negligible Moderate Major Critical important numbers of migratory, or congregatory species, key evolutionary species, and species vital to the survival of a high value species. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 185 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report 6.3.2 Habitat Modification and Loss Context The habitat mapping exercise in the ecological baseline (Section 4.3.3) has identified four kinds of habitat in the study area forest land, scrub land, agricultural land and water bodies. Based on the proposed siting locations for the Project components, only scrub land and agricultural land, i.e. only modified/lost for the Project construction. Additionally, the banks of the [Water Body Unit 3] located at the southern end of Unit 3 of Neemuch may be completely modified or lost due to the Project construction. The habitat with the highest sensitivity in the Project site is the scrub land adjacent to [Water Body adjacent Unit 3]. The water body supports migratory and resident bird species including small colonies of the Vulnerable Woolly-necked Stork. As vegetation surrounding the water body is commonly utilized by resident bird species, the loss of these habitats could result in displacement of fauna from the area. Storks are also commonly found perched at heights on Transmission Lines or trees near water bodies and therefore the loss of vegetation would affect the Vulnerable Woolly-necked Stork. The habitat has therefore been classified as medium sensitivity based on Table 6.11, as it is known to support species classified as vulnerable in the latest IUCN Red List. Embedded/In-built Controls The following embedded controls have been incorporated into the Project planning: The forest land located within Arnea Reserve Forest block (300 m- 1 km north of the Project site) has been avoided for the siting of Project components and ancillary facilities; Existing village roads are being widened and utilized for access to the Project site to the extent possible and therefore clearance of vegetation has been limited for road construction; and The Project site is located at least 300 m south of the forest land and therefore the resultant vegetation clearance will not create an edge effect1 for the local ecology. Impact Magnitude Based on the current site layout, the scrubland along the west to north of [Water Body Unit 3] (cardinal direction 225° to 0° SW to N) will be modified or cleared for the construction of Unit 3 of the Project. The loss of the scrubland adjacent to the pond may result in displacement of some aquatic bird species especially species that roost along the vegetation cover near water bodies. If displacement occurs, then species may move to the south to southeast end of the water body where frequent livestock movement was identified or migrate to alternate habitat in the area. The largest water bodies in the surrounding areas include Mandol Dam (~ 5 km north) and the Rana Pratap/Gandhi Sagar Dam areas. The loss of the vegetation could therefore result in displacement of species up to 5 km north of the current roosting site. The displacement however, has not been considered significant because most individuals would prefer using the less developed areas of the water body as long as other impacts from noise, human-wildlife conflict and anthropogenic movement is not significant. The impact has therefore been classified as small because there is availability of similar habitat in the surrounding areas or the species can travel to other large water bodies within the 5 km radius. 1 Edge effect refers to the modification or loss of habitat in a habitat transition area e.g. forest edges. The edge habitat is important for biodiversity and displays a higher floral and faunal diversity than the individual habitats because of higher sunlight penetration and larger range of foraging resources. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 186 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report Impact Significance The impact significance has been classified as minor as per Table 6.11. Additional Mitigation Measures The primary concern from habitat loss and modification is the loss of vegetation around [Water Body Unit 3] and the resultant impacts. The mitigation measures that can be implemented for reduction of impacts to surrounding habitats has been provided below: Larger mature trees with significant height and girth should be avoided to the extent possible when constructing the Solar Park. Larger trees can be set aside within the Solar Park and avoided as part of the micro-siting of the solar modules The Kawai Pond and Bardawada Pond is located within 500 m and 100 m from Unit 2 and 1 respectively. The vegetation surrounding these ponds should be avoided to the extent possible when siting temporary facilities (i.e. labour camps, contractor facilities, batching plant, etc.). A natural canal delineates the border between Kawai and Badi Villages. The canal was dry during the site visit despite the assessment being immediately after the monsoon season. The canal may pass through Unit II and/or Unit III after the compound is constructed. The natural drainage through the canal should not be blocked due to construction and operation/maintenance activities. If changes in the boundaries of the proposed units or any further expansions are anticipated than the areas surrounding the Arnea Reserve Forest block should be avoided to prevent increased risk of edge effects. The area around the [Water Body Unit 3] should be avoided for the siting of any ancillary facilities including access roads, contractor facilities or labour accommodation and even siting of equipment (e.g. DG set, waste storage area, material storage area, etc.) should not be undertaken adjacent to the water body. Residual Impact Significance The residual impact significance will remain minor because the biggest impact i.e. loss of scrub habitat around [Water Body Unit 3] can only be prevented/reduced but not completely mitigated. . Impact Habitat Modification and/or loss Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale Limited to Project site and ancillary facilities Impact Magnitude Positive Negligible Small Medium Large Resource/ Receptor Low Medium High Sensitivity Negligible Minor Moderate Major Impact Significance Significance of impact is considered minor Residual Impact Positive Negligible Small Medium Large Magnitude Negligible Minor Moderate Major Significance of impact is considered minor www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 187 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report 6.3.3 Impacts due to Construction Activities Context The following impacts from the construction phase has been considered: Laying of approach road, walling of the Solar Park, installation of the solar modules, construction of other Project components (e.g. transformers, storage sheds and control monitoring building), batching plant operations, Diesel Generator set operation and anthropogenic/vehicular movement will create noise and vibrational impacts in the surrounding areas. Constant and/or periodic movement of vehicles and people around the Project site will create a disturbance to local fauna and force them to remain in an alert mode for extended periods of time that prevents proper foraging, roosting, nesting, breeding, mating and socializing activities. Vegetation clearance, site levelling, site preparation and excavation will change the local soil properties by compacted soil layers, loosing top soil strength and increase soil erosion. The resultant impact could affect the viability of local flora, ground-roosting bird species and ground- dwelling fauna. Fauna would eventually adjust to the increased disturbance levels within the Project site and move to less disturbed area. The resultant movement may create a net displacement of local fauna and affect the species composition in and around the Project site. Increased demographic influx into the Project site may increase the human-wildlife conflict risk including hunting/trapping/injuring of local fauna and potentially road kills. The human-wildlife risk is further increased if proper toilets and gas based stoves are not provided to any labour accommodation because the labourers may then be forced to enter forested areas for their needs and increased cutting of firewood trees. The increased movement in the forest area will force conflicts with more sensitive fauna as indicated in the ecological baseline. As determined in the habitat mapping exercise (Section 4.3.3), the habitats with the highest species sensitivity are the forest and water bodies. The proposed road segments, Project components and ancillary facilities are not passing through or adjacent to forest and water bodies. The exception again is Water body adjacent Unit 3 because vegetation clearance and site preparation may occur immediately adjacent to the pond. There is potentially an increased risk to species occupying the habitat immediately surrounding the ponds including the vulnerable Woolly-necked Stork due to noise, vibrations, increased disturbance and hunting/trapping/injury risk. Similarly, the Kawai pond located 500m from the Unit II appears to support a small flock of the vulnerable Common Pochard (Aythya ferina). The species in the Kawai pond may be similarly affected by noise, vibration, disturbance and hunting/trapping/injury risk. As there is a potential impact to vulnerable species, the receptor sensitivity has been classified as medium according to Table 6.11 and Table 6.12. Embedded/In-built Controls The following embedded controls have been incorporated into the Project: The forest land located within Arnea Reserve Forest block (300 m- 1 km north of the Project site) has been avoided for the siting of Project components and ancillary facilities; Existing village roads are being widened and utilized for access to the Project site to the extent possible and therefore impact from road construction has been limited where possible; and The Project has proposed the use of local demography for the labour requirement for the Project and reduced the demographic influx into the site. The resultant human-wildlife conflict risk will also therefore be reduced. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 188 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report Impact Magnitude Several impacts have been identified for the construction phase of the Project and the impact with the highest magnitude is likely noise and vibration impacts from the various point sources of noise. The resultant impact will create displacement of local fauna including vulnerable Woolly-necked Stork and Common Pochard. There is also possibility that the impact will extend into the nearby forest areas and may affect vulnerable mammals (e.g. Leopard and Sloth Bear) and critically endangered and endangered vultures (e.g. White-rumped Vulture, Red-headed Vulture and Egyptian Vulture) if the embedded controls of avoiding forest land is not followed. The impact however, will only affect a small part of the habitat because it will be restricted to the outskirts of the habitat that is in the direction of the Project site. The impact is going to affect a small part of the habitat and has therefore been classified as small according to Table 6.11. Impact Significance The impact significance has been classified as minor assuming that no forest land will be impacted by temporary contractor/construction facilities. Additional Mitigation Measures The following mitigation measures can be implemented for the Project site: No hunting, trapping or injuring of local fauna should be communicated to labourers through a workshop or formal training exercise. The training should also communicate presence of species protected under Wildlife Protection Act, 1972 Schedule I and the penalties associated with contravention on the identified law; Noise control measures such as acoustic enclosures for DG sets, noise attenuation barriers in areas near sensitive habitat and proper maintenance of the vehicles used for the Project site should be implemented to reduce the effect of construction noise on local ecology; Set routes, consolidation of trips and no off-roading policies should be introduced by the EPC contractor to reduce the impact from noise and human-wildlife conflict; Adequate toilets, gas/firewood and space should be provided in any anticipated labour accommodation and the labourers should be informed not to enter or utilize any resources from surrounding forest land over the course of the construction period; Local semi-skilled and unskilled labourers should be used to the extent possible to reduce demographic influx into the Project site and therefore reduce the risk of disturbance to local fauna; Waste that is generated from the Solar Park during construction and operation should be stored in covered containers within the site premises. Uncovered waste may attract fauna to the Solar Park; Micrositing of project components and clear marking of project component locations in the field during construction activities should be done; Excavated areas should be adequately fenced and security should be deployed to prevent wildlife intrusion into these areas; Construction work and anthropogenic movement should be restricted near any major water bodies (including all water bodies identified in Table 4.29) to reduce the impact on aquatic bird species (resident or migratory); Construction activities and transportation should be avoided during peak ecological activity i.e. dawn (5:30 am to 7:30 am) and dusk (5:00 pm to 7:00 pm). Night-time activities should be kept to a minimum; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 189 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report Areas with pre-existing nests, ground-roosting sites and burrows should be avoided for construction related work to reduce the impact on local fauna; and Hazardous materials and waste should not be stored near any drainage channels or cliff-sides to prevent contamination of the surrounding environment and impact on local flora/fauna. Residual Impact Significance The residual impact significance will be retained as minor because of the proximity to the water body to Unit 3 and therefore higher chance of human-wildlife conflict and disturbance to species due to movement of people, vehicle and equipment. Impact Impact due to construction activities Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale Limited to Project site and ancillary facilities Impact Magnitude Positive Negligible Small Medium Large Resource/ Receptor Low Medium High Sensitivity Negligible Minor Moderate Major Impact Significance Significance of impact is considered minor Residual Impact Positive Negligible Small Medium Large Magnitude Negligible Minor Moderate Major Significance of impact is considered minor 6.3.4 Ecosystem Services Context The Project will include the long-term loss of food resources, water, shelter, nesting sites, etc. because of the establishment of the Solar Park. It is expected that the Solar Park, which is a 1065.657 Ha land parcel will be walled off and therefore any resources existing within the land parcels will not be available. The existence of the walled compound may also hinder daily pathways taken by reptiles, mammals and birds for foraging, roosting and socializing. Specific to the Project site, the clearance of vegetation, access to the natural canal between Kawai and Badi Villages and Badi Pond will be lost due to construction of the wind farm. Additionally, access to smaller ponds located along the access roads may be affected by the Solar Park construction. Some pictures of the resources that will be lost due to the Solar Park construction has been provided below: www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 190 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report Water body along the access road to Unit 3 Tree resources located at the northern end of Unit 2 Natural Drain between Kawai and Badi Villages Weaverbird Nesting Site in Unit 3 The loss of ecosystem services due to the construction of the Solar Park has been described below: The loss of cultivated crops and medicinal plants that are found along the agricultural land and scrubland within the 1065.7 ha land parcel; Loss of some wood products and non-timber forest products (e.g. catechu) that is found around the Project site; Loss of freshwater resources as smaller ponds along the access roads; Loss of viability of the [Water Body Unit 3] due to any impacts (e.g. sedimentation, water contamination, etc.) from the adjacent construction work for Unit 3 of the Project; Loss of climate management resources including water purification, pest regulation, fire regulation, disease regulation, erosion regulation, shade, carbon sequestration and air temperature/quality regulation. Reduced aesthetic value of the lost scrub habitat and conversion to industrial areas; and Loss of primary production. The loss of resources includes the areas surrounding [Water Body Unit 3] that that supports vulnerable species and therefore receptor sensitivity is defined as medium in accordance to Table 6.11. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 191 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report Embedded/In-built Controls The following embedded controls have been incorporated into the Project planning: The forest land located within Arnea Reserve Forest block (300m- 1km north of the Project site) has been avoided for the siting of Project components and ancillary facilities; Existing village roads are being widened and utilized for access to the Project site to the extent possible and therefore clearance of vegetation has been limited for road construction; and Larger water bodies such as Kawai Pond, [Water Body Unit 3] and Bardawada Pond have been avoided as part of the Project siting. Impact Magnitude The loss of ecosystem services includes, natural canal, smaller water bodies, mature trees and scrub habitat. Alternative habitat including larger water bodies, forested land and similar habitat types is found in the surrounding region. The Project site is also largely affecting scrub habitat consisting of thorny dry deciduous forests that have a lower ecological value because of the low floral diversity and limited foraging resources/shade cover. The loss of the resources across the construction and operation phases would therefore affect a small part of the habitat but the overall loss of long-term viability of the ecosystem will not occur due to availability of similar habitat in the region. The impact magnitude has been assessed as small in accordance to Table 6.11. Impact Significance The impact significance has been assessed as minor for the Project site Additional Mitigation Measures The following mitigation measures can be implemented for the Project site: Nesting trees should be avoided to the extent possible when it falls within the Solar Park site. Larger mature trees 1 with significant height and girth should be avoided to the extent possible when constructing the Solar Park. Larger trees can be set aside within the Solar Park and avoided as part of the micro-siting of the solar modules. Natural drain passing between Kawai and Badi should be unaffected by the Project construction. Similar seasonal drainage pathways should not be blocked during the Project construction. Seeding of native plant species outside of the Solar Park especially in areas where the soil layers have been impacted and around water bodies to offset the loss of floral resources and dependent ecosystem services. Pollution and spill control mechanisms should be implemented and strictly enforced around [Water Body Unit 3] to ensure that there is no impact to the water quality or any drainage channels into the water body. Residual Impact Significance The residual impact significance will remain minor after implementation of mitigation measures because there will still be an impact due to the loss of smaller water bodies within the Solar Park and scrub habitat that cannot be adequately offset due to the large land requirement for the Project. 1 Mature trees can provide several ecosystem services including firewood, non-timber forest produce, shelter, climate regulation, habitat provision and foraging resources. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 192 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report Impact Impact due to loss of resources Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale Limited to Project site and ancillary facilities Impact Magnitude Positive Negligible Small Medium Large Resource/ Receptor Low Medium High Sensitivity Negligible Minor Moderate Major Impact Significance Significance of impact is considered minor Residual Impact Positive Negligible Small Medium Large Magnitude Negligible Minor Moderate Major Significance of impact is considered minor 6.3.5 Collision and electrocution risk Context The solar modules being housed within the Project site are in close proximity to each other and therefore can mirror the reflection of a large water body during daytime hours. The smooth surface can also be mistaken by bats to be water bodies when using echolocation. The risk of the lake effect wherein birds and bats mistake the solar modules as a water body is more pronounced in this Solar Park because an existing water body (Water Body Unit 3) is immediately adjacent to the proposed location of Unit 3 of the Project. Species that have traditionally used the water body may have an increased risk of collision with the solar modules or internal Transmission Line infrastructure along the boundary walls during the operation phase. Electrocution risk occurs when bird and bat species roost or nest Transmission Lines and are exposed to the uninsulated electrical components. There is also a chance of collision with the live electrical line components due to the line being not clearly visible during daytime hours (lack of reflective capacity) and night-time hours (poor light). The risk of electrocution is significantly reduced in internal Transmission Lines of solar projects because the large amount of development/disturbance in a restricted space may dissuade bird movement into the Solar Park and the transmission lines are typically covered/underground within the solar compound. The external Transmission Line, which has a higher risk of electrocution, is not scoped into this ESIA report. The risk is therefore limited to birds roosting on solar modules and getting exposed to any electrical wiring or collision with any overhead lines within the Solar Park. Some examples of bird roosting on Transmission Lines have been provided below: www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 193 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report Beheaded Red-vented Bulbul Feather spots under an existing Indian Roller roosting on a below an existing Transmission Transmission Line indicating a Transmission Line Line mortality due to electrocution Green Bee-eater roosting on a Long-tailed Shrike roosting on a Large Grey Babbler roosting Transmission Line Transmission Line on a Transmission Line The species that were observed roosting on Transmission Lines were largely Least Concern species. Species that have been identified in the Project as vulnerable or higher as per the latest IUCN Red List are largely aquatic birds and therefore the likelihood of these species roosting on solar modules or Transmission Line components within the Solar Park is very low. The two exceptions are the species mistake the solar panels for lakes and collide with the PV modules and any Transmission Line infrastructure within close proximity to [Water Body Unit 3]. The presence of the Solar Park in close proximity to [Water Body Unit 3] can increase the risk of collision with the solar modules but the likelihood of collision/electrocution with internal transmission line infrastructure is negligible. There is a risk that the vulnerable Woolly-necked Stork would use this surrounding features for roosting during daytime hours. The presence of the vulnerable stork results in a receptor sensitivity that is medium in accordance to Table 6.12. Embedded/In-built Controls As is typically undertaken in solar projects, the array cables from the solar modules to the connector box/inverter will be underground cabling and will not be exposed to create any electrocution risk to roosting fauna. Impact Magnitude Birds and bats will adjust to the presence of the Solar Park over time and therefore avoid the structure entirely. The biggest collision and electrocution risk is from impact with power evacuation infrastructure, which is minimal for internal transmission lines because the lines are typically covered or underground. The impact from collision and electrocution risk with the Solar Park will therefore be greatly reduced. From a long-term viability perspective, it is anticipated that a very small portion of the species composition. The impact magnitude has therefore been assessed as small in accordance to Table 6.12. Note: the above impact magnitude has been considered only for collision with solar modules and internal transmission line infrastructure. The impact magnitude does not consider collision and electrocution risk with external transmission line infrastructure that has been separately covered in another ESIA. Impact Significance The impact significance has been assessed as minor. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 194 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report Mitigation Measures Restrictions should be imposed so that dead carcasses are not disposed near the Solar Park. The O&M team should be trained on removing any carcasses found around these Project components in a timely manner to ensure that no vulture or birds of prey are attracted to the Project site. RUMSL should maintain a carcass register as part of the Operation and Maintenance (O&M) phase to record any bird carcasses or suspected bird carcasses. The register should include a date, type of specie (to the extent identifiable), geographic location and nearest Transmission Line infrastructure for each carcass entry. If possible, the register should be backed-up with photo-documentation of any identified carcasses or remains. If the number of carcasses are significant, then RUMSL should commissioning an ecologist to suggest more stringent mitigation measures at the sensitive Project components. The O&M team should be instructed to regularly inspect areas around transmission line and solar module infrastructure as part of their periodic maintenance and rounds of the operational Solar Park. The purpose is to identify any roosting or nesting of bird species. The internal Transmission Line, if any, should be marked with diffractors/diverters at a spacing of 10m apart including bird guards/diverters in low voltage lines/cables. Residual Impact Significance The impact magnitude for collision/electrocution risk due to internal Transmission Line infrastructure and solar modules can be reduced to negligible after implementing the above mitigation measures. Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale Limited to Project site and ancillary facilities Impact Magnitude Positive Negligible Small Medium Large Resource/ Receptor Low Medium High Sensitivity Negligible Minor Moderate Major Impact Significance Significance of impact is considered minor Residual Impact Positive Negligible Small Medium Large Magnitude Negligible Minor Moderate Major Significance of impact is considered negligible 6.4 Impacts on Social Environment The maximum impacts of the project related activities will be in the Project villages, on the land owners, Patta Land holders and households that are using the land formally and informally as encroachers, agricultural labourers, graziers, etc. Specifically, the impacts will be due to use of Government land identified for the project, within which several uses exist, as elaborated in Section 4.4.6. The project design features went through an avoidance exercise to reduce the need for private land and Patta Land for the project to the extent feasible. As part of the optimization exercise, no Abadi area (area with village habitation and residential structures) has been included in the project footprint. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 195 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report 6.4.1 Avoidance and optimisation of the Project footprint As understood from the project documents, there have been multiple optimization exercises, in order to ensure maximum avoidance of land used for agriculture and habitation in Project villages. The land originally identified for the project is presented below. Table 6.13 Land identified for the Project at the DPR stage Land Category Bardawada (ha.) Kawai (ha.) Badi (ha.) Total land (Hectare) Government Land 201.4 245.7 521.9 969 Private Land 5.1 13.9 15.5 34.6 Patta Land 50.7 26.2 10.8 87.7 Sum 257.2 285.8 548.3 1091.3 Source: DPR, October 2019 Additionally, details of and identified by the project, based on ownership and use, are presented in the table below. Table 6.14 Details on land identified for the project Ownership and Bardawada Kawai Badi Total community use Total land requirement 257.7 (23.5%) 285.9 (26.2%) 549.1 (50.3%) 1092.7 (ha and %) Government land (total) 202 245.7 521.2 968.8 (ha) Private land (ha) 5.1 13.9 16.5 35.5 No of Private parcels 6 12 30 48 Patta land (ha.) 50.7 26.2 10.8 87.7 No of Patta parcels 43 22 8 73 Source: Data shared by RUMSL on 3June 2020 The land optimization exercise has resulted in reduction in the requirement of private land for the The area of land to be used for the project is as presented in the table below. Table 6.15 Details of land footprint finalised for the Solar Park Land Category Unit 1 (ha.) Unit 2-(ha.) Unit 3 Total land (ha.) (Hectare) Bardawada Kawai Kawai Badi Badi Government Land 201.8 89.6 156. 1 163.2 351.7 962. 5 (both NRED allotted & identified) Private Land 5.1 4.2 0 1.7 10.4 21.4 Patta Land 50.7 0 22.4 3.6 5 81.7 Sum 351.5 347 367 1065.7 Source: Land Data provided by RUMSL, 3 June 2020, included in the Final DPR July 2020 The impacts of land take on these villages will flow from all categories of land, whether government, patta or private, and will potentially affect livelihoods and easements (traditional access and use) but www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 196 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS Final ESIA Report also on availability of land for future generations. Some impacts may be possible to mitigate or manage while others will need to be compensated, while certain residual impacts will continue to remain even after implementation of the mitigation measures. 6.4.2 Potential impacts from Project activities on stakeholder categories The land identified for procurement for the Neemuch project comprises 21.4 ha. Private land (nearly 2% of total land required), 81.7 ha. Patta Land (approximately 8% of the total land required) and 962.5 ha of Government Land (comprising nearly 90% of the total land). There are 48 Private land owners and 73 Patta land holders associated with the land that has been identified for the project. Considering the fact that the average size of the household in the project area is 5 (as presented in Table 4.39), the total number of Project Affected population belonging to Private and Patta land holder families is nearly 600. Furthermore, there are households that are impacted due to loss of grazing land in vicinity or loss of income due to agricultural activity on land parcels encroached/ squatted upon. Additionally, there will be some households whose members work as agricultural labourers on private, patta and encroached Government land parcels that are identified for the Solar Park. The details and number of agricultural labourers will be captured through RAP survey. The table below describes the potential impacts that are likely to result from Project activities in various stages of the project, comprising, Planning, Construction and Operation, on various socioeconomic and community aspects, including from the land requirements of the project, as noted in the Table 6.16. Additionally, the table below and the sections 6.4.4, 6.4.5, 6.4.6, 6.4.7 and 6.4.8 detail out the embedded controls and mitigation measures for specific impacts, as drawn from the ESMF for the project and enhanced through specific impacts identified. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 197 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Table 6.16 Summary of Potential impacts from project activities Impact Categories Impacts Impacted Stakeholders Mitigation measure Planning Phase Impacts Private Land (Purchased Approx. 21 ha. of private land is being considered for Private land owners; The private land sellers should be provided with through MP Mutual purchase by the project, which forms nearly 2% of the Agricultural either alternate land parcels with similar nature Consent Policy, 2014 total area identified for the project; labourers employed of productivity and financial assistance to The private land parcels that are identified are not being seasonally; prepare the land for cultivation or adequate used for residential purposes, thus there is no physical Local Community. compensation, at twice the value of land and displacement due to project; however, economic assets, as per MP Mutual Consent Policy, 2014; displacement will occur for the private land sellers whose After assessing the applicability and need during land parcels will be purchased for project related activities the RAP Survey, a Resettlement Action Plan- affecting livelihoods and incomes; Livelihoods Restoration Plan is required to be Landlessness may potentially result due to purchase of formulated to address: private land parcels in some cases. The total land holding - Livelihood impacts on the land owners if the and proportion of land remaining with the sellers after the holdings that remain are sub-optimal, or owners mutual consent based sale, is not known currently, but will are rendered landless; be assessed during the RAP survey; Agricultural labourers employed by the land owners of the - Additional livelihood assistance to private land parcels identified for purchase for the project vulnerable households, or women headed will experience loss of livelihood opportunities; households, with skill trainings or Loss of access or easement for the local community due entrepreneurship support, etc. under the LRP; to diversions/ barricading of areas due to construction - Impacts on land users or regular agricultural phase activities. labourers affected - The general community being impacted due to access restrictions/easements; Other displacement impacts on private and patta land owners. Preference to members (vulnerable) of the families post selling land to the project for employment opportunities in the Construction/operation phase, small contracts; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 198 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Impact Categories Impacts Impacted Stakeholders Mitigation measure Timely sharing of project related information with all relevant stakeholders; Provision of Grievance Redressal Mechanism to all impacted stakeholders in order to raise and register their grievances. Pattta Land (Negotiated Approx. 81.7 ha. of Patta land is being considered for Patta Land Holders; Patta is being treated at par with ownership, for purchase through MP purchase by the project, which forms approx. 8% of the Non-recognised the land procurement process. Thus treatment Mutual Consent Policy) total area identified for the project ; of Patta Land holders will be similar to Private Economic displacement will occur for the Patta Land have procured the land owners and Patta holders shall be provided holders who have invested cost and efforts in the Patta patta based on a with either alternate land parcels with similar land to make it cultivable and are currently undertaking verbal agreement nature of productivity and financial assistance to agricultural activities; with the original (and prepare the land for cultivation or adequate The Tarmeem process demarcated the location of 43 registered) patta compensation at twice the value of land and Patta land parcels in Bardawada, 22 Patta land parcels holder assets, as per MP Mutual Consent Policy, 2014; from Kawai and 8 patta land parcels in Badi and while the Agricultural After assessing the applicability and need during recorded Patta land holders can be based on the labourers; the RAP Survey, a Resettlement Action Plan- available records, these will need to be updated during Local Community. Livelihoods restoration Plan is required to be the RAP survey to get the current number of affected formulated to address: households and persons (reasons outlined below).; - Livelihood impacts on the land owners if the Typically Patta land owners are likely to be from holdings that remain are sub-optimal, or vulnerable households like SC, ST and other previously owners are rendered landless; landless households and the land purchase for the project may lead to cases of landlessness, (which is more - Additional livelihood assistance to likely to be in this category than the category of vulnerable households, or women headed private land holders, as landlessness is a baseline households, with skill trainings or criteria for initial award of pattas); entrepreneurship support, etc. under the It is understood that certain Patta Land parcels have been LRP; t - Impacts on land users or regular agricultural was originally allotted to, without a change in records. labourers affected Although this is not allowed as per the terms of the allotment, it is reported as a practise. In such cases, the - The general community being impacted due households using the Patta lands through this to access restrictions/easements; arrangement are also understood to be impacted, in www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 199 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Impact Categories Impacts Impacted Stakeholders Mitigation measure addition to original owners, who are still on record as - Other displacement impacts on private and patta land owners. Agricultural labourers working at the Patta land parcels Preference to members (rendered landless or identified for purchase for the project will experience loss with sub-optimal holdings) of the families post of livelihood opportunities; selling land to the project for employment Loss of access or easement for the local community opportunities in the Construction/operation due to diversions/ barricading of areas due to construction phase, small contracts; phase activities. Additional safeguards to be addressed through the RAP-LRP for Patta Land owners; Timely sharing of project related information with all relevant stakeholders; Provision of Grievance Redressal Mechanism to all impacted stakeholders in order to raise and register their grievances. Government Land Government land being identified for the project from the Local Community; Provision for alternate grazing land for livestock (LUPA between RUMSL three project villages amounts to 962.5 ha, which forms Livestock Owners or near the project village, or confirmation of and New and Renewable nearly 90% of the total land required for project. Graziers whose adequacy of remaining grazing land; Energy Department, This land has different uses by the local community: livestock grazes in Development of community fodder lots may be Government of MP): the identified land explored as a Livelihood restoration activity in - Livestock grazing in the open as well as within for 8 months in a the area as part of Resettlement Action Plan. Used Land (permitted year (except This, if feasible, shall serve the purpose of uses): Grazing, encroachers(see below); summers), from 3 augmentation of grazing land and as an income easements, cultural - Incidental collection of non-timber products like project villages and generating activity for people losing land based heritage sites, water other villages that livelihoods. sources, fuel wood are sending their Provision of easements shall be maintained in collection and collection of - Easements, access to assets and other resources not livestock for grazing order to not sever the access to CPRs for the other resources; within the project boundary, etc. and the change in in identified land; community; use and ownership of Government land will affect the Timely sharing of project related information with users in the community to varying degrees. all relevant stakeholders; The Impacts on users of this land type comprise the Provision of Grievance Redressal Mechanism to following: all impacted stakeholders in order to raise and register their grievances. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 200 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Impact Categories Impacts Impacted Stakeholders Mitigation measure Loss of Grazing land for the livestock in the area and loss of livelihood and nutritional security due to possible reduction in livestock herd size due to reduced access to grazing land (potential vulnerability) Loss or severance of access for the community, livestock, etc.; Loss of cultural resources in terms of religious trees, structures, etc. Government Land Additionally, a portion of this Government land has been Squatters and RUMSL shall serve a three months advance (LUPA between RUMSL informally (and illegally) encroached by local land owners Encroachers; notice to the project affected persons (PAPs) to and New and Renewable for cultivation of crops, livestock grazing, etc. Anecdotal Local Community. manage the potential losses to standing crops; Energy Department, evidence suggests that most of the encroachment is done In case of crop losses ensuing from project Government of MP): by land owners from the Dhakad community, it is also activities, RUMSL shall pay compensation for reported that people from this community are skilled crops, at full replacement cost, as per the ESMF; Informally occupied Land: (more than others) in local forms of agriculture and able to Timely sharing of project related information with Captured/encroached for develop dry land and make it cultivable. all relevant stakeholders, in order to serve agriculture or grazing, It was also reported that the encroachers/occupiers paid advance notice and reduce the extent of losses/ prohibiting use by other fines to the Government (revenue department) self- impacts; people reporting a smaller proportion of land than is actually Employment to members of such encroacher squatted upon/ encroached. There are no reliable records and squatter households, based on qualification; of the actual extent of government land Skill development of members of such encroached/occupied for agriculture. The amount of land encroacher and squatter households, based on encroached has grown in recent years, with the any existing skill set (if any), and self-declared availability of regular power supply, enabling the use of interests. deeper bore-wells to extract ground water for irrigation. Provision of Grievance Redressal Mechanism to Out of the 968.9 ha. Government land for the project, all the key stakeholders in order to raise and anywhere between 10-20% may be encroached and / or register their grievance. squatted upon by land owners, leaving a lesser amount of land for common usage by the larger community. If captured land is taken for the project it would affect the following groups: - Encroachers/squatters who have occupied (and developed) government land for agriculture (these are www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 201 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Impact Categories Impacts Impacted Stakeholders Mitigation measure all reported to be land owners) and belonging to the three Project villages - Agricultural labour employed seasonally, to work in these fields - The community at large, using common grazing land is already deprived of these areas as they are no longer available to them for grazing due to squatting and encroachment, so, they will not be affected. Construction Phase Impacts Temporary occupation of The land required for temporary activities like setting up of Owners of land Adequate lease/ rents to the land owners; land for construction a number of labour camps for the required duration, land required for Restoration of land to its original state, or better, phase activities: for safety setbacks, storage areas, parking areas and temporary at the time of handing it back to the owners; Labour Camps; other construction related temporary land requirements, if occupation and use Compensation for the loss of livelihoods to the Safety Setbacks; these are located outside the boundary of the Project Users of land users of the land required for temporary use as Storage areas; Area. If all these activities can be accommodated with the Local Community this will temporarily economically displace them; Parking areas; Project footprint, the impacts from temporary land lease- Application of all precautions to implement and Other construction rent, will be avoided; follow the COVID-19 related safeguards, as related temporary Other impacts, from noise, nuisance, resource use, etc., relevant and as prescribed by the government, land requirements, are discussed below. at that time etc. COVID 19 related infection risks may persist and may be Timely dissemination of project related enhanced for workers, living and working in close information with all relevant stakeholders, in proximity of each other order to serve advance notice and reduce the extent of losses/ impacts; Provision of Grievance Redressal Mechanism to all the key stakeholders in order to raise and register their grievance. Community Health and The movement of material and machinery would pose Local Community; Stakeholder engagement through the project Safety including accident health and safety risks to the community and livestock as Livestock Owners or cycle and an effective Grievance Redressal risks for animals the vehicular movement will increase in the area and may Graziers; Mechanism to avoid, mitigate and mange result in collision and accident risks, and create additional conflicts and disagreements. vehicular and dust pollution, affecting people, animals and www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 202 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Impact Categories Impacts Impacted Stakeholders Mitigation measure potentially affecting crops in the vicinity of the corridor of Workers engaged As part of the stakeholder engagement and movement; during construction information disclosure process, Labour influx in the area due to construction phase may phase The community will be provided with an lead to community health and safety related impacts which understanding of the activities to be undertaken may include and the precautions taken for safety; The project will also propagate health and safety - Potential spread of communicable diseases awareness amongst the community; (infectious and vector-borne), if external labour will The traffic movement for the project in the area be sourced from outside the region, will be regulated to ensure road and pedestrian - The issue of COVID-19 related infections may remain (including livestock) safety; a relevant concern and may need to be especially RUMSL shall maintain safe distance of project managed both, within labour camps and in the components from schools, hospitals, etc. in interactions of workers and the local community order to avoid interactions with community hotspots and hence risks of accidents; - Conflicts with local community resulting from The Contractor shall be informed of the EHSS disagreements over other issues and local impacts practices that are expected from its workers during the construction phase engagement. Obligations like preparation of Traffic Management Plan, Local Procurement Plan, EHSS Plan, etc. shall be communicated to them at the time of selection and appropriate clauses should be included at the time of contract finalization; The contractor shall be required to adhere to camps in terms of provisions, sanitation facilities, etc. thus limiting the probability of diseases and infections in the local community on account of improper management of waste; The movement of workers from the project site and labour camps should be regulated and similarly the project boundary and labour accommodation to check for unauthorized www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 203 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Impact Categories Impacts Impacted Stakeholders Mitigation measure visitors/ outsiders entering the site in order to avoid any possible tensions between the migrant workforce and host community; RUMSL shall put in place a grievance redressal mechanism to allow for the workers and community members to report any concern or grievance related to project activities. Stress on Community Depletion of ground water resources in the area may take Local Community; There will be a worker Code of Conduct defined resources - Water and place due to use for project related activities like by RUMSL that prevents workers and Forest, Roads construction, use for drinking water, cooking and sanitary contractors from using the local resources like purposes, etc. potentially affecting water availability for water, forest. Refer Section 6.2.2 for other the local population, that depends on the same resources; mitigation measures; Potential loss of forest resources due to exploitation An induction session will be organised for the triggered by influx of labour in the area, thereby affecting migrant workers where they will be sensitized on the stock available for the local community; Wear and tear of roads may take place due to movement project location, which would include aspects on of heavy machinery on the roads, creating movement conservation of problems and risks for local road users. The contractor shall be asked to use Tanker water supply during the summer months, which are dry months in which water scarcity issues are reported by the community; Periodic maintenance activities for roads used for transportation of goods for the project shall be the undertaken by the Solar Park operator , through its contractors; There will be a set of contractor obligations that require preparation of Traffic Management Plan, Local procurement plan, etc. in order to safeguard com Provision of Grievance Redressal Mechanism to all the key stakeholders in order to raise and register their grievance on misuse of locally available resources. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 204 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Impact Categories Impacts Impacted Stakeholders Mitigation measure Employment and The construction phase will provide a boost to the local Members of local Enhancement measures entrepreneurship employment as a higher number is expected to be community that can The sourcing of local labour wherever possible opportunities during engaged as construction labour during construction phase; be engaged as should be made obligatory for the Solar Project construction Development of smaller vendors in the area through petty labours for the Developers and sub-contractors and in all major shops, petty contractors, etc. providing essential goods construction phase; procurement activities; and services during the construction phase; Existing vendors. Preference should be given to the land losers There will be an impact on local food basket due to and vulnerable population in the Project Villages, increased demand for agricultural products and food to the extent practicable; items. Employment of members of SC-STs and Women Headed households should be encouraged by the Solar Project Developers through documented agreement with contractors/ sub- contractors and may be set at a minimum of 30% of total workers or person-days of employment; Engagement of local vendors, to the extent possible, for the goods and services required for the project during construction phase; The project proponent will establish a mechanism to audit subcontractors and suppliers with respect to compliance of utilizing local labour and resources; Provision of Grievance Redressal Mechanism to all the key stakeholders in order to raise and register their grievance with respect to information sharing related to jobs and access to jobs. Operations Phase Impacts Community Health and The Operations phase would have very limited activity Local Community; Community engagement and sensitization Safety outside the project site as the construction phase would Livestock and sessions should be re-organised at the beginning have been over and the scale of activity and workforce at Livestock Owners of Operations phase, in order to mention about the project footprint area would have reduced significantly. This would lead to far fewer impacts: the new developments in the area and provide Less or negligible noise, www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 205 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Impact Categories Impacts Impacted Stakeholders Mitigation measure Fewer workers at site on near project villages, an understanding of the precautions to be taken Reduced traffic load (compared to construction phase) for safety; from the movement of people and goods. Additional precautions may be needed to address the COVID-19 related safeguards, as relevant and as prescribed by the government, at that time the community shall still be in implementation to deal with any concerns of community health and safety, being raised by the local community. Impact on Employment The Operations phase would require much smaller Local Community Enhancement Measures workforce as compared to construction phase and the RUMSL shall ensure that the Solar Project skillset of the required workforce shall be different. The Developers (SPDs) advertise the roles of Operations phase would require Engineers, Technicians to manage the Plant operations and amongst the Technical staff required during operations requirement of semi-skilled workers in limited numbers for phases, in the local newspapers to enable hiring housekeeping and Security related jobs, on the payroll of of competent people from nearby areas, to the RUMSL. Additionally, there may be some vacancies with extent feasible; the private Solar Project Developers (SPDs) that may Preference shall be given (to the extent feasible) have some local employment, if feasible to hire competent members from PAHs for semi- skilled jobs like housekeeping or Security Guards. Impacts on Vulnerable Groups Impacts on Indigenous Out of the three phases, the Indigenous Communities and SC/ ST communities To identify and assess the extent of impacts on Communities/ Vulnerable vulnerable groups are understood to be impacted the Vulnerable this group, a review of the scope of FPIC and most during Planning phase of the project, on account of Groups households IPP, in terms of remaining impacts on IP groups, loss of livelihoods linked to land being procured for project. Since these agricultural workers are not rightful their traditional livelihoods and customary land owners or users of land as per records, the project related use; including dependence on natural resources, compensation measures would not be directly reaching will be undertaken; out to this group. Based on this review, the target groups for the FPIC process will be identified in terms of villages and number of households in each village. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 206 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Impact Categories Impacts Impacted Stakeholders Mitigation measure It should be noted that the exact number of households may be identified only post the site walk through and social mapping. Review the consultation process carried out as part of allotment process of unoccupied government land through discussions with personnel from the Land Division of District Magistrate office to access the Gram Sabha resolutions as part of the land allotment process. Relevant details in relation to the Gram Sabha Resolution will be collected to understand implications for any legacy issues. As part of the stakeholder engagement, ensure adequate representation of the Indigenous groups and vulnerable groups, and specific engagement activities are undertaken with these groups; Ensure that the grievance management mechanism established is accessible to these groups. Impacts on Women Impact on Women There are 6 female private land owners and 12 female Women community A Gender Action Plan is prepared for the Project (Construction phase) Patta land holders identified from the list of 48 private land members in Project where women focussed engagement is detailed owners and 73 Patta land holders, respectively villages; (refer Appendix F). Potential impacts on women within households affected by Women Headed Ensure that the employment of women from private and patta land procurement, where women are not households vulnerable households is done for the project land owners: and efforts are made for development of women owned enterprises in the area, from where - Women may be potentially affected more severely in procurement for project related needs is such households, if they are being rendered land-less undertaken; - Risk of gender based violence from delayed Undertake a profiling of the various social payments or other land ownership based conflicts groups in the Study Area, to understand the www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 207 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Impact Categories Impacts Impacted Stakeholders Mitigation measure Women Headed households (both Joint as well as individual needs and concerns of the various independent) may potentially become more vulnerable in women belonging to different social groups and cases of sale of land for the project, if land is not in their design community development and CSR name, or they do not receive the benefits. programmes in light of the same; Women land owners may face additional risks of not being As part of the stakeholder engagement, RUMSL included in negotiations, or other key meetings due to shall ensure and communicate to the private prevailing cultural norms and may not therefore receive Solar Project developers, that Women focussed the benefits and advantages compared to those who do discussions are conducted in order to ensure participate adequate representation of the Women and their Access to jobs during the construction phases generally needs and concerns in order to design specific skews in favour of males, thus preventing women from engagement activities; availing project benefits. Provision of Grievance Redressal Mechanism to Women and girls are disproportionately at risk in terms of all the stakeholders in order to raise and register safety (gender based violence, harassment, curtailed their grievances. movement, reduced access to resources) during the construction phase, with the arrival of migrant labourers in the construction phase and their accommodation being planned near the project villages. The nature of impacts are envisaged on women in the Operations Phase Operations phase will be as following: The extent of outsiders and migrant population in the area would have reduced along with risk to their safety; There would be limited requirement of labourers jobs or vendor-ship opportunities in Operations phase, which might render them in search of livelihood options again. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 208 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report 6.4.3 Assessing the Significance of Impacts For the assessment of social impacts, the sensitivity and magnitude criteria outlined in Section 6.1 has been used. The social impacts associated with the planning, construction, operations and decommissioning stages have been assessed qualitatively and in some cases quantitatively (subject to availability of data), using professional judgement and based on past experience from similar projects. 6.4.4 Planning Phase Impacts 6.4.4.1 Impact due to Private Land Purchase Context and Receptors The Private land identified for the Neemuch Solar Park comprises approximately 21.4 ha. and is largely used for agricultural activity. Some of the private land parcels that were initially identified that were part of an inhabited settlement and have been carved out to an extent from the Project boundary, as avoidance measures. Thus, there is understood to be economic displacement due to project related private land purchase and no physical displacement is anticipated and the same will be confirmed during RAP surveys to be conducted in October- 2020. There is agricultural labour engaged at these private agricultural land parcels which comprise of members of households with smaller or no landholdings, which may also face loss of livelihoods linked to these land parcels; however the estimate of people working as agricultural labour on these land parcels is not currently known. Furthermore, the area surrounding the private identified land for project would still be used for cultivation and livestock grazing in future and the project may restrict access or make accessibility difficult for the local community, livestock, etc. especially during the construction phase. The potential impacts caused due to procurement of Government land are detailed in Table 6.16. Embedded/In built control RUMSL shall procure private land based on principles of negotiated settlement, to the extent possible and the price to be paid for the land sale shall be determined using the principles of MP Mutual Consent Policy 2014. However, RFCTLARR 2013 Act may only be used for land parcels that either do not have clear titles, or have ownership related disputes. To clarify, as stated in Section 2, the RAP-LRP will be prepared for all impacted families including the consenting private land owners who are economically displaced wherever negotiated settlement process have been undertaken. The LRP will also cover economic displacement impacts on agricultural labor, working on the procured/purchased private land. An amount of INR 2 lakhs per MW per annum has been envisaged to be provided to the local district collector to facilitate development activities in the area and these activities may range for skill development, training, restoration of local water bodies and other local development works. Impact significance The impact of change in land ownership and use which imposes restrictions to the identified private land and surrounding agricultural land in the construction phase is evaluated to be Moderate and the nature of change is irreversible. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 209 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Additional Mitigation Measures The private land sellers should be provided with either alternate land parcels with similar nature of productivity and financial assistance to prepare the land for cultivation or adequate compensation at twice the value of land and assets, as per MP Mutual Consent Land Purchase Policy, 2014; A Resettlement Action Plan shall be formulated to cover economic displacement categories (subject to the qualifications stated under embedded controls) to address the following: - Livelihood impacts on the land owners if the holdings that remain are sub-optimal, or owners are rendered landless; - Additional livelihood assistance to vulnerable households, or women headed households, with skill trainings or entrepreneurship support, etc. under the LRP; - Impacts on land users or regular agricultural labourers affected - The general community being impacted due to access restrictions/easements; Other impacts on private land owners. Preference to members of the families rendered landless or with sub-optimal holdings post selling land to the project for employment opportunities in the Construction/operation phase and/or small contracts; Timely sharing of project related information with all relevant stakeholders; Provision of Grievance Redressal Mechanism to all impacted stakeholders in order to raise and register their grievances. Residual Impacts After the implementation of these mitigation measures, the residual impact significance is expected to be Minor. Impact on private land sellers, agricultural labourers and community due to change Impact in land ownership and use Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Local Regional International Impact Extent Project villages Frequency Planning Phase Impact Magnitude Positive Negligible Small Medium Large Vulnerability of social Low Medium High Receptors Negligible Minor Moderate Major Impact Significance Significance of impact is considered Moderate. Residual Impact Positive Negligible Small Medium Large Magnitude Residual Impact Negligible Minor Moderate Major Significance www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 210 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report 6.4.4.2 Impact due to Patta Land Purchase Context and Receptors The Patta Land identified for the project comprises approximately 81.7 ha. and 73 Patta land holders are understood to be identified, some of whom would be impacted by the purchase. The Patta land is understood to be largely used for agriculture. As mentioned in Section 4.4.6.2 the Patta holders are typically from SC and ST communities that were granted Pattas by the Government by dint of their landlessness and vulnerability. Some Patta holders are using the lands for their own purpose (agriculture or grazing), while some Patta holders have sold of their lands in lieu of economic benefits from the sale, probably in times of distress (refer Section 4.4.6.2 for more details). Thus the impacts of negotiated purchase of Patta Lands shall be on Patta holders, non-recognised Patta owners (those who purchased rights to use Patta land through a verbal agreement without a legally documented sale of land by original and registered Patta holders), agricultural labourers engaged on the identified land parcels and the community affected due to access restriction to their assets or grazing land for livestock. Embedded/In built control RUMSL shall procure Patta land based on the MP Mutual Consent Land Purchase Policy 2014; To clarify, as stated in Section 2, the RAP-LRP will be prepared for all impacted families including those who are economically displaced. The LRP will also cover economic displacement impacts on agricultural labor, working on the procured/purchased patta land. An amount of INR 2 lakhs per MW has been envisaged to be provided to the local district collector to facilitate development activities in the area and these activities may range for skill development, training, restoration of local water bodies and other local development works. Impact significance The impact of change in land ownership and use which imposes restrictions to the identified Patta land and surrounding agricultural land is evaluated to be Moderate as the number of households to be impacted from the change is understood be higher for 81.7 ha. Patta land and the nature of change is irreversible. Additional Mitigation Measures Patta is being treated at par with ownership, for the land procurement process. Thus treatment of Patta Land holders will be similar to Private land owners and Patta holders shall be provided with either alternate land parcels with similar nature of productivity and financial assistance to prepare the land for cultivation or adequate compensation at twice the value of land and assets, as per MP Mutual Consent Land Purchase Policy, 2014; A Resettlement Action Plan-shall be formulated to cover economic displacement categories (subject to the qualifications stated under embedded controls) to address: - Livelihood impacts on the land owners if the holdings that remain are sub-optimal, or owners are rendered landless; - Additional livelihood assistance to vulnerable households, or women headed households, with skill trainings or entrepreneurship support, etc. under the LRP; - Impacts on land users or regular agricultural labourers affected - The general community being impacted due to access restrictions/easements; - Other impacts on patta land owners. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 211 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Preference to members (rendered landless or with sub-optimal holdings) of the families post selling land to the project for employment opportunities in the Construction/operation phase and/or small contracts; Additional safeguards to be addressed through the RAP-LRP for Patta Land owners, including verbal agreement and without documentation Timely sharing of project related information with all relevant stakeholders; Provision of Grievance Redressal Mechanism to all impacted stakeholders in order to raise and register their grievances. Residual Impact Significance After the implementation of these mitigation measures, the residual impact significance is expected to be Minor. Impact on Patta land owners (formal and informal), agricultural labourers and Impact community due to change in land ownership and use Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Local Regional International Impact Extent Project villages Frequency Planning phase Impact Magnitude Positive Negligible Small Medium Large Vulnerability of social Low Medium High Receptors Negligible Minor Moderate Major Impact Significance Significance of impact is considered Moderate. Residual Impact Positive Negligible Small Medium Large Magnitude Residual Impact Negligible Minor Moderate Major Significance 6.4.4.3 Impact due to LUPA of Government Land Context and Receptors The proportion of Government land identified for the project is approximately 90%. The various uses of Government land (discussed in Section 4.4.6.2) are encroachment and squatting by private and Patta land owners for agriculture, livestock grazing, cultivation of fodder lots for commercial purposes, etc. Thus, the stakeholders likely to be impacted by long lease of Government land by RUMSL are local community using the land for access to their assets and Common property resources, livestock owners whose Livestock grazes on the Government land for approximately 8 months in a year, and squatters and encroachers, who are not rightful users of the land, but their livelihoods will be affected due to non-availability of the land, that they have prepared by investing cost, for cultivation and are cultivating. The impacts caused due to procurement of Government land are detailed in Table 6.16. Embedded/ In built control There is a provision in the MP Land Revenue Code that a minimum of 2% of total agricultural land available in the Project villages must be secured for grazing of livestock, even after setting up of project. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 212 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Grazing rights on areas -Charnoi/charagah- designated in government records are not allotted for projects. However, in some villages, it may be the case that less than 2% land is available for grazing (charnoi/charagah) even before the project allotment. In such cases, the District Collector can designate other government land as charagah and charnoi, for grazing. However, the functional adequacy will be more a function of quality and access. Impact Significance The impact of long terms lease of Government land by RUMSL imposes restrictions to the current economic activity, impacts access and easements for the community and affects livestock grazing significantly, as it is a large area (962.5 ha. approximately). Thus, the significance of this impact is evaluated to be Major as the number of households likely to be impacted from the change is understood be higher and the nature of change is irreversible. Additional Mitigation Measures Provision for alternate grazing land for livestock shall be made near the project villages or confirmation of adequacy of remaining grazing land, to be confirmed during the RAP survey (including the assessment of access and quality of the remaining area); Development of a program to include grazing area improvement and fodder intensification (cultivation) in designated areas, as agreed with the Tehsil office and the local dependent community of graziers. This may include the development of community fodder lots under the Livelihood restoration activity in the area as part of Resettlement Action Plan. This, if feasible, shall serve the purpose of improving the quality of the grazing land, ensuring access and as an income generating activity for people losing land based livelihoods. The project developer is also encouraged to explore identifying unused areas within the solar park boundary and a part of the area with solar panels (10% area), for fodder cultivation, or controlled and managed open grazing of goats, or agriculture (selected crops), to explore the potential of the agreement of RUMSL and in partnership with domain specialist agencies and local . Provision of easements shall be maintained in order to not sever the access to CPRs for the community; Preference of members of Project affected households (PAH), as identified in the RAP, in employment opportunities during construction phase; In case of Squatters and encroachers, RUMSL shall serve a three months advance notice to the project affected persons (PAPs) to manage the potential losses to standing crops; In case of crop losses ensuing from project activities, RUMSL shall pay compensation for crops, as defined in the RAP (entitlement matrix); Timely sharing of project related information with all relevant stakeholders in order to serve advance notice and reduce the extent of impacts and losses; Provision of Grievance Redressal Mechanism to all impacted stakeholders in order to raise and register their grievances. Residual Impact Significance After the implementation of these mitigation measures, the residual impact significance is expected to be Moderate. Impact Impact due to LUPA of Government land Impact Nature Negative Positive Neutral www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 213 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Local Regional International Impact Extent Project villages Frequency Planning Phase Impact Magnitude Positive Negligible Small Medium Large Vulnerability of social Low Medium High Receptors Negligible Minor Moderate Major Impact Significance Significance of impact is considered Major. Residual Impact Positive Negligible Small Medium Large Magnitude Residual Impact Negligible Minor Moderate* Major Significance *If may provide positive benefits to the community over the life of the project, further reducing the residual impact significance to minor or negligible. 6.4.5 Construction Phase Impacts 6.4.5.1 Temporary occupation of Land for Construction Phase Activities Context and Receptors The construction period for the Neemuch Solar Park is expected to last for about 21 months, during which various construction related activities will be in progress and would may additional land (apart from identified land for project) for the following activities: Setting up of Labour Camps; Safety Setbacks; Storage areas for construction material; Parking area for vehicles; Other construction related temporary land requirements, etc. The additional land for temporary activities like setting up of a number of labour camps for the required duration, land for safety setbacks, storage areas, parking areas and other construction related requirements, if required, would be met by renting/ leasing additional land from the local community; however would lead to increased disruptions in access for local community. If all these activities can be accommodated with the Project footprint, the impacts from temporary land lease-rent, will be avoided. The impacts caused due to temporary occupation of private land for construction phase activities are detailed in Table 6.16. Impact Significance The significance of this impact is evaluated to be Minor based on the nature, duration and extent of the activity. Additional Mitigation Measures Provision of adequate lease on rental amounts to the land owners shall be ensured by RUMSL; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 214 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report The land leased/ rented shall be restored to its original state (or made better) at the time of handing it back to the owners; Provision of compensation for the loss of livelihoods to the users of the land required for temporary use as this will temporarily economically displace them; Timely dissemination of project related information with all relevant stakeholders, in order to serve advance notice and reduce the extent of losses/ impacts; Provision of Grievance Redressal Mechanism to all the key stakeholders in order to raise and register their grievance. Residual Impact Significance After the implementation of these mitigation measures, the residual impact significance is expected to be Negligible. Impact Impact due to temporary occupation of land during construction phase Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Local Regional International Impact Extent Limited to Project Footprint area and Project villages Frequency Construction Phase Impact Magnitude Positive Negligible Small Medium Large Vulnerability of social Low Medium High Receptors Negligible Minor Moderate Major Impact Significance Significance of impact is considered Minor. Residual Impact Positive Negligible Small Medium Large Magnitude Residual Impact Negligible Minor Moderate Major Significance 6.4.5.2 Community Health and Safety Context and receptor The receptors for impacts on community health and safety include the local community within the Study Area who may be present in the vicinity of the project, for grazing purposes or while commuting as well as the workers engaged during construction phase. The construction phase activities, laying down of Transmission Line towers and construction of substations and movement of material and personnel may result in impacts on the health and safety of the community. These activities will involve the use of machinery and power Transmission Lines. Furthermore, the movement of material and personnel via the access roads may result in damage to human life or livestock due to accidents, especially during night time. Additionally, the establishment of labour camps for workers from outside areas/ states may lead to spread of infections and diseases due to interactions between the migrant workers and local community, improper management of waste and underdeveloped sanitation facilities, etc. The situation of infections become grim, especially with the arrival of Covid 19 and due to which special provisions for engagement and management of migrant labourers will have to be ensured. The Community health and safety impacts in construction phase are detailed in Table 6.16. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 215 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report The embedded controls, as derived from the ESMF comprise the following: Alternate arrangement for fuel wood, heating and cooking should be made to meet fuel wood requirement of the labour; Migrant workforce should be prohibited from disturbing the flora, fauna including hunting of animals, Wildlife hunting, poaching and tree felling. Treated Water shall be made available at Site for Labour drinking purpose. Proper Impact Significance Based on the above understanding, the impact is assessed to be Moderate. Additional Mitigation Measures In addition to the embedded measures, the following risk mitigation measures are suggested to minimize the potential risks/hazards to community: Responsibilities of RUMSL Ensuring stakeholder engagement through the project cycle and provision of an effective Grievance Redressal Mechanism to avoid, mitigate and mange conflicts and disagreements; As part of the stakeholder engagement and information disclosure process, the community will be provided with an understanding of the activities to be undertaken and the precautions to be taken for safety; RUMSL shall maintain safe distance of project components from schools, hospitals, etc. in order to avoid interactions with community hotspots and hence risks of accidents; The Contractors to be engaged by RUMSL shall be informed of the EHSS practices that are expected from its workers during the construction phase engagement. Obligations like preparation of Traffic Management Plan, Local Procurement Plan, EHSS Plan (including for managing COVID 19 related risks), etc. shall be communicated to them at the time of selection and appropriate clauses should be included at the time of contract finalization; camps in terms of provisions, sanitation facilities, etc. thus limiting the probability of diseases and infections in the local community on account of improper management of waste; RUMSL shall put in place a grievance redressal mechanism to allow community members to report any concern or grievance related to project activities. The contractors engaged shall also be contractually required to put in place a similar mechanism to deal with concerns raised by the community (or external stakeholders) and the workers engaged during construction phases. Contractors The contractor shall induct migrant workers on health and safety awareness and practices to be followed at site during construction phase; The contractors shall cordon off areas that are under construction and put relevant safety signs to restrict movement of local community members or workers engaged at site, which may become safety threats; The Contractors shall prepare a Traffic Management Plan and traffic movement due to the project in the area will be regulated to ensure road and pedestrian (including livestock) safety; Additionally, training on vehicular safety shall be organised for the transport workers. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 216 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report The movement of workers from the project site and labour camps shall be regulated and similarly the project boundary and labour accommodation to check for unauthorized visitors/ outsiders entering the site in order to avoid any possible interactions leading to conflicts or tensions between the migrant workforce and host community; Contractors shall ensure that regular health check-ups are conducted for the construction phase workers (especially migrant workers staying in temporary labour accommodation) and any major illnesses are reported in the Block level medical authorities at the earliest; The labour accommodation should be clean and hygienic and disposal of kitchen waste and food waste shall be done on a daily basis in an appropriate manner; Proper sanitation facilities shall be provided, taking into account the number of labourers that will be using the facilities, both at construction site, as well as labour accommodation; Residual Impact Significance The significance of impact will be reduced to minor on implementation of mitigation measures. Impact Impact on Community Health and Safety Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale Limited to Project Footprint area, Project villages and Study area for transportation related activities Frequency Construction Phase Impact Magnitude Positive Negligible Small Medium Large Resource/Receptor Sensitivity Low Medium High Impact Significance Negligible Minor Moderate Major Significance of impact is considered Moderate Residual Impact Positive Negligible Small Medium Large Magnitude Residual Impact Negligible Minor Moderate Major Significance Significance of Residual Impacts is considered as Minor 6.4.5.3 Stress on Community Resources Context and Receptors The community resources like water, forest resources and roads will be the prime receptors for the impact caused by project activities. The project related construction activities are understood to span across 21 months and would require water for drinking, cooking and sanitary purposes. As per DPR, construction water requirements will be met through tanker water and no ground water will be abstracted. The water consumption during construction phase will put stress on water resources used for tanker water supply, which are presently not known (Refer Section 6.2.2 for details). Additionally, the impact on forest resource can take place due to labour influx and their unregulated movement around the Project footprint area and project villages. The roads used by the community would also face wear and tear due to transportation of heavy machinery and material, which shall lead to early damages than their anticipated life span. The Impacts due to stress on community resources in construction phase are detailed in Table 6.16. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 217 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Impact Significance The significance of impact from the above activities is understood to be Minor. Additional Mitigation Measures RUMSL responsibilities There will be a worker Code of Conduct defined by RUMSL that prevents workers and contractors from using the local resources like water, forest, which will be shared with private SPDs for onward sharing with sub-contractors and its workers; An induction session will be organised for the migrant workers where they will be sensitized on The contractor shall be asked to use Tanker water supply during the summer months, which are dry months in which water scarcity issues are reported by the community; Periodic maintenance activities for roads used for transportation of goods for the project shall be the undertaken by RUMSL, through its contractors; Provision of Grievance Redressal Mechanism to all the key stakeholders in order to raise and register their grievance on misuse of locally available resources. Residual Impact Significance The significance of impact will be reduced to Minor (for water) to Negligible on implementation of mitigation measures. Impact Impact on Community Resources Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale Limited to Project Footprint area, Project villages and Study area for transportation related activities Frequency Construction Phase Impact Magnitude Positive Negligible Small Medium Large Resource/Receptor Sensitivity Low Medium High Impact Significance Negligible Minor Moderate Major Significance of impact is considered Minor Residual Impact Positive Negligible Small Medium Large Magnitude Residual Impact Negligible Minor Moderate Major Significance Significance of Residual Impacts is considered as Minor to Negligible 6.4.5.4 Impact on Employment and Entrepreneurship Opportunities Context and Receptors The construction phase will provide a boost to the local employment, as a higher number of unskilled labourers is required to be engaged for construction activities. Additionally, there would be some skilled labour required that would be brought in from other states (if not present in local area) that would also lead to spike in economic activity in the area, during construction phase. This would lead to better business opportunities for smaller vendors in the area owning petty shops, petty contractors firms, etc. for providing essential goods and services to the project. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 218 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Additionally, there would be increased demand for agricultural products, animal based food products, etc., that may require enhanced production of associated items and opportunities for traders. Impact Significance The significance of this impact is understood to be Moderate. Enhancement Measures The sourcing of local labour wherever possible should be made obligatory by RUMSL (through contractual provisions) for the Solar Project Developers and sub-contractors and in all major procurement activities; Preference should be given to the land losers and vulnerable population in the Project Villages, to the extent practicable; Employment of members of SC-STs and Women Headed households should be ensured by the Solar Project Developers through documented agreement with contractors/ sub-contractors; Engagement of local vendors, to the extent possible, for the goods and services required for the project during construction phase; The project proponent will establish a mechanism to audit subcontractors and suppliers with respect to compliance of utilizing local labour and resources; Provision of Grievance Redressal Mechanism to all the key stakeholders in order to raise and register their grievance with respect to information sharing related to jobs and opportunities for vendor-ship. 6.4.6 Operations Phase Impacts 6.4.6.1 Community Health and Safety Context and Receptors The Operations phase would have very limited activity at the project site as the construction phase would have been over and the scale of activity and workforce at the project footprint area would have reduced significantly. This would lead to less or negligible noise, lesser workers at site on near project villages, reduced traffic load (compared to construction phase) and the general material supply related traffic would reduce. However, the community shall still be a receptor of the impacts due to increased traffic, compared to the pre-project phase. There would be additional Transmission Lines installed/ erected and may create access issues for the community movement, if necessary precautions are not taken by the local residents. As discussed in Section 6.2.4, communities that are residing close to the Solar Park may experience the Heat Island Effect due to the expanse of the PV solar panels (based on local conditions, for a few days in the year), but this is understood to dissipate over a 300m distance. Impact Significance Based on the above understanding, the impact is assessed to be Minor. Additional Mitigation Measures In addition to the embedded measures, the following risk mitigation measures are suggested to minimize the risks/hazards of construction activities onsite: www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 219 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Where community residential clusters are closer to the project boundary, keep a safety setback (as relevant) to mitigate the heat island effect. Community sensitization sessions should be re-organised at the beginning of Operations phase, in order to mention about the new developments in the area and provided an understanding of the precautions to be taken for safety; sal Mechanism for the community shall still be in implementation to deal with any concerns of community health and safety, being raised by the local community. Residual Impact Significance The significance of impact will be reduced to negligible on implementation of mitigation measures. Impact Impact on Community Health and Safety Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale Limited to Project Footprint area Frequency Operations Phase Impact Magnitude Positive Negligible Small Medium Large Resource/Receptor Sensitivity Low Medium High Impact Significance Negligible Minor Moderate Major Significance of impact is considered Minor Residual Impact Positive Negligible Small Medium Large Magnitude Residual Impact Negligible Minor Moderate Major Significance Significance of Residual Impacts is considered as Negligible 6.4.6.2 Impact on Employment Context and Receptors The Operations phase would require much smaller workforce as compared to construction phase and the skillset of the required workforce shall be different. The Operations phase would require Engineers, Technicians to manage the Plant operations and amongst the requirement of semi-skilled workers in limited numbers for housekeeping and Security related jobs, on the payroll of RUMSL. Additionally, there may be some vacancies with the private Solar Project Developers (SPDs) that may have some local employment, if feasible. Impact Significance The significance of this impact is understood to be Minor. Enhancement Measures The private SPDs shall advertise the roles of Technical staff required during operations phases, in the local newspapers to enable hiring of competent people from nearby areas, to the extent feasible; Preference shall be given (to the extent feasible) to hire competent members from PAHs for semi- skilled jobs like housekeeping or Security Guards. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 220 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report 6.4.7 Impact on Indigenous Communities/ Vulnerable Groups Context and Receptors Vulnerability in the society is defined on the basis of the economic status of the households, and the difference in access to social, economic and political power between men and women. Thus households with limited landholdings and resources are relatively vulnerable to changes in the immediate surroundings, affecting their livelihoods. As discussed in Section 4.4.4, the Study Area is characterised by a SC population of 7.2% and ST 1 population of 18.4%. The majority of the ST population consists of Bhils and Rabaris, with a majority of Bhil tribe groups. While there is no caste based distinction reported in terms of habitation patterns, practices, etc., the SC and ST households are generally reported to have lesser land holding than the general population. Table 6.17 Demographic Profile for Neemuch Solar Park Village Name Total Population No of households ST Population Bardawada 399 77 22 Kawai 527 106 105 Badi 1121 257 249 Source: Census of India 2011, PCA. Of the three villages in Neemuch Solar Park footprint, only Badi village is reported to have multiple hamlets. The villages of Kawai and Bardawada were reported to be a single compact settlements; while Badi village has four hamlets, the details of which are presented below. Table 6.18 Hamlets within Badi village with High Bhil population Hamlets of Badi Number of households in hamlet* Bhil HHs in Hamlet Mama Basti 40 ~40 Sutaru ki Badi 65 0 Meetro ka Jhopda 45 0 Jhero ka Jhopda 35 ~35 Source: Consultation with Badi Sarpanch While the land for the project is a combination of private, Government and Patta Lands, the details of the profile of private and patta land owners, in terms of financial and social profile are presently not available. The land identified for the project is used by the local community for grazing purposes, and does not have any specific SC/ST group usage in terms of grazing, cultivation, water body and cultural/religious property. However, since this is understood from the baseline that SC and ST households on an average has limited landholdings compared to other caste groups, the probability of members of these groups working as agriculture labourers is higher. Additionally, this groups is also understood to possess ownership of a relatively higher number of sheep and goats, compared to other groups in the community. Out of the three phases, the Indigenous Communities and vulnerable groups are understood to be impacted the most during Planning phase of the project, on account of loss of livelihoods linked to land being procured for project. Since these agricultural workers are not rightful owners or users of land as per records, the project related compensation measures would not be directly reaching out to this group or may be reaching in a diminished manner. 1 ST community is considered akin to Indigenous population in India generally; however there are a number of ST groups present in India, some of whom have merged with the mainstream population in terms of habitation and occupational patterns, language, etc., while certain groups continue to follow distinguished cultural practices. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 221 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Embedded/In Built Control As part of the Community Development Activities in the local villages, the Project proponent will identify specific programmes for SC/ST groups and vulnerable groups. Impact Significance Based on the profile of the stakeholder group, the impact significance is assessed to be Moderate. Additional Mitigation Measures In addition to the embedded measures, the following additional mitigation measures are identified: To identify and assess the extent of impacts on this group, a review of the scope of FPIC and IPP, in terms of remaining impacts on IP groups, their traditional livelihoods and customary land use; including dependence on natural resources, will be undertaken; Based on this review, the target groups for the FPIC process will be identified in terms of villages and number of households in each village. It should be noted that the exact number of households may be identified only post the site walk through and social mapping. Review the consultation process carried out as part of allotment process of unoccupied government land through discussions with personnel from the Land Division of District Magistrate office to access the Gram Sabha resolutions as part of the land allotment process. Relevant details in relation to the Gram Sabha Resolution will be collected to understand implications for any legacy issues. As part of the stakeholder engagement, ensure adequate representation of the Indigenous groups and vulnerable groups, and specific engagement activities are undertaken with these groups; Ensure that the grievance management mechanism established is accessible to these groups. Residual Impact Significance The significance of impact will be reduced to Minor after implementation of mitigation measures suggested. Impact Indigenous Communities/Vulnerable Groups Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale The SC/ST Community and vulnerable groups may be negatively impacted by the project, in case the economic or developmental opportunities generated by the project are not equally accessible to them in comparison to other social groups. Frequency Planning and Construction Phase Likelihood Possible Impact Magnitude Positive Negligible Small Medium Large Resource/Receptor Sensitivity Low Medium High Impact Negligible Minor Moderate Major Significance Significance of impact is considered to be Moderate Residual Impact Positive Negligible Small Medium Large Magnitude Residual Impact Negligible Minor Moderate Major Significance Significance of Residual Impacts is Minor www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 222 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report 6.4.8 Impact on Women 6.4.8.1 Construction Phase Context and Receptors As per the list of potential land owners identified for the Private and Patta land (provided by RUMSL on 3rd June 2020), the break-up of land ownership (in terms of area and number) of male and female land owners is provided below. Table 6.19 Gender disaggregated data for identified land owners (in terms of land area) Badi Village (In ha.) Kawai Village (In ha.) Bardawada Village (In ha.) Total Private Patta Private Patta Private Patta 16.7 Female 0.86 0 3 5.224 0.62 7 (13.5%) 85.5 Male 15.6 10.8 10.942 21* 4.466 43.71 (86.5%) Total 16.46 10.8 13.942 26.224 5.086 50.71 123.2 Table 6.20 Gender disaggregated data for identified land owners (in terms of no of owners) Badi Village Kawai Village Bardawada Village Total No. of Land Owners Private Patta Private Patta Private Patta Females 2 0 3 6 1 6 18 (14.7%) Males 28 8 9 16* 5 37 104 (85.3%) Total 30 8 12 22 6 43 122 As per the data provided there are 14.75% female private land owners and 12 female Patta land owners out of 48 private land owners and 73 Patta land holders that are identified for the project. This list is for a larger portion of land that has been identified for the Neemuch Solar Park (1092.7 ha), whereas the land to be used for the project (1065.7 ha) is lesser and the actual number of land owners to be impacted from the identified will be confirmed during the RAP survey. For the purpose of this assessment, the broader list is used which states that out of the private and patta land identified for the project, the combined ownership by women (Private +Patta land) is 13.5% overall with 5.2% in Badi village, while 26.4% in Kawai and 14.2% Bardawada villages. As stated in Section 4.4.11, women from most social and caste groups, take equal responsibilities of working on agricultural fields owned by the household, taking care of domestic chores of cooking, cleaning, fetching water from community water points to their respective houses, caretaking of children and elderly as well as tending to livestock owned by the family. Women take care of domestic livestock management responsibilities but are not engaged in grazing of livestock outside the household premises. Male members of the household are responsible for livestock grazing near the villages, sale and purchase of livestock, livestock feed and by products. There have not been any cases reported for women working as construction labourers or in any enterprise outside their respective villages. On the agricultural fields, women are involved in cutting, sowing, threshing, watering, and collecting fuel wood however this is usually unpaid labour by women on the fields owned by their families, while are paid an amount of INR 100-200 per day when they www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 223 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Ownership of land and assets by women is also understood to be minimal and in cases where women own land legally, the management of the same in terms of sale, purchase or usage is largely decided by men, with limited or no consultations with women. The proceeds from sale of land and its usage is also usually discussed within households but the final decision on usage of money is taken by male members of the household. The Women headed households (both joint as well as independent, as discussed in detail in Section 4.4.11) face additional risks of not being included in negotiations, or other key meetings due to prevailing cultural norms and may not therefore receive the benefits and advantages compared to those who do participate. Thus they become a little more vulnerable in cases of sale of land for the project, where there is a chance that the proceeds from sale of land do not reach them. Additionally, the probability of access to jobs during the construction phases is also sometimes skewed in the favour of males, thus making these households more vulnerable. Women and girls are disproportionately at risk in terms of safety (gender based violence, harassment, curtailed movement, reduced access to resources), with the arrival of migrant labourers in the construction phase and their accommodation being planned near the project villages. Embedded/In Built Control As part of the Community Development Activities in the local villages, the Project proponent will identify specific programmes for women groups and Women Headed households. The migrant workforce engaged during construction phase shall be inducted in the initial phases community, not causing disturbances to the community, etc. Provide alternative arrangements for land, and create access for ease of use to collect fuelwood, and fodder. Impact Significance Based on the above the impact after implementing the embedded controls is assessed to be Moderate. Additional Mitigation Measures In addition to the embedded measures, the following additional mitigation measures are identified: A Gender Action Plan is being prepared for the Project where women focussed engagement is detailed in Appendix F; Ensure that the employment of women from vulnerable households is done for the project and efforts are made for development of women owned enterprises in the area, from where procurement for project related needs is undertaken; Undertake a profiling of the various social groups in the Study Area, to understand the individual needs and concerns of the various women belonging to different social groups and design community development and CSR programmes in light of the same; As part of the stakeholder engagement, RUMSL shall ensure and communicate to the private Solar Project developers, that Women focussed discussions are conducted in order to ensure adequate representation of the Women and their needs and concerns in order to design specific engagement activities; Include provisions of coverage of women under skill training and Financial literacy training programs, as part of livelihood restoration activities by the project or through developmental programs of SPDs; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 224 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Provision of Grievance Redressal Mechanism to all the stakeholders in order to raise and register their grievances. Residual Impact Significance The significance of impact will be reduced to Minor after implementation of mitigation measures suggested in construction phase Impact Women in the project villages Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale The women in the Project villages are understood to be impacted during Planning and construction phases Frequency Planning and Construction Phases Likelihood Possible Impact Magnitude Positive Negligible Small Medium Large Resource/Receptor Sensitivity Low Medium High Impact Negligible Minor Moderate Major Significance Significance of impact is considered to be Moderate Residual Impact Positive Negligible Small Medium Large Magnitude Residual Impact Negligible Minor Moderate Major Significance Significance of Residual Impacts is Minor 6.4.8.2 Operations Phase Context and Receptors The nature of impacts are envisaged on women in the Operations phase will vary from construction phase as the extent of presence of outsiders and migrant population in the area would have reduced along with risk to their safety. Furthermore, vendor-ship opportunities in Operations phase, which might render them in search of livelihood options again. Embedded / In built Measures The duration (months) and nature of employment (temporary) shall be communicated in advance to this group in order to manage impacts due job reductions. Impact Significance Based on the above the impact after implementing the embedded controls is assessed to be Minor. Additional Mitigation Measures The SPDs shall ensure appropriate measures for hiring of women, as per required skill set, are put in place, during the Operations phases. Residual Impact Significance The significance of impact will be reduced to Negligible in operations phase. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 225 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Impact Women in the project villages Impact Nature Negative Positive Neutral Impact Type Direct Indirect Induced Impact Duration Temporary Short-term Long-term Permanent Impact Extent Local Regional International Impact Scale The women in the Project villages are understood to be impacted during Planning and construction phases Frequency Operations Phase Likelihood Possible Impact Magnitude Positive Negligible Small Medium Large Resource/Receptor Sensitivity Low Medium High Impact Negligible Minor Moderate Major Significance Significance of impact is considered to be Minor Residual Impact Positive Negligible Small Medium Large Magnitude Residual Impact Negligible Minor Moderate Major Significance 6.5 Summary of pre and post mitigation Impact Significance The table below presents the summary outcome of the comprehensive assessment of identified impacts pre and post mitigation during various phases of the Project. Table 6.21 Summary of Impacts Category Impact Significance (without Impact Significance (post- mitigation measures) mitigation) Planning Phase Impact due to private land purchase Moderate Minor Impact due to Patta land purchase Moderate Minor Impact due to LUPA of Government Land Major Moderate Construction Phase Land use and Land cover Moderate Moderate Soil compaction and erosion Minor Negligible Waste generation and soil contamination Minor Minor Topography and Drainage Minor Minor Water resources and availability Major Major to Moderate Water quality Minor Minor Ambient air quality Minor Minor to Negligible Ambient noise quality Moderate Minor Occupational health and safety Minor Minor Habitat Modification and Loss Minor Minor Impacts due to construction Activities Minor Minor Ecosystem Services Minor Minor Impact due to temporary occupation of Land Minor Negligible Community Health and Safety Moderate Minor Impact due to Stress on Community Minor Minor to Negligible Resources Impact due to Noise nuisance and Dust Minor Negligible Impact on Employment and Moderate (positive benefits) Entrepreneurship Opportunities www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 226 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL IMPACTS Final ESIA Report Category Impact Significance (without Impact Significance (post- mitigation measures) mitigation) Operation Phase Soil Environment Minor Minor Water resources and availability Major Major to Moderate Health and safety Minor Minor to Negligible Collision and Electrocution risks Minor Negligible Community Health and Safety Minor Negligible Impact on Employment Minor Minor Impacts on specific stakeholder categories Impact on Indigenous Communities Moderate Minor (Construction and Operations Phases) Impact on Women (Construction Phase) Moderate Minor Impact on Women (Operations Phase) Minor Negligible www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 227 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ANALYSIS OF ALTERNATIVES Final ESIA Report 7. ANALYSIS OF ALTERNATIVES An analysis of probable alternatives for the chosen technology and location of Project site along with other similar factors that contribute to the Project as a whole has been carried out. The following scenarios have been taken into consideration: Project vs No Project scenario; Alternate Source for Power Generation; Location for Project Site. 7.1.1 Project vs No Project scenario The state of Madhya Pradesh is endowed with high solar radiation with around 300 days of clear sun. The state offers good sites having potential of more than 5.5 kWh/ sq.m/per day for installation of Solar based power projects. State wise targets by MNRE requires MP to achieve 5,675 MW of Solar power by 2022. As on July 2018, the State has commissioned solar capacity of 1,358 MW and under- construction capacity of 685 MW. Renewable Purchase Obligation (RPO) target and current status for the state of Madhya Pradesh is as presented in Figure 7.1 below. Figure 7.1 RPO target and compliance status of Madhya Pradesh Source: Detailed Project Report, 500 MW Neemuch Solar Park, July 2020 The proposed project will enable state to meet their target for solar power and renewable purchase obligations. In addition, the clean power generated by these solar projects play a role for reducing -end technical investments and empower local communities. 7.1.2 Alternate Source for Power Generation There are different modes for power generation depending upon the source of energy such as coal energy, natural gas energy, wind energy, solar energy, nuclear energy, geothermal energy and waste to energy. Solar energy is the eco-friendly mode of power generation providing a non-polluting source of energy that can displace greenhouse gas emissions from conventional power. Besides this: Negligible emissions from the operation (mainly vehicular emissions); No fuel required for operation of the Solar Park; The gestation time required for solar energy projects is comparatively less than conventional power generation and requires short lead time to design, install, and start-up. Manufacturing of parts, related up-stream and downstream activities in a typical solar energy development projects, are associated with emissions due to consumption of fossil fuels which contributes to Green House Gases (GHGs). The lifecycle emissions from various power sources is shown in Table 7.1. ww.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 228 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ANALYSIS OF ALTERNATIVES Final ESIA Report Table 7.1 Life-cycle Emissions from Power Sources LCA Emissions Wind Solar Nuclear Coal (g CO2 equivalent/kWh) Implementation 13.7 37.5 1.2 3.6 Operation 4.7 12.0 12.4 918.8 Decommissioning 0.6 0.5 0.4 52.2 Total 19 50 14 975.3 Source: Report on developmental impacts and sustainable governance aspects of renewable energy Projects, Ministry of New and Renewable Energy, 2013 As evident of Table 7.1 above, the emission of CO2 per kWh of energy generated from a Coal based power plant is more than that of the emission from a solar based power plant. The only emissions from the Renewable energy technologies are the emissions from fossil sources used in the production and manufacturing of equipment, waste disposal during construction, recycling etc. These life-cycle emissions are significantly lower as indicated in the table above. The advantages and disadvantages of various power generation systems are shown in Table 7.2 below. Table 7.2 Environmental Advantages and Disadvantages of Power Generation System Mode Disadvantage Advantage Thermal Power Plant High fossil fuel consumption. Large scale production potential Large quantities of water requirement Moderate gestation period for cooling Relatively inexpensive High volume of emissions from Wider distribution potential operation Accumulation of fly ash (in case of coal powered installations) Upstream impact from mining and oil exploration GHG emission estimated as 228gCeq/kWh Hydropower Plant Site specific, dependent on GHG emission estimated as low as reservoir/river etc. 1.1gCeq/kWh for run of river Projects Downstream impact on flow Long gestation period Acute and chronic social and ecological impacts Nuclear Power Availability of fuel source Cheaper power generation Hazards associated with radioactive GHG emissions as low as material 2.5gCeq/kWh High cost of Project Long gestation period Risk of fallout and meltdown scenarios and its impacts on the local populace and environment. Wind Power Overall land requirement is large Pollution levels are insignificant Site specific (associated to wind Inexpensive power generation pattern) Inexhaustible source Expensive installation GHG emissions as low as 2.5gCeq/kWh for the Production Chain Solar Power Large land requirement Pollution levels are insignificant Site specific to solar insolation Inexpensive power generation Expensive installation Inexhaustible source Concrete foundation on larger area GHG emissions as low as 8.2gCeq/kWh for the Production Chain ww.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 229 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ANALYSIS OF ALTERNATIVES Final ESIA Report Source: International Atomic Energy Agency (IAEA) Table 7.3 Green House Emissions from Different Electricity Production Chains Technology Mean tonnes (CO2e/GWh) Low tonnes (CO2e/GWh) High tonnes (CO2e/GWh) Lignite 1054 790 1372 Coal 888 756 1310 Oil 733 547 935 Natural Gas 499 362 891 Solar PV 85 13 731 Biomass 45 10 101 Nuclear 29 2 130 Hydroelectric 26 2 237 Wind 26 6 124 Source: World Nuclear Association (WNA); http://www.world- nuclear.org/uploadedFiles/org/WNA/Publications/Working_Group_Reports/comparison_of_lifecycle.pdf Further to the above mentioned reasons, it can be conclude that: The Project is environment friendly with minimal greenhouse gas emissions; It is the most feasible choice of power generation in the State of Madhya Pradesh; and It will contribute towards the state of Madhya Pradesh attaining self-sufficiency in power supply. 7.1.3 Location for Project Site 7.1.3.1 Availability of Solar Radiation Solar Projects are non-polluting energy generation Projects, which are site specific and dependent on the availability of solar irradiance resource. Solar irradiance mapping, in India is the responsibility of the Solar Energy Centre (SEC) of India and the National Renewable Energy Laboratory (NREL) of the United States of America as part of the initiatives of the U.S.-India Energy Cooperation /Partnership to Advance Clean Energy (PACE), which is mapped and quantified based on which potential areas that are notified by the SEC, based on hourly data. Based on the review of data obtained from The US National Aeronautics and Space Administration (NASA), NREL, Meteonorm; the average daily and monthly Global Horizontal Irradiance (GHI) values at Neemuch are presented in Table 7.4 below. Table 7.4 Daily and Monthly GHI at Neemuch Solar Park Site Month GHI (kWh/m2/ day) GHI (kWh/m2/ month) NASA NREL Meteonorm 7 NASA NREL Meteonorm 7 January 4.34 4.42 4.16 135 137 129 February 5.11 5.41 5.43 143 151 152 March 5.91 6.42 6.29 183 199 195 April 6.48 7.05 6.93 194 212 208 May 6.53 7.14 7.00 202 221 217 June 5.91 6.46 6.07 177 194 182 July 4.55 5.29 5.03 141 164 156 August 4.19 5.00 4.71 130 155 146 September 5.09 5.80 5.57 153 174 167 October 5.09 5.53 5.35 158 172 166 ww.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 230 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ANALYSIS OF ALTERNATIVES Final ESIA Report Month GHI (kWh/m2/ day) GHI (kWh/m2/ month) November 4.49 4.58 4.37 135 138 131 December 4.07 4.16 4.06 126 129 126 Annual Average 5.14 5.60 5.41 156 170 165 Source: Detailed Project Report, 500 MW Neemuch Solar Park, July 2020 The site selected has average Global Horizontal Irradiance of 5.77 kWh/m 2/day. and annual GHI of more than 1876 kWh/m2 is observed at the project site which is appropriate for a Solar PV project development. 7.1.3.2 Availability of land During Project conceptualization stage, RUMSL had identified three locations for establishment of Solar Park in Neemuch District, viz. Singoli Tehsil (final selected site), Jiran Tehsil and Rampura Tehsil. One of the key requirement for Solar Park is availability of contiguous land parcels. At Jiran and Rampura sites, majority of large size government land parcels available in cluster were allotted to forest department. In addition, at Rampura site, other larger area land parcels were allotted to Gandhi Sagar Dam. At Neemuch site, clusters of government contiguous land parcel are available. Figure 7.2 Map Showing Initially Identified Locations for Solar Park Source: Knight Frank report, 2017 The selected Project site has following other location advantages: Site with high solar irradiation; ~ 90% of Land area is government land; Most of the land parcels selected are scrubland with barren rocky surfaces with sparse vegetation; ww.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 231 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ANALYSIS OF ALTERNATIVES Final ESIA Report No physical displacement for Project; No ecological sensitive receptor such as National Parks, Wildlife Sanctuary, within 5 km radius; There are no places of Archaeologically Important Places (ASI recognized); There exists no major obstacles around the site in the form of trees, buildings etc. that could lead to near shading; and Site is approachable through State Highway 9A and National Highway (NH) 76 connecting Kota and Chittorgarh. ww.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 232 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT Final ESIA Report PLAN 8. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN The purpose of an Environmental and Social Management Plan (hereinafter referred as ESMP) is to ensure that social and environmental impacts, risks and liabilities identified during the ESIA process are effectively managed during the construction and operation of the proposed Project. This is in accordance to MNRE Environmental and Social Management Framework, February, 2017, which emphasizes the importance of managing social and environmental performance through the lifecycle of the Project. 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. The ESMP describes the mitigation measures for all the identified potential impacts associated with the proposed project during its construction and operation phases. 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 RUMSL, EPC contractor, workers (including sub-contractors), local community and other stakeholders. RUMSL have an obligation to ensure compliance to all the commitments towards Environment, Social, Health and Safety Standards while executing all the project related activities for the proposed project. 8.1 Environmental and Social Management Plan This section outlines the potential impacts, mitigation measures, monitoring and management responsibilities during construction and operation phases of the Project. ESMP measures already embedded/ in-built are not included in the ESMP presented in Table below. As a part of ESMP specific management plans including waste management plan, water management plan, occupational health & safety plan, disaster management and emergency response plan, contractor and labour management, gender action plan and stakeholder engagement plan has also been prepared for the project which are provided in Appendix F. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 233 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Table 8.1 Planning Phase ESMP Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Land Procurement Impacts due to Private land RUMSL - The private land sellers should be provided with either purchase alternate land parcels with similar nature of productivity and financial assistance to prepare the land for cultivation or adequate compensation at twice the value of land and assets, as per MP Mutual Consent Policy, 2014; A Resettlement Action Plan- Livelihood Restoration Plan shall be formulated to address the following: - Livelihood impacts on the land owners if the holdings that remain are sub-optimal, or owners are rendered landless; - Additional livelihood assistance to vulnerable households, or women headed households, with skill trainings or entrepreneurship support, etc. under the LRP; - Impacts on land users or regular agricultural labourers affected - The general community being impacted due to access restrictions/easements; Other impacts on private land owners. Preference to members of the families rendered landless or with sub-optimal holdings post selling land to the project for employment opportunities in the Construction/operation phase and/or small contracts; Timely sharing of project related information with all relevant stakeholders; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 234 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Provision of Grievance Redressal Mechanism to all impacted stakeholders in order to raise and register their grievances. Impact due to Patta land purchase Patta is being treated at par with ownership, for the land RUMSL - procurement process. Thus treatment of Patta Land holders will be similar to Private land owners and Patta holders shall be provided with either alternate land parcels with similar nature of productivity and financial assistance to prepare the land for cultivation or adequate compensation at twice the value of land and assets, as per MP Mutual Consent Policy, 2014; A Resettlement Action Plan-Livelihoods restoration Plan is required to be formulated to address: - Livelihood impacts on the land owners if the holdings that remain are sub-optimal, or owners are rendered landless; - Additional livelihood assistance to vulnerable households, or women headed households, with skill trainings or entrepreneurship support, etc. under the LRP; - Impacts on land users or regular agricultural labourers affected - The general community being impacted due to access restrictions/easements; Other impacts on private land owners. Preference to members (rendered landless or with sub- optimal holdings) of the families post selling land to the project for employment opportunities in the Construction/operation phase and/or small contracts; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 235 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Additional safeguards to be addressed through the RAP- LRP for Patta Land owners; Timely sharing of project related information with all relevant stakeholders; Provision of Grievance Redressal Mechanism to all impacted stakeholders in order to raise and register their grievances. Impact due to LUPA of RUMSL - Provision for alternate grazing land for livestock shall be Government Land made near the project villages or confirmation of adequacy of remaining grazing land; Development of community fodder lots shall be explored as a Livelihood restoration activity in the area as part of Resettlement Action Plan. This, if feasible, shall serve the purpose of augmentation of grazing land and as an income generating activity for people losing land based livelihoods. Provision of easements shall be maintained in order to not sever the access to CPRs for the community; Preference of members of Project affected households (PAH) in employment opportunities during construction phase; In case of Squatters and encroachers, RUMSL shall serve a three months advance notice to the project affected persons (PAPs) to manage the potential losses to standing crops; In case of crop losses ensuing from project activities, RUMSL shall pay compensation for crops, at full replacement cost; Timely sharing of project related information with all relevant stakeholders in order to serve advance notice and reduce the extent of impacts and losses; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 236 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Provision of Grievance Redressal Mechanism to all impacted stakeholders in order to raise and register their grievances. Impact on Women RUMSL along with SPDs Monthly reports on A Gender Action Plan shall be prepared for the Project number of women where women focussed engagement shall be detailed; engaged in the project Ensure that the employment of women from vulnerable activities households is done for the project and efforts are made for development of women owned enterprises in the area, from where procurement for project related needs is undertaken; Undertake a profiling of the various social groups in the Study Area, to understand the individual needs and concerns of the various women belonging to different social groups and design community development and CSR programmes in light of the same; As part of the stakeholder engagement, RUMSL shall ensure and communicate to the private Solar Project Developers, that Women focussed discussions are conducted in order to ensure adequate representation of the Women and their needs and concerns in order to design specific engagement activities; Provision of Grievance Redressal Mechanism to all the stakeholders in order to raise and register their grievances. Water Resources SPD - As part of project designing, SPD shall consider the rainwater harvesting ponds in the open area depending on the topography, slope, natural drainage etc. Accordingly infrastructure such as drains/ piping system/ size of pond etc. shall be designed. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 237 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Similarly, in case water is sourced from surface water bodies, infrastructure requirements shall be identified and planned in project design. Table 8.2 Construction Phase ESMP Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Site preparation - Site Change of topography Project designing shall be done in a way to utilize existing topography EPC Contractor/ Sub- Monthly Report to clearing, excavation and disturbance to to maximum; contractor RUMSL and levelling drainage pattern. Project shall ensure to avoid any unnecessary changes in the topography especially during the preconstruction and construction phase; Micro drainage channel should be particularly avoided when constructing access roads or planning the Transmission Line pathway in order to ensure no change to the topography of the area. Habitat Modification and EPC Contractor/Sub Monthly Report to Larger mature trees with significant height and girth should be Loss Contractor in association RUMSL Planning avoided to the extent possible when construction the Solar Park. The with RUMSL Planning Team trees can be incorporated into the solar compound construction but Team avoided during the siting of individual solar modules. The Kawai Pond and Bardawada Pond is located within 500m and 100m from Unit 2 and 1 respectively. The vegetation surrounding these ponds should be avoided to the extent possible when siting temporary facilities (i.e. labour camps, contractor facilities, batching plant, etc.). A natural canal delineates the border between Kawai and Badi Villages. The canal was dry during the site visit despite the assessment being immediately after the monsoon season. The canal may pass through Unit 2 and/or Unit 3 after the compound is constructed. The natural drainage through the canal should not be blocked due to construction and operation/maintenance activities. If changes in the boundaries of the proposed units or any further expansions are anticipated than the areas surrounding the Arnea Reserve Forest block should be avoided to prevent increased risk of edge effects. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 238 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Construction Change in land use Construction activities should be restricted to designated area; EPC Contractor/ Sub- Monthly Report to Activities at Site On completion of construction activities, land used for temporary contractor RUMSL facilities such as Contractor office, batching plant (if any), stockyard, labour camp should be restored to the extent possible The land use in and around permanent Project facilities should not be disturbed; and The land should be restored back to the original state to the extent possible after completion of life cycle of the Project and in case there are plans not to continue further at the site. Soil Compaction and The topsoil present in the construction shall be removed and stock EPC Contractor/ Sub- Monthly Report to Erosion pilled in separate area; contractor RUMSL The stock pile should be protected from natural elements to prevent from erosion and also degradation; Topsoil to be reused on site for landscaping purpose; Defined routes for transportation and construction vehicles, workers etc. to minimize soil compaction; Good drainage as per the natural slope condition should be provided to reduce surface runoff and associated erosion; Back filling and revegetation of the area disturbed will be undertaken phase wise immediately after the completion; and Site clearance, piling, excavation and access road construction will not be carried out during the monsoon season to minimize erosion and run-off. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 239 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Soil Contamination Construction and Demolition Waste should be stored separately and EPC Contractor/ Sub- Monthly Report to be periodically collected by an authorized treatment and storage contractor RUMSL facility; All waste should be stored in a shed that is protected from the elements (wind, rain, storms, etc.) and away from natural drainage channels; Designated areas should be provided for Solid Municipal Waste and daily collection and period disposal should be ensured; The hazardous wastes to be stored onsite temporarily at separate designated covered area provided with impervious flooring and secondary containment and to be disposed in accordance with Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016; A log book should be maintained for quantity and type of hazardous waste generated; EPC Contractor should ensure that no unauthorized dumping of used oil and other hazardous waste is undertaken at the site; Hazardous waste to be disposed through MPPCB authorised vendors; In case of accidental/unintended spillage, the contaminated soil should be immediately collected and stored as hazardous waste; and E waste, used discarded batteries shall be disposed off in accordance to e waste management rules and batteries management and handling rules. Impact on Water Construction labour deputed onsite to be sensitised about water EPC Contractor/ Sub- Monthly Report to Resource and conservation and encouraged for optimal use of water; contractor RUMSL Availability No ground water shall be abstracted for construction activities; Regular inspection for identification of water leakages and preventing wastage of is necessary for efficient utilisation of water; Maintain logbook for water consumption www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 240 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Impact on Water Quality Ensure proper cover and stacking of loose construction material at EPC Contractor/ Sub- Monthly Report to site to prevent surface runoff and contamination of receiving water contractor RUMSL body; Open defecation and random disposal of sewage will be strictly restricted; Planning of toilets, soak pits and septic tanks, waste collection areas away from natural drainage channels; Provision of number of toilets across with easily accessible location as the project site is spread across large area of 3 units; Use of licensed contractors for management and disposal of waste and sludge; Labourers will be given training towards proactive use of designated areas/bins for waste disposal and encouraged for use of toilets. Open defecation and random disposal of sewage will be strictly restricted; Provision for impervious storage area, especially for fuel & lubricant, hazardous waste, etc. will be made onsite; and Spill/ leakage clearance plan to be adopted for immediate cleaning of spills and leakages. Impact on Air Quality The construction site shall be barricaded; EPC Contractor/ Sub- Monthly Report to Keeping areas of open excavation to a minimum; contractor RUMSL Minimising stockpiling by coordinating excavations, spreading, re- grading, compaction activities; Cease or phase down work if excess fugitive dust is observed, investigate source and take suppression measures; Speed of vehicles on site to be limited to 10-15 km/hr; The emissions from diesel generator shall be by optimised operations, orientation at the site and providing adequate stack height for wider dispersion of gaseous emissions Switch off machinery and equipment when not in use; Prevent idling of vehicles and equipment; and Vehicle engines will be properly maintained and will have a valid Pollution under Control (PUC) to ensure minimization in vehicular emissions. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 241 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Impact on Noise Quality Only well-maintained equipment to be operated on-site; EPC Contractor/ Sub- Monthly Report to If it is noticed that any particular equipment is generating too much contractor RUMSL noise then lubricating moving parts, tightening loose parts and replacing worn out components to be carried out to bring down the noise. It is to be ensured that such machinery are kept far away from the households; Machinery and construction equipment that may be in intermittent use to be shut down or throttled down during non-work periods; Low noise equipment shall be used as far as practicable; The number of equipment operating simultaneously shall be reduced as far as practicable; DG set with acoustic enclosures shall be used; Vehicular movement through village roads should be planned to avoid traffic jam and inconvenience to local residents; Equipment noise should be 85 dB (A) at 1 m from the source in line with WB/IFC EHS guidelines; and Minimal use of vehicle horns needs to be encouraged through induction training and periodic toolbox training sessions. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 242 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Impacts due to No hunting, trapping or injuring of local fauna should be EPC Contractor/Sub- Report to RUMSL construction activities communicated to labourers through a workshop or formal training contractor Construction Team exercise. The training should also communicate presence of species protected under Wildlife Protection Act, 1972 Schedule I and the penalties associated with contravention on the identified law; Noise control measures such as acoustic enclosures for DG sets, noise attenuation barriers in areas near sensitive habitat and proper maintenance of the vehicles used for the Project site should be implemented to reduce the effect of construction noise on local ecology; Set routes, consolidation of trips and no off-roading policies should be introduced by the EPC contractor to reduce the impact from noise and human-wildlife conflict; Adequate toilets, gas/firewood and space should be provided in any anticipated labour accommodation and the labourers should be informed not to enter or utilize any resources from surrounding forest land over the course of the construction period; Local semi-skilled and unskilled labourers should be used to the extent possible to reduce demography influx into the Project site and therefore reduce the risk of disturbance to local fauna; Waste that is generated from the Solar Park during construction and operation should be stored in covered containers within the site premises. Uncovered waste may attract fauna to the Solar Park; Excavated areas should be adequately fenced and security should be deployed to prevent wildlife intrusion into these areas; Construction work and anthropogenic movement should be restricted near any major water bodies (including all water bodies identified in Table 4.29) to reduce the impact on aquatic bird species (resident or migratory); Construction activities and transportation should be avoided during peak ecological activity i.e. dawn (5:30 am to 7:30 am) and dusk (5:00 pm to 7:00 pm). Night-time activities should be kept to a minimum and if essential, should be done with prior intimation to the neighbouring communities; Areas with pre-existing nests, ground-roosting sites and burrows should be avoided for construction related work to reduce the impact on local fauna; and Hazardous materials and waste should not be stored near any drainage channels or cliff-sides to prevent contamination of the surrounding environment and impact on local flora/fauna. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 243 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL The area around the [Water Body Unit 3] should be avoided for the siting of any ancillary facilities including access roads, contractor facilities or labour accommodation and even temporary siting of equipment (e.g. DG set, waste storage area and material storage area) should not be undertaken adjacent to the water body or its drainage channels. Loss of Ecosystem Nesting trees should be avoided to the extent possible when it falls EPC Contractor Report to RUMSL Services within the Solar Park site. Construction Team Natural drain passing between Kawai and Badi should be unaffected by the Project construction. Similar seasonal drainage pathways should not be blocked during the Project construction. Seeding of native plant species outside of the Solar Park especially in areas where the soil layers have been impacted and around water bodies to offset the loss of floral resources and dependent ecosystem services. Pollution and spill control mechanisms should be implemented and strictly enforced around [Water Body Unit 3] to ensure that there is no impact to the water quality or any drainage channels into the water body. Larger mature trees with significant height an girth should be avoided to the extent possible when construction the solar compound. Larger trees can be set aside within the Solar Park and avoided as part of the micro-siting of the solar modules. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 244 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Occupational Health & Health & safety training to be provided; EPC Contractor/ Sub- Monthly Report to Safety Prior to start of work, workers should be informed about the related contractor RUMSL safety risks and precautions to be taken through tool box meetings; Manual lifting by adult men to be less than 55 kg and for women it should be less than 30 kg; Adequate PPEs to be provided for all activities at site including but not limited to welding, cutting or similar operations which may cause hazard to eyes; All persons performing construction work to wear safety shoes and helmets confirming to national standard; Every worker engaged in handling sharp objects which may cause injury to hand shall be provided suitable hand gloves; While working in hot conditions, measures such as work break at regular intervals, keeping hydrated by drinking water and liquids, covering face with damp cloth etc. shall be used; Permitting system should be implemented to ensure that cranes and lifting equipment is operated by trained and authorized persons only; Appropriate safety harnesses and lowering/raising tools should be used for working at heights; All equipment should be turned off and checked when not in use; Emergency contact numbers and route to the nearest hospital to be displayed at the construction site; The local/ host community to be kept at safe distance from construction site; At a minimum, implement all COVID-19 related safety and emergency response measures, as relevant and as prescribed by the government A Site specific safety or emergency response plan should be in place to account for natural disasters, accidents and any emergency situations; Site specific/ activity specific Hazards Identification and Risk Assessment (HIRA) should be developed prior to start of the activities at site; and Provide H&S achievement information to employees. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 245 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Photovoltaic Heat Island SPD and RUMSL - The existing ground vegetation in the Solar Park area shall be Effect disturbed to minimum extent; Ground vegetation shall be planted in the buffer areas/open areas available in the Solar Park; The feasibility of mixed land use development in the Solar Park shall be explored Flood Risk SPD and RUMSL Undertake an assessment to estimate the High Flood Level (HFL) at the Site. This will help in estimation of the risks of flooding and inundation to the Site. Installation of solar panels and other critical infrastructure above the HFL will greatly reduce disruptions and losses to the Park; Enhance structural stability of banks of all seasonal streams which are in close vicinity of the Site units and provide robust erosion protection to withstand flood water; Storm water drains must be designed in line with the natural topography and eventually drain into the natural seasonal streams in the Site area; maximum water levels of the natural seasonal streams; Provide sluice/ flap gates at the SWD outfall to prevent backflow during a backflow event; Make provisions for pumping infrastructure within the Site to ensure rapid evacuation of water in case of high flow/backflow associated with ponds and seasonal streams ; Implement an effective flood monitoring and disaster management system in place for effective mitigation of floods at a Site level; Coordinate with the district and local disaster management cells to update on flood early warning notifications www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 246 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Social impacts due to Temporary occupation of Provision of adequate lease on rental amounts to the land owners RUMSL - ongoing construction land for construction shall be ensured by RUMSL; activities phase activities The land leased/ rented shall be restored to its original state (or made better) at the time of handing it back to the owners; Provision of compensation for the loss of livelihoods to the users of the land required for temporary use as this will temporarily economically displace them; Timely dissemination of project related information with all relevant stakeholders, in order to serve advance notice and reduce the extent of losses/ impacts; Provision of Grievance Redressal Mechanism to all the key stakeholders in order to raise and register their grievance. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 247 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Impact on Community Responsibilities of RUMSL RUMSL along with Monthly reports to Health and Safety Contractors RUMSL from EPC Ensuring stakeholder engagement through the project cycle and contractors provision of an effective Grievance Redressal Mechanism to avoid, mitigate and mange conflicts and disagreements; As part of the stakeholder engagement and information disclosure process, the community will be provided with an understanding of the activities to be undertaken and the precautions to be taken for safety; RUMSL shall maintain safe distance of project components from schools, hospitals, etc. in order to avoid interactions with community hotspots and hence risks of accidents; The Contractors to be engaged by RUMSL shall be informed of the EHSS practices that are expected from its workers during the construction phase engagement. Obligations like preparation of Traffic Management Plan, Local Procurement Plan, EHSS Plan, etc. shall be communicated to them at the time of selection and appropriate clauses should be included at the time of contract finalization; The contrac guidelines, for the labour camps in terms of provisions, sanitation facilities, etc. thus limiting the probability of diseases and infections in the local community on account of improper management of waste, special measures may be required to additionally manage the risk of the COVID-19 related infections and emergency response; RUMSL shall put in place a grievance redressal mechanism to allow community members to report any concern or grievance related to project activities. The contractors shall also be contractually required to put in place a similar mechanism to deal with concerns raised by the community (or external stakeholders) and the workers engaged during construction phases. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 248 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Contractors The contractor shall induct migrant workers on health and safety awareness and practices to be followed at site during construction phase; The contractors shall cordon off areas that are under construction and put relevant safety signs to restrict movement of local community members or workers engaged at site, which may become safety threats; The Contractors shall prepare a Traffic Management Plan and traffic movement due to the project in the area will be regulated to ensure road and pedestrian (including livestock) safety; Additionally, training on vehicular safety shall be organised for the transport workers. The movement of workers from the project site and labour camps shall be regulated and similarly the project boundary and labour accommodation to check for unauthorized visitors/ outsiders entering the site in order to avoid any possible interactions leading to conflicts or tensions between the migrant workforce and host community; Contractors shall ensure that regular health check-ups are conducted for the construction phase workers (especially migrant workers staying in temporary labour accommodation) and any major illnesses are reported in the Block level medical authorities at the earliest; The labour accommodation should be clean and hygienic and disposal of kitchen waste and food waste shall be done on a daily basis in an appropriate manner; Proper sanitation facilities shall be provided, taking into account the number of labourers that will be using the facilities, both at construction site, as well as labour accommodation. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 249 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Stress on Community RUMSL along with Monthly reporting by There will be a worker Code of Conduct defined by RUMSL that Resources contractors contractors prevents workers and contractors from using the local resources like water, forest, which will be shared with private SPDs for onward sharing with sub-contractors and its workers; An induction session will be organised for the migrant workers where tay near project location, which would include aspects on conservation of The contractor shall be asked to use Tanker water supply during the summer months, which are dry months in which water scarcity issues are reported by the community; Periodic maintenance activities for roads used for transportation of goods for the project shall be the undertaken by RUMSL, through its contractors; Provision of Grievance Redressal Mechanism to all the key stakeholders in order to raise and register their grievance on misuse of locally available resources. Impact due to Noise RUMSL Monthly reporting Ensure safe distance of project related activities from schools, Nuisance and Dust hospitals, etc.; Install enclosures around construction area, in order to reduce the extent of noise and dust emanating due to project related activities; Limit construction related activities to day time in order to restrict the noise related nuisance in the evenings, where permissible noise threshold is lesser; Provision of Grievance Redressal Mechanism to all the key stakeholders in order to raise and register their grievances pertinent to noise and dust related issues. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 250 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Impact on Employment RUMSL - Enhancement Measures and Entrepreneurship opportunities The sourcing of local labour wherever possible should be made obligatory by RUMSL (through contractual provisions) for the Solar Project Developers and sub-contractors and in all major procurement activities; Preference should be given to the land losers and vulnerable population in the Project Villages, to the extent practicable; Employment of members of SC-STs and Women Headed households should be ensured by the Solar Project Developers through documented agreement with contractors/ sub-contractors; Engagement of local vendors, to the extent possible, for the goods and services required for the project during construction phase; The project proponent will establish a mechanism to audit subcontractors and suppliers with respect to compliance of utilizing local labour and resources; Provision of Grievance Redressal Mechanism to all the key stakeholders in order to raise and register their grievance with respect to information sharing related to jobs and opportunities for vendor- ship. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 251 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Impact on Women RUMSL along with SPDs Monthly reports on Include provisions of coverage of women under skill training and number of women Financial literacy training programs, as part of livelihood restoration engaged in the activities by the project or through developmental programs of SPDs; project activities Ensure that the employment of women from vulnerable households is done for the project and efforts are made for development of women owned enterprises in the area, from where procurement for project related needs is undertaken; Undertake a profiling of the various social groups in the Study Area, to understand the individual needs and concerns of the various women belonging to different social groups and design community development and CSR programmes in light of the same; Provision of Grievance Redressal Mechanism to all the stakeholders in order to raise and register their grievances. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 252 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Table 8.3 Operation Phase ESMP Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Solar Park Water Resource O&M Contractor Annual Report to operation leasing to Conserving Water Resources RUMSL RUMSL use of water Dry robotic cleaning of modules to be explored as recommended by MNRE (1); Alternate sources of water shall be explored Ground water abstraction shall be done in accordance to CGWB guidelines. Implement rainwater harvesting and/or groundwater recharge and replenishment opportunities within Site premises especially near the low-lying and gently sloping area. Optimising water usage in the SCADA building by application of water conservation measures such as sensor based taps, low flush urinals etc.; Maintain logbook for water consumption; Implement groundwater and wastewater monitoring vis-à- vis quality/quantity; Adopt less water consuming module cleaning methods; The surface runoff from during solar panel cleaning shall be diverted to a settlement tank for settlement of suspended solids. The overflow shall be treated in water treatment unit and recycled in the Project. Use of water from multiple sources to avoid dependency on one particular source (groundwater or surface water). This also includes tapping of rainwater received during the monsoons for the long-term and uninterrupted operations. (1) MNRE had issued a letter dated 3 June 2019 to Principal Secretaries of States and Solar Association of all States regarding optimal utilization of water and preferably use Robotic technology for cleaning of modules. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 253 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL The Project should implement principles of water stewardship to ensure water security not just for the site, but also for other stakeholders within the watershed. Some of the water stewardship frameworks/ standards that can be adopted are UN Global Compact's CEO Water Mandate or AWS Standards. Identify stakeholders directly impacted by the groundwater use at the Project site and develop long- term stakeholder engagement plan particularly focused on stakeholders near site to develop positive perception towards Project and its operations. Rain Water Harvesting Rainwater harvesting pond shall be provided at site. In addition, groundwater recharge shall be undertaken within the Site to replenish the shallow aquifer zones. Piezometers to be installed to monitor the groundwater level changes in the aquifer trapped by the abstraction wells at Project site. Water Quality Ensure proper cover and stacking of loose construction material at site to prevent surface runoff and contamination of receiving water body; Open defecation and random disposal of sewage will be strictly restricted; Planning of toilets, soak pits and septic tanks, waste collection areas away from natural drainage channels; Provision of number of toilets across with easily accessible location as the project site is spread across large area of both the Units; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 254 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL Use of licensed contractors for management and disposal of waste and sludge; Labourers will be given training towards proactive use of designated areas/bins for waste disposal and encouraged for use of toilets; Provision for impervious storage area, especially for fuel & lubricant, hazardous waste, etc. will be made onsite; and Spill/ leakage clearance plan to be adopted for immediate cleaning of spills and leakages. Other Management Aspects Preparing an inventory of water consumption during construction and O&M activities. Solar Park Soil contamination Designated areas should be provided for Solid Municipal O&M Contractor Annual Report to operation leading to Waste and daily collection and period disposal should be RUMSL ensured; waste generation The hazardous wastes to be stored onsite temporarily at and leaks & spill separate designated covered area provided with impervious flooring and secondary containment and to be disposed in accordance with Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016; A log book should be maintained for quantity and type of hazardous waste generated; O&M Contractor should ensure that no unauthorized dumping of used oil and other hazardous waste is undertaken at the site; Hazardous waste to be disposed through MPPCB authorised vendors; In case of accidental/unintended spillage, the contaminated soil should be immediately collected and stored as hazardous waste; The guidelines and procedures shall be prepared and followed for immediate clean-up actions following any spillages; Damaged/ discarded solar panels to be disposed with the help of authorised recycling vendors/ module installation contractors; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 255 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL A SOP shall be prepared for storage and disposal of broken solar panels. MNRE had prepared a concept note for storage and disposal of used solar panels. The recommendations such as recycling of glass, storage of discarded panels in cover shed etc. shall be adopted in the Project; (1) The broken panels shall not be mixed with normal glass and kept separately in accordance to HW Rules; and Other wastes such as e-waste, used discarded batteries shall be disposed off in accordance to E-waste Rules and batteries management Rules. Solar Park Occupational Health and Safety At Substation, SOPs will be prepared for all O&M activities; O&M Contractor Report to RUMSL operations H&S training to be imparted; Team Work permit system to be developed and implemented; Appropriate PPEs for electrical work and other O&M work to be provided; First aid kit to be provided; Records of incident/ accidents shall be maintained; Root cause analysis shall be carried out for any incident/ accident; Emergency contact numbers and route to the nearest hospital to be displayed at the construction site; A safety or emergency management plan should be in place to account for natural disasters, accidents and any emergency situations; and Provide H&S achievement information to employees. Collision and electrocution risk Restrictions should be imposed so that dead carcasses are O&M Contractor Report to RUMSL with live electrical components not disposed near the Solar Park or external Transmission Team Line infrastructure. The O&M team should be trained on removing any carcasses found around these Project components in a timely manner to ensure that no vulture or birds of prey are attracted to the Project site. RUMSL should maintain a carcass register as part of the Operation and Maintenance (O&M) phase to record any bird carcasses or suspected bird carcasses. The register should include a date, type of specie (to the extent identifiable), geographic location and nearest Transmission Line infrastructure for each carcass entry. If possible, the (1) http://164.100.94.214/sites/default/files/webform/notices/DraftBluePrintAntimony.pdf www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 256 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL register should be backed-up with photo-documentation of any identified carcasses or remains. If the number of carcasses are significant, then RUMSL should commissioning an ecologist to suggest more stringent mitigation measures at the sensitive Project components. The O&M team should be instructed to regularly inspect transmission towers as part of their periodic maintenance and rounds of the operational Solar Park. The purpose is to identify any roosting or nesting of bird species. The internal Transmission Line along [Water Body Unit 3] should be marked with diffractors/diverters at a spacing of 10m apart Social Impacts Community Health and Safety Solar Project Developers Monthly Community sensitization sessions should be re-organised during Operations (SPDs) at the beginning of Operations phase, in order to mention Phase about the new developments in the area and provided an understanding of the precautions to be taken for safety; community shall still be in implementation to deal with any concerns of community health and safety, being raised by the local community. Impact on Employment (General, Enhancement Measures: Vulnerable and Indigenous The private SPDs shall advertise the roles of Technical groups and women) staff required during operations phases, in the local newspapers to enable hiring of competent people from nearby areas, to the extent feasible; Preference shall be given (to the extent feasible) to hire competent members from PAHs for semi-skilled jobs like housekeeping or Security Guards; Preference to Indigenous and Vulnerable groups shall be provided to the extent possible for semi-skilled jobs, like housekeeping, security guards, etc., and as Technicians and more, if there is a skill set match. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 257 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Activity Potential Impacts Mitigation Measures Responsibility Reporting to RUMSL The SPDs shall ensure appropriate measures for hiring of women, as per required skill set, are put in place, during the Operations phases. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 258 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report 8.2 Institutional Structure for Implementation To ensure the efficacy of Environmental and social management plan, certain institutional mechanism with well-defined roles and responsibilities is essential for effective implementation of identified mitigation measures both during construction and operation phases. 8.2.1 Project Implementation- SPPD and SPD The proposed Solar Park project will be owned by RUMSL and will be established jointly by Solar Power Park Developer (SPPD), i.e. RUMSL and Solar Project Developers (SPD). SPDs will be selected through bidding process. RUMSL had appointed PGCIL as PMC to oversee the project development. Presently, bidding process for selection of SPD is in planning stage. 8.2.1.1 Responsibilities of SPPD and SPD The scope of SPPD and SPD is given in Table 8.4 below. Table 8.4 Responsibilities of SPPD and SPD Project Phase/Scope SPPD SPD Name of Agency RUMSL To be selected through bidding process Permissions Land Acquisition, Gram Panchayat NOC, Registrations/ permissions required for work to be executed NA Conversion by SPD such as CTO for batching Support in obtaining permissions such as plant, Registration under Contract Labour Act and other labour laws - Geology & Mining NOC (as applicable), NOC from Gram - PTCC Approval Panchayat, Geology & Mining - CEIG Approval NOC etc. - Commissioning Certificate PTCC Approval - Open Access Approval CEIG Approval - Approval from Irrigation Commissioning Certificate department Open Access Approval - Registrations/ permissions Approval from Irrigation required for work (to be executed department by RUMSL) Solar Park Common facilities Site levelling activities for individual units Access roads, roads within Solar Park to provide access to individual plots and Development of three units (160 other common facilities MW, 170 MW and 170 MW) lightening to the common area such as Development of internal roads utility area, street lighting of the roads within each unit The Fire Fighting & Protection System for Labour camps common infrastructure such as the Pooling Substation www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 259 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Project Phase/Scope SPPD SPD Substation and Development of internal evacuation 33 kV cable circuit to evacuate Transmission Line infrastructure including three numbers of the generated power from each 33/220 kV substations unit to Unit substation. Erection of Transmission Line from Unit O&M of respective unit substation substations to PGCIL substation and internal transmission system proposed at Badi village Water Requirement RUMSL shall make available the Payment of construction water construction water by way of water cost. tankers including facilitating required Arrangement of water necessary approvals requirement during operation phase. Construction power Infrastructure for construction of power Cost of construction power to be through DG set or temporary supply from paid by SPD. Distribution Company Operation and O&M of common facilities shall be O&M of each unit Maintenance undertaken by RUMSL Source: DPR, July 2020 RUMSL will appoint EPC contractor for their scope of work such as construction of external roads, substations, common facilities etc. PGCIL will be responsible to oversee the EPC contractor activities. 8.2.1.2 Power Grid Corporation India Limited (PGCIL) PGCIL will be responsible for providing grid connectivity to the Solar Park for power evacuation. For this purpose PGCIL will construct a 220kV /400 kV ISTS substation at Badi Village. RUMSL has also appointed PGCIL as Project Management Consultant. Under this role, the responsibilities of the PGCIL includes supervision of EPC contractor to be hired by RUMSL for construction of common infrastructure of Solar Park such as roads, control room and construction of internal evacuation infrastructure, i.e. 33kV/220 kV Pooling substations at each Unit and 220 kV Transmission Line connecting Pooling substations to ISTS substation. 8.2.2 Implementation of ESMP RUMSL will have ultimate responsibility for implementing the provisions of the ESMP. This role will include the on-going management of environmental and social impacts, monitoring of contractor performance as well as development of mechanisms for dealing with environmental and social problems. RUMSL will also ensure that the activities of its contractors are conducted in accordance with good practice measures, implementation of which will be required through contractual documentation. The organizational structure of RUMSL with respect to management of EHSS issues across the project life cycle is shown in Figure 8.1 below. The overall management and coordination of the Project will be the responsibility of Project Manager of RUMSL. RUMSL will engage EPC contractors to undertake construction activities for pooling substation and common infrastructure at all the three Units, i.e. Unit 1, Unit 2 and Unit 3. The project level activities will be managed at the Site by Site Supervisor(s) of respective Units. At project level, implementation of management plans and corrective actions are the responsibilities of Site Supervisor in coordination with EHS Manager, hired by the respective Unit EPC contractor. In construction and operational phase, EHS Manager of each www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 260 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report respective Unit will supervise the Contractor HSE En management action plans in coordination with Site Supervisor. Figure 8.1 Proposed Organisation Structure for ESMP Implementation As the project is being developed on some private land also; it is envisaged that SPD need to appoint an onsite social/admin officer to manage social (including labour and community) issues. The name and contact number of the appointed person should be displayed at the site office. 8.2.2.1 Roles and Responsibilities This section describes the roles and responsibilities of the key persons responsible for management of onsite activities for the proposed project: Project Manager /Site In charge The Project Manager of RUMSL will be responsible for overall management of the project and ESMP implementation during construction and operation phase. The following tasks will fall within his/her responsibilities: Monitor site activities on a daily basis for compliance during construction phase and weekly during operation phase; Conduct internal audits of the construction site against the ESMP; Confine the construction site to the demarcated area; Reporting EHSS related issues & incidents to Chairman of RUMSL; Conducting meetings with Site Supervisor of Unit Developers regarding EHSS issues; Oversee activities of Site Supervisor and will coordinate with him for updates on the project; and Reviewing and updating of ESMP for its effective implementation. Site Supervisor Site Supervisor will be appointed by the SPD/EPC Contractor and will be responsible for the following scope of work: Meet the labour requirements during construction phase; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 261 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Hiring and management of different contractors for civil, mechanical and electrical works; Supervise the daily activities occurring on the site during construction and operation phase; and Plan the traffic route for movement of material and solar panels and will communicate the same to RUMSL officials. EHS Manager EHS Manager as appointed by SPD/EPC Contractor shall be responsible for checking compliance of the contractor(s) with the requirements of this EMP and any other relevant environmental legislation for all activities associated with the contract. The general duties of the EHS Manager are as follows: Be familiar with the environmental management requirements contained in this ESMP; Regular auditing of the contractor(s) with the view of ensuring that all activities on the site are undertaken in accordance with the ESMP; Issuing regular audit reports to the Site Supervisor and contractor(s)regarding compliance with this EMP with help of Safety Officers; and Advising on environmental legal requirements regarding issues that may arise during the project to the Site Supervisor and the contractor(s). Safety Officer Safety Officers appointed by SPD/EPC Contractor will also be responsible for conducting an EHS audit during the construction phase of the project on a weekly basis according to the provisions of the Environmental and Social Management Plan. The major responsibilities will be: construction activities; Provide tool box trainings to labour and will also issue relevant PPEs to them; Develop formats for work permit system and will ensure its implementation; Conduct independent environmental audits; and Submit audit reports to the EHS Manager and Site Supervisor of respective Units. Supervisor (Social and Community aspects) A supervisor shall be appointed by RUMSL to manage social and community aspects on site The Supervisor (S&C) shall be responsible for maintaining category wise records of those eligible for priority hiring of labourers by the contractors at the time of Construction activity initiation, based on the lists provided based on RAP-LRP eligibility for priority employment. Additionally, the Supervisor (S&C) shall be responsible for maintenance and upkeep of records related to liaison with local community including awareness and communications on construction phase activities by the project personnel, on various topics, and also be responsible for maintaining stakeholder engagement records. The Supervisor (S&C) shall also be designated as the Grievance Officer for the project, who is liable to maintain records of all incoming grievances (including but not limited to RAP and LRP implementation or linked to compensation payments), maintain grievance trackers and drive the communication to the aggrieved on receipt and resolution of grievances and also in cases of any delays that are anticipated in resolution of grievances. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 262 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report HSE Engineer The HSE officer shall be responsible for implementation of the ESMP and any other environmental requirements that may be identified by the Site Supervisor during the course of the contract. The Contractor(s) HSE officer shall have received basic HSE training either as part of the HSE officer shall be: Ensure that all personnel (including sub-contractors) are duly informed of the requirements contained in this ESMP, and the associated responsibilities and implications of this ESMP; Consult with the Safety Officer of SPD/EPC Contractor regarding interpretation of the EMP and any other aspects of the contract that may impact significantly on the environment; and Ensure that all records needed to demonstrate compliance with the EMP requirements are obtained, filed and readily available for inspection by the Site Supervisor of Module or the Project Manager of RUMSL. 8.2.3 Monitoring and Reporting RUMSL through the respective PMC will monitor the project to ensure conformity to the requirements of the ESMF. The monitoring will cover construction and operation phases. The list of performance indicators as provided in Table 8.5 will be used to monitor project objectives. The monitoring will be carried out through the environmental and social safeguard compliance reports that will form a part of Monthly Progress Reports (MPR) for the project during construction phase and monthly and annual reports during operation phase. Besides this, regular visits by the EHS Manager shall also be carried out for monitoring of ESMP implementation on site. Delegated personnel shall require to fully complying with the reporting programme in terms of both timely submissions of reports as per acceptable level of detail. Reporting: Reporting is the process of measuring actual performance or how well the mitigation measures have been implemented, including the format, timing and responsibility for reporting of the monitoring results. This needs to be undertaken in form of environmental, health, safety and social check list, incident record register, environmental, health, safety and social performance reports. RUMSL shall develop and implement a programme of reporting through all stages of the project construction and commissioning, operation and maintenance. 8.2.3.1 Monitoring Indicators Regular monitoring of critical environmental parameters is of immense importance to assess the status of environment during construction and operation stage. The monitored data can serve as an indicator for any change in environmental quality due to the Solar Park with respect to baseline environmental conditions, so that suitable mitigatory steps could be taken in time to safeguard the environment. The monitoring action plan covering various performance indicators, frequency and institutional arrangements of the project in the construction and operation stages is given in have been presented in the following Table 8.5. Table 8.5 Monitoring Action Plan No. Parameter Performance Indicator Implementing Monitoring Frequency Agency Agency A Construction Phase www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 263 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report No. Parameter Performance Indicator Implementing Monitoring Frequency Agency Agency 1 Compliance to Permission for borrow area/ SPD and EPC RUMSL Quarterly Statutory Norms stone query/ explosive permit Contractor Availability of required regulatory permissions; Compliance to applicable environmental and labour laws 2 Air Quality PM10, PM2.5, SPD and EPC RUMSL Quarterly SOx, NOx, CO at 3 locations Contractor covering all the 3 Units through Approved Environmental Laboratory 3 Noise Quality Leq Day and Night at 5 SPD and EPC RUMSL Quarterly locations Contractor through Approved Environmental Laboratory 4 Water Quality Suspended Solids (SS), Total SPD and EPC RUMSL Quarterly dissolved solids (TDS), oil, Contractor grease, Heavy metals (Fe, Cr, through Pb, etc.) Biological Oxygen Approved Demand (BOD), Total Environmental coliforms, Faecal coliforms at 2 Laboratory locations 5 Soil Quality Oil and grease, Heavy metals SPD and EPC RUMSL Quarterly (Pb, Cr, Ni, Mn, Fe, etc.), Contractor N.P.K. at 2 to 3 locations through covering all the 3 Units Approved Environmental Laboratory 6 Personnel Total supply of PPEs vs SPD and EPC RUMSL Daily number of workers working Safety Contractor Number of workers working using PPEs Safe access Safe working platform for work site Incident investigation Number of near misses Number of incidents 7 Site Restoration Visual Observation of sites SPD and EPC RUMSL After completion of including plant site, borrow Contractor works & before area, camp site demobilization of the contractor 8 Debris Removal of debris from site SPD and EPC RUMSL After completion of Management (visual Observation) Contractor works & before issuing completion certificate www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 264 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report No. Parameter Performance Indicator Implementing Monitoring Frequency Agency Agency 9 Habitat Visual observation of Project SPD and EPC RUMSL Monthly visits Modification and site to ensure that any mature Contractor during the Loss trees that are set aside and construction phase vegetation around water bodies to ensure is being avoided by documented construction team information is being followed. 10 Labour Camp SPD and EPC RUMSL Monthly Availability of adequate Contractor potable water in labour camp and at construction site Adequate toilet and bathing facilities and their maintenance Adequacy of process of waste water disposal Source of cooking fuel Use of wood as a cooking fuel Adequate lighting and ventilation in labour camo Is an emergency response plan in place for the site and are the emergency contact details displayed in the camp Number of first aid kit available and required first aid medicine filled Key Health (Malaria/ dengue/fever/ any other) issues reported during the last month 11 Social Implementation of GAP, SPD and SPPD RUMSL Quarterly SEP, GRM B Operation Phase 1 Regulatory Availability of the regulatory O&M contractor RUMSL Annual permissions and its compliance Compliances 2 Waste Quantity of hazardous waste O&M contractor RUMSL Quarterly generated and its disposal generation 3 Water reuse and Water consumption reports and O&M contractor RUMSL Monthly wash water reuse and recycling recycling 4 Disposal of Number of batteries disposed O&M contractor RUMSL Annual Batteries 5 Ground water Monitoring of ground water RUMSL through RUMSL Half Yearly level fluctuation level External Agency www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 265 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report No. Parameter Performance Indicator Implementing Monitoring Frequency Agency Agency 6 Soil Quality Oil and grease, Heavy metals Contractor RUMSL Half yearly (Pb, Cr, Ni, Mn, Fe, etc.), through N.P.K. Approved Environmental Laboratory 7 Health & Safety Availability of PPEs; Contractor RUMSL Monthly Availability of procedures for preventive maintenance along Transmission Line and substation; Records of incident/ accidents and their root cause analysis; Display of emergency contact numbers; Availability of firefighting equipment at substation. 8 Biodiversity Maintenance of carcass registry O&M Contractor RUMSL Half-yearly visits to and records of any bird check register and nesting/roosting along records and confirm Transmission Line the findings with Infrastructure local communities who can comment on presence/absence of carcasses in the area. 9 Community The implementation of the SEP O&M Contractor RUMSL Monthly health and and GRM formulated for the safety project and monitoring against the indicators identified in it External Reporting and Communication EHS Manager shall be responsible for ensuring that communication with government agencies and stakeholders are maintained as per the requirement. All complaints and enquiries to be appropriately dealt with and records be maintained in a Complaint/Enquiry Register. The reporting to external agencies on Environmental and social performance of the project shall be done as agreed in contract. 8.2.3.2 Indicative Environmental Monitoring Budget Indicative cost of environmental monitoring for the project have been presented in Table below. Table 8.6 Environmental Monitoring Budget Component Item Unit Approx.. Unit Quantity Cost (Rs.) Construction Phase Ambient Air Quarterly monitoring of AAQ Per sample 4000 3 locations covering comprising of PM10, PM2.5, Quality all the three Units SOx, NOx, CO at nearby villages www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 266 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report Component Item Unit Approx.. Unit Quantity Cost (Rs.) Ambient Noise Quarterly ambient noise level Per sample 3000 5 locations covering monitoring near D.G. sets/ Level all the three Units batching plant/ nearest receptors Surface Water Quarterly monitoring of surface Per sample 7000 2 locations (nearby Quality water quality water bodies) Parameters as per CPCB Use-class Soil Quality Oil and grease, Heavy metals Per sample 8000 2 to 3 locations (Pb, Cr, Ni, Mn, Fe, etc.), covering all the 3 N.P.K. Units Operation Phase Ambient Noise Leq Day and Night to be Per sample 3000 3 locations monitored on six monthly basis Level comprising to nearest receptors to all the three Units Surface Water Six monthly monitoring of Per sample 7000 2 locations (nearby Quality surface water quality water bodies/lakes) Parameters as per CPCB Use-class Soil Quality Six monthly monitoring of Per sample 8000 3 locations (near Oil and grease, Heavy metals storage area of all (Pb, Cr, Ni, Mn, Fe, etc.), the three units) N.P.K. Ground Water Ground water level to be Per sample 200000 One per Unit Level Monitoring monitored once in a year 8.3 ESMP Budget The project will have its own budget for implementation of ESMP and RAP. The budget heads for Construction and O&M stage will include cost towards Dust Control (Construction Phase) Wastewater treatment; Waste management; Personal protective equipment; Health & Safety; and Hazardous material transportation & disposal An indicative budgetary allocation for ESMP implementation during construction and O& M stage is provided in Table 8.7. Table 8.7 Indicative Budgetary allocation for ESMP Implementation S. N. Particular Capital Cost Recurring Cost (INR in (INR in lakhs) lakhs) per annum A. Construction Phase www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 267 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report S. N. Particular Capital Cost Recurring Cost (INR in (INR in lakhs) lakhs) per annum Dust Suppression with sprinkling of water, 10 1 covers of the vehicles transporting construction material. (During moderate operations 10-20 tankers will be required on daily basis depending on the season of the year) Wastewater treatment - septic tank and soak 8 2.5 2 pits 3 Waste Management - Construction of 8 5 suitable masonry bins with concrete floors for waste collection and for further disposal as per applicable norms 4 Environment, health and safety and EMP 50 10 implementation 5 Environmental monitoring 3 6 Landscaping 10 7 Labour camp cleanliness 5 8. RAP, LRP, FPIC measures etc. To be decided after completion of these studies Subtotal A 76 35.5 B. Operation and Maintenance Phase 1 Wastewater treatment- septic tank and soak 10 2.5 pits 2 20 2.0 Rainwater harvesting (for roof top at pooling substation) The cost of rainwater harvesting pond in the open area shall be determined on land available, topography, slope, piping system required etc.) 3 Waste Management - Municipal solid waste 5 1.5 and hazardous waste storage area sheds (impervious shed for hazardous waste storage) 4 Environment, health and safety training and 25 4.0 ESMP evaluation 5 Dry Robotic cleaning depends on Robot make depends on Robot make and capacity and capacity 6 Horticulture and landscaping (including 20 2 seeding of native plants around the Solar Park and adjacent to water bodies) 7 RAP, LRP, FPIC measures etc. To be decided after completion of these studies Subtotal B 80 12 Total (Subtotal A+ Subtotal B) 156 47.5 Note: The above cost does not include cost of manpower needed for the EMP implementation www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 268 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Final ESIA Report 8.4 Training and Capacity Building Successful implementation of the Project will depend on the effective implementation of the environmental and social management measures outlined in the ESMPs, RAPs, etc. Training and capacity building will be necessary for the key stakeholders in order to ensure effective implementation of the Environmental and Social Management Framework (ESMF). Project Manager will ensure that the training needs are identified and conducted. Training needs will be identified based on the specific requirements of ESMP and existing capacity of site and project personnel (including the EPC Contractors and Sub-contractors) to undertake the required ESMP management actions and monitoring activities. m to encourage the implementation of environmentally sound practices and compliance requirements of the project activities. This will help in minimising adverse environmental impacts, compliance with the applicable regulations and standards, and achieving performance beyond compliance. RUMSL in coordination with the educational / research institutions in the country who have substantial experience in the environmental and social management sector including a good understanding of the WB/IFC safeguard requirements, shall conduct classroom training sessions for all staff likely to be involved in sub-project planning & implementation. The EH&S officer can also be one of the resource persons for conducting such training programs. An environmental management training programme will be conducted for project related activities. This will ensure capacity building for effective implementation of the management and control measures on various project activities. The training shall focus on the environmental, health and safety and social issues. The contents will basically focus on the ESMF concept, regulatory requirements, Environment and Social priority issues, project cycle, outline of Environmental Assessment / Social Assessment and report formats in respect of the Environmental aspects. The typical training modules for formal class room training could cover the following: Module 1 - ESMF Profile (Concept, regulatory requirements, ESA, reports and formats) Module 2 - Environmental Assessment Process (Environmental Laws & Regulations, EIA process, Identification of Environmental Impacts, Impact Identification Methods, Identification Mitigation Measures, Formulation of Environmental Management Plan, Implementation and Monitoring, Institutional Mechanism) Module 3 - Social Assessment Process (Description of R&R, tribal and gender frameworks and procedures and National requirements, LA process, Necessity for RAP and its preparation process) Module 4 List of protected and threatened species found in and around the Project site and the provisions of no hunting, trapping and injuring of the species in accordance to the Wildlife Protection Act, 1972. Proper use and avoidance of destructive practices (e.g. siting of hazardous components, tree cutting, etc.) around the Arnea Reserve Forest Block, Bardawada Pond, Kawai Pond and [Water Body Unit 3]. The program should be structured in such a way that it clearly brings out the value addition and enhancement benefits of proper management of environmental and social issues. Als implementation of environmentally sound practices and compliance requirements of the project activities. This will help in minimising adverse environmental impacts, compliance with the applicable regulations and standards, and achieving performance beyond compliance. The same level of awareness and commitment will be imparted to the contractors and sub-contractors prior to the commencement of the project. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 269 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS GRIEVANCE REDRESSAL MECHANISM Final ESIA Report 9. GRIEVANCE REDRESSAL MECHANISM of a project lifecycle, it encounters numerous instances of conflicts, allegations and dissatisfaction within the working and associated human capital and their interactions. Some of the areas of grievances for the project may include issues regarding land procurement, payment of compensation for land or wages to the workers, issues arising due to allotment of alternate land parcels with diminished productivity or higher upfront costs required for making it fit for cultivation, failure to fulfil commitments, poor management of construction activities, accidents due to inappropriate planning of vehicle movement, etc. Presently, RUMSL does not have a formal grievance redressal mechanism in place for external stakeholders. In order to manage these risks, it needs an internal mechanism to allow the aggrieved party/s to lodge their complaints and get them amicably settled prior to approaching the formal legal mode of solutions. However, according to the consultations undertaken with the local community and the project team, it was understood that the public meetings were used by the local community to voice their concerns and there have been agitations and demonstrations by the community at the Tehsil and district level Government offices. The local community representatives are also reported to have access to the contact information of the project team; however, this is an informal process and no records of such communication are maintained. For the remaining project lifecycle, a formal grievance redressal mechanism has been put in place for the project. 9.1 Objectives of the Grievance Redressal Mechanism The primary objective of the GRM shall be to provide an accessible mechanism to the stakeholders of the project and resolve any social and environmental related grievances. For this purpose, a Grievance Redressal Cell (GRC) shall be established, to resolve non-judicial disputes arising out of various matters related to the implementation of the ESMP, as well as other aspects of the project, as deemed fit to be raised before the GRC. 9.2 Composition of the GRC The GRC will be driven internally by the Project team and shall have representation from the following teams to ensure fair and timely solution to the grievances: Site Manager/Project Manager; EHS Officer; Community Relations Officer; Senior representation on behalf of the Project Company; and Any other concerned person with decision making authority in relevance to the grievance or aggrieved party. The GRC shall be led by a Grievance Officer, who can either be the site EHS officer or Community Relations Officer. The aggrieved party shall register their grievances with the GRC. The GRC shall be empowered to take a decision which is to be considered final and binding on the Project. However, the decision of the GRC is not binding on the aggrieved person and he or she may take the grievance to the administrative setup in case any grievance channel is available at that level or take a legal course, in case not satisfied with the outcome of GRC decision. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 270 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS GRIEVANCE REDRESSAL MECHANISM Final ESIA Report 9.2.1 Functioning of the GRC for Grievance Redress The GRC meetings will be held on a regular basis (at least key responsibilities of the GRC shall be as follows: Receive, review, consider and resolve grievances related to the social and environmental aspects of the project; Entertain grievances of indirectly affected persons and/or persons affected during project implementation; Resolve grievances within a period of two weeks at the GRC level and communication of the resolution to the aggrieved party; any matters pending in the court of law; Arrive at decisions through consensus, failing which resolution will be based on majority vote. Any decision made by the GRC must be within the purview of Environmental Management Plan, Corporate EHS and Social Policies or any such documents of relevance of that matter; In case the grievance relates to environmental monitoring results or engineering matters, the management team/ environmental monitoring team. However, GRC will not be in a position to question the validity of the data provided to it. If needed, may undertake field visits to verify and review the issues, disputes or other relevant matters. 9.3 External Grievance Redressal Mechanism of RUMSL The medium of receiving Grievances from external stakeholders, comprising fence line community, private and patta land sellers, encroachers and squatters, etc., shall be documented and displayed at relevant locations outside the Solar Park, near entrances, on the boundary walls, etc. The external grievances may be submitted through various mediums, comprising the following: Face to face/Walk in; In written form to the address displayed by RUMSL; Through a toll free phone line or through direct calls to concerned officials, as set up by RUMSL; and Online through website. The Social and Community Supervisor in the SPPD team shall be responsible for coordination of grievance/complaints received. The person in-charge, based on nature of complaint, will forward the same to the concerned official. A ticket or a unique number will be generated for all such calls and messages based complaints. The complainant will follow up based on that unique number. 9.3.1 Grievance Receipt and Recording An acknowledgement shall be sent to the aggrieved, either on the spot, or through mail. RUMSL shall maintain records of all grievances received as part of Grievance management process, in the form of a tracker, along with date of receipt of Grievance, nature and details of Grievance, concerned department or personnel linked to Grievances, resolution details and date of closure. Additionally provision of communication of resolution to the aggrieved shall also be maintained by RUMSL, during project lifecycle. The format to be used for recording of grievances is presented below. GRIEVANCE REGISTRATION FOR EXTERNAL STAKEHOLDERS Case No.: Date: Name: www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 271 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS GRIEVANCE REDRESSAL MECHANISM Final ESIA Report GRIEVANCE REGISTRATION FOR EXTERNAL STAKEHOLDERS District: Village: Contact number: Details of grievance: Name of person recording the grievance: Designation of recording person: Proposed date of response: Signature of the recording person Signature of complainant GRIEVANCE REDRESSAL RESPONSE Date of Resolution : Decision of the GRC (give full details): Complainant accepts the outcome: Accepted Not accepted Signature of the complainant Signature of the S&C Supervisor Additionally, the format to be used for an external Grievance Tracker is provided below. Table 9.1 Format for Grievance Tracker Departmen Departmen Requireme Concerned for Closing Communic Medium of Grievance Grievance Investigati Individual Details of Remarks t/ Village Timeline Present Scope Status Name within S. No Issue ation Date on t 9.3.2 Grievance Resolution and Communication All grievances lodged by the aggrieved, shall be responded within two weeks. If response is not received within 15 days, the complaint will be escalated to next level. The staffing of GRC will include Social and Community Supervisor of SPPD; and two representatives from community / beneficiary / affected persons. The head of the cell will be a person of repute but not continuing in the government service. Any project affected person however is free to approach judiciary system of the country if he or she is not satisfied with the verdict given by GRC. 9.4 Internal Grievance Redressal Mechanism Project developers, staff, contractors and contractual workers or RUMSL, staff and workers of private Solar Project Developers, etc. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 272 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS GRIEVANCE REDRESSAL MECHANISM Final ESIA Report The mode of receipt of grievances coming from internal stakeholder of RUMSL shall be the following: Face to face/Walk in; In written form through suggestion boxes set up within Solar Park premises by RUMSL; and Through a toll free phone line or through direct calls to concerned officials, as set up by RUMSL. 9.4.1 Grievance Receipt and Recording An acknowledgement shall be sent to the aggrieved, either on the spot, or through mail. RUMSL shall maintain records of all grievances received as part of Grievance management process, in the form of a tracker, along with date of receipt of Grievance, nature and details of Grievance, concerned department or personnel linked to Grievances, resolution details and date of closure. Additionally provision of communication of resolution to the aggrieved shall also be maintained by RUMSL, during project lifecycle. The format to be used for recording of grievances is presented below. GRIEVANCE REGISTRATION FOR EXTERNAL STAKEHOLDERS Case No.: Date: Name: District: Village: Contact number: Details of grievance: Name of person recording the grievance: Designation of recording person: Proposed date of response: Signature of the recording person Signature of complainant GRIEVANCE REDRESSAL RESPONSE Date of Resolution : Decision of the GRC (give full details): Complainant accepts the outcome: Accepted Not accepted Signature of the complainant Signature of the S&C Supervisor Additionally, the format to be used for an external Grievance Tracker is provided below. Table 9.2 Format for Grievance Tracker Departmen Departmen Requireme Concerned for Closing Communic Medium of Contractor Grievance Grievance Investigati Individual Details of Remarks Timeline Present t/ SPD/ Scope Status Name within S. No Issue ation Date on t www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 273 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS GRIEVANCE REDRESSAL MECHANISM Final ESIA Report Departmen Departmen Requireme Concerned for Closing Communic Medium of Contractor Grievance Grievance Investigati Individual Details of Remarks Timeline Present t/ SPD/ Scope Status Name within S. No Issue ation Date on t 9.4.2 Grievance Resolution and Closure The GRC will organize an inspection/review of the grievance received, to check the validity and severity of the grievance. The inspection will be undertaken in no later than seven days of receiving the grievance. The assigned individual will work with immediate supervisors/ managers of the concerned department or contractors to investigate the problem and identify measures to resolve the grievance as appropriate, within 15 days. This could involve provision of information to clarify the situation, undertaking measures to remedy actual problems or compensate for any damage that has been caused. Where a grievance is found to be not a real problem a clear explanation will be provided to the complainant. A formal response detailing how the grievance has been resolved shall be provided to each complainant once a resolution is reached. Where resolution is delayed the complainant will be provided with regular updates on progress. Once a resolution is decided and agreed upon internally, it is communicated to the aggrieved. If the GRC along with the concerned department head are not able to resolve the grievance adequately within 15 days, the same may be escalated. 9.5 Monitoring and Evaluation Like the other project components, the GRM shall be regularly monitored to ensure that the stakeholders are having no or limited issues with the project and in case there are concerns, they are being adequately addressed as per the mandate. In order to keep track on the effectiveness of GRM, it is the responsibility database on grievances for periodic review. The mechanism shall be based on two components, internal monitoring and reporting and external monitoring and reporting which shall run simultaneously. Mostly this shall be aligned with simultaneous process monitoring rather than doing it separately all the time. 9.6 Budgeting RUMSL shall ensure adequate budgeting and resource allocation for implementing the GRM. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 274 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS CONCLUSION Final ESIA Report 10. CONCLUSION The ESIA has assessed the overall acceptability of environmental and social impacts likely to arise as a result of construction and operation of Neemuch Solar Park. To summarize, - specific. These impacts include change in land use, stress on ground water resources, increase noise & vibration and air quality, etc. during the site preparation of Solar Park, pooling substations and community health and safety during material transportation. The proposed project will require water for cleaning of solar modules during operation phase. The project area falls under semi-critical category in terms of ground water availability. Water requirement for the project will be met mainly through ground water. Considering the stress on water resources in the area, it is recommended to evaluate alternate sources or plan for dry robotic cleaning. The land footprint of the project is 1065.7 hectares for Solar Park. The social impacts of the project will be higher in the planning and construction phases of the project, where land linked livelihoods will be impacted, there would be an impact on community resources and community health and safety risks, during construction phases and some short term employment will be generated. The Environmental and Social Management Plan (ESMP) describes mitigation measures for impacts specific to Project activities and also discuss implementation mechanism. Project specific management plans are also provided for certain Project activities such as waste management, occupational health & safety, contractor and labour management plan, gender action plan, stakeholder management plan, grievance redressal, etc. This ESIA study together with mitigation measures and follow up of recommendations on management actions will help RUMSL in complying with the environmental standards. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 275 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS REFERENCES Final ESIA Report 11. 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); https://www.nature.com/articles/srep35070 Balachandran, S., Katti, T. and Manakadan, R. 2018. Indian Bird Migration Atlas. BNHS India. Oxford University Press. Pp 215 Building Materials and Technology Promotion Council (BMTPC), 2019. Vulnerability Atlas of India, Ministry of Housing and Urban Affairs, Government of India: http://bmtpc.org/DataFiles/CMS/file/VAI2019/index.html Building Materials and Technology Promotion Council (BMTPC), Ministry of Housing and Urban Affairs, Government of India. Earthquake Zoning Map: http://bmtpc.org/DataFiles/CMS/file/VAI2019/MAP/eqmap/EQ_JPG/EQ_INDIA.jpg Census of India, 2011 Champion, H.G. and Seth, S.K. 1968. A revised survey of foret types of India. 404 pp. Climatological Table 1961-90, India Meteorological Department Data Basin Global Flood Hazard Frequency and Distribution (https://databasin.org/datasets/e5190023c8194691b5b233df41955417) 1DelftUniversity of Technology, Deltares, Utrecht University, Institute for Environmental Studies (IVM), International Food Policy Research Institute (IFPRI), PBL Netherlands Environmental Agency, and RepRisk District Brochure, Neemuch District, 2013 http://cgwb.gov.in/District_Profile/MP/Neemuch.pdf District Disaster Management Plan, Neemuch District , https://cdn.s3waas.gov.in/s334173cb38f07f89ddbebc2ac9128303f/uploads/2019/07/2019070330.pdf Ebird.org, IUCN Red List, India Biodiversity Portal and media articles (e.g. https://indiasendangered.com/more-vultures-in-madhya-pradesh/) Flood Estimation Report for Chambal Sub-Zone - http://cwc.gov.in/sites/default/files/chambal20subzone201b.pdf FM-Global Flood Hazard Map (https://www.fmglobal.com/research-and-resources/nathaz-toolkit-and- map/flood-map Forest Working Plan for Neemuch District Grimmet, R. Inskipp, C. and Inskipp, T. 2013. Birds of the Indian Subcontinent - Second Edition. Published by Christopher Helm, 49-51 Bedford Square, London. Relevant Global Water R https://www.wri.org/publication/aqueduct-30 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 276 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS REFERENCES Final ESIA Report http://agricoop.nic.in/agriculturecontingency/neemuch http://bhuvan.nrsc.gov.in/bhuvan_links.php http://cgwb.gov.in/District_Profile/MP/Neemuch.pdf http://datazone.birdlife.org/userfiles/file/sowb/flyways/7_Central_Asia_Factsheet.pdf http://hydro.imd.gov.in/hydrometweb/(S(zq1q35r5cjodlizybet3jlqn))/DistrictRaifall.aspx http://wiienvis.nic.in/Database/HtmlPages/bioprovincemap.htm https://cdn.s3waas.gov.in/s334173cb38f07f89ddbebc2ac9128303f/uploads/2019/07/2019070330.pdf https://earthexplorer.usgs.gov/ https://neemuch.nic.in/en/about-district/ https://preview.grid.unep.ch/index.php?preview=dataandevents=floodsandevcat=5andlang=eng https://www.fmglobal.com/research-and-resources/nathaz-toolkit/about-global-flood-map https://www.iucnredlist.org/species/22727255/110064997 https://www.wri.org/resources/data-sets/aqueduct-global-maps-30-data https://www.researchgate.net/publication/327838950_Impacts_of_a_PV_Power_Plant_for_Possible_ Heat_Island_Effect https://pvbuzz.com/photovoltaic-heat-island-effect/ Knutson et. Al. 2005. Agricultural ponds support amphibian populations. Ecological Applications. 14 (3): 669-684. Menon, V. 2003. A field guide to Indian Mammals. Dorling Kindersley (India) Ltd. New Delhi. Menon, V. 2014. Indian Mammals: A Field Guide. Hachette, India. Neemuch District Census Handbook, 2011 Prater, S.H. 2005. The Book of Indian Animals. Bombay Natural History Society and Oxford University Press 12th Edition. Pp 316 The Beaufort Scale. Royal Meteorological Society: https://www.rmets.org/resource/beaufort-scale UNEP/GRID Europe (http://ihp-wins.unesco.org/layers/geonode:fl1010irmt) Welsh H.H. Jr. and Lind, A. 1991. The structure of the herpetofaunal assemblage in the Douglas- fir/hardwood forest of norther western California and southwestern Oregon. Pp 395-411. In: Wildlife and vegetation of unmanaged Douglas-fir forests. (Tech. Coords). L.F. Ruggiero, K.B. Aubry, A.B. Carey and M.H. Huff. Ge. Tech. Rep. PNW-GTR-285. Portland, OR: US Department of Agriculture, Forest Service. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 277 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS REFERENCES Final ESIA Report Welsh, H.H. jr. 1987. Monitoring herpetofauna in woodlands of north-western California and south west Oregon: a comparative strategy. Pp. 203-213. In. Multiple hardwood resources. T.R. Plumb, N.H. Pillisbury (eds. Gen. Tech. Regional Environmental Planning. PSW 100) US Department of Agriculture, Forest Service. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 278 APPENDIX A PHOTO DOCUMENTATION www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 View of project site View of project site Agricultural field in the project area View of project site View of stone wall present in project area View of Monitoring activities undertaken on site www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Consultation activities undertaken on site Consultation activities undertaken on site View of stone quarry in the project area Consultation activities undertaken on site View of approach road View of approach road Oriental Garden Lizard Black-headed Ibis www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Common Teal Woolly-necked Stork Wood Sandpiper Indian Roller Green Bee-eater Pied Bushchat www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Long-tailed Shrike Plain Prinia Spotted Dove Rose-ringed Parakeet Black-winged Stilt Indian Cormorant www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Indian Robin Little Cormorant Bar-headed Goose Ruddy Shelduck Black Stork Red-wattled Lapwing www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Great White Egret Intermediate Egret Large Grey Babbler Common Stonechat www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Red-vented Bulbul Indian Pond Heron Chestnut-shouldered Petronia Common Pochard Ruddy Shelduck Langur Nilgai Fruit Bat www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 APPENDIX B DETAILS OF CONSULTATIONS UNDERTAKEN DURING NEEMUCH ESIA PREPARATION www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 S. Location Meeting with Topics of discussion No Date: 19 November 2019 1. Neemuch District Magistrate, along General information sharing on the commencement of ESIA related activities, initial field consultations by ERM with RUMSL officials - Mr Sanjay Verma and Mr Bajaj 2. Tehsil Office Tehsildar in Singoli Tehsil Discussion on background of project and the profile of the land owners present in the identified area; Singoli along with Mr Sanjay Verma (RUMSL) Sgurr team started the drone survey on 22nd November and will take a week to complete. The result is going to be a contour map with details of drainage and water bodies Discussion on ongoing site activities by Revenue Inspector and other staff from Tehsil office; The team on site led by a Revenue Inspector is mapping the exact location of all the patta land within the government land parcels that have been provisionally allotted to RUMSL- while the area was noted on revenue records, the location was not. This exercise is likely to take a month or so (4-6 weeks) and will be ready by mid or late Dec in paper map form. 3. Project site, Introduction Meeting with Discussion on the ongoing activity of site survey; Badawada Revenue Inspector and his Village team The site survey is expected to take about 1 month to cover all three villages; The team is verifying the on ground status of private land parcels and assigned land parcels; however there are no details being recorded for land encroached by the locals; It is unde - which is a significant area (for 2 of 3 villages) and there are no reliable records of this available. Most of the encroachments have been in place for years and some for decades, and been passed down the family to the children. Date: 20 November 2019 4. Badi Village Consultation with a few The water table in the village is low and water is found at 800-900 ft, which is hard water and largely used for residents of Badi Village agriculture; Audio recording www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 S. Location Meeting with Topics of discussion No The household level supply of water is also done through the borewells (400-450ft), by an infrastructure set up by Panchayat that has piped connections to some common water access points in the village as well as to some households as well; There were two quarries operating on lease by mining department, but they are not being used presently; There are no active quarries in the project area currently; Currently, the dependence for land and animal husbandry is higher in the area while some people work as labourers in the nearby quarries, in Rajasthan; agriculture is not solely sufficient for sustenance; There has been damage to the crops due to excess rainfall and there have been compensation payments for the damage, approx. INR 20,000-25,000 per hectare; The crops grown in the area comprise of Garlic, wheat, gram, mustard, pulses, etc.; Opium (Afeem) cultivation is also undertaken by one farmer, who has the license to cultivate; Opium crop fetches proceeds from sale of Poppy seeds, the flower and the case; thus leading to more profits. 5. Kawai Village Consultations with village Discussion on the concerns of people on inclusion of land encroached by them for project; Rajput hamlet groups comprising of Rajput Community and a Discussion on the aspect that only a small fraction of the total area encroached is put in records for payment few other people of fines, while the actual on ground encroachment is much larger and unaccounted for; Audio recording This practice is to get the names of families registered against land, and simultaneously limiting the amount of fines to be paid for the land encroached actually, which would be higher; 6. Kawai Village Consultations with village The village comprises of majorly Dhakad, Gujjar and Rajput communities and some households belonging to Dhakad hamlet groups comprising Dhakad Bhil, Balai and OBC communities. The village has about 100 Households and comprises of approx. 600 Community, and a few people; other people Audio recording The villagers depend on agriculture and animal husbandry. The Bhil community largely has Goats and Sheep while the Gurjars and Dhakads have cows and buffaloes; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 S. Location Meeting with Topics of discussion No The land holdings in the villagers are relatively higher amongst Dhakads; There is understood to be lot of land that is encroached by the villagers which they believe can be made productive by putting in some investment and effort; The villagers have got to know a and preparing land for cultivation; There have been reportedly a lot of complaints and protests by the villagers at the Tehsil office and other offices at District level; The water for irrigation is available at a depth of 600 ft and almost all the fields have either wells or tube wells; It was also established during consultations that the affluent families were undertaking encroachment on the land due to higher cost involved in preparation of land to make it cultivable 7. APMC Yard, Discussion with the staff at Discussion on nature and extent of crops grown in the area and sold in the Mandi; Singoli APMC yard Kharif crops comprise of Maize, Soyabean, groundnut, pulses, etc.; Maize is used for poultry business in Haryana, Soyabean is used for oil extraction, Groundnut is used for consumption as well as oil extraction; Rabi crops in the area comprise of Wheat, Gram and Mustard; Wheat cultivation in the area has been good in the area in the last year due to good rainfalls; Jow is a less water intensive crop and is grown in absence of abundant rainfall; Understanding of how Minimum support price for a crop is determined and the measures in place for implementation of MSP; Rates are determined on the basis of quality of crops, the crops with higher water content are sold at relatively lower prices; The rates of crops in the area are published in newspapers as well as an online portal Agmanet; Understanding of the press followed for registration of farmers and methods in place to check for legalities associated with procurement of crops by Government. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 S. Location Meeting with Topics of discussion No Date: 21 November 2019 8. Bardawada Consultations with The villages comprises of Dhakad households in majority; Village - farmers- Badawada village The women are aware of the upcoming Solar project near the village; There are certain people in the village who have encroached land in the area identified for the project; The encroachment is done by the residents of Badawada village and some residents of other villages as well; Some of the encroachers also possess their 5 Bigha ( 1 hectare) Patta land assigned by the Government; The criteria followed for assigning land by Government was reportedly landlessness; There are understood to be certain households that have sold their assigned lands to the local villagers and are now working as labourers, etc.; The women are largely engaged in the agricultural activities during the day and household work thereafter; There is 1 women headed household in the villages and these families are reported to undertake cultivation on their respective fields; Additionally, the extended family is also reported to support these women headed households; There are reported to be grazing farms set up on the encroached land parcels where livestock is allowed to graze against a payment of INR 1000 per livestock head per year; Milk from the livestock is used for self-consumption; Drinking water is generally easily available in the area, with limited water scarcity problems reported during summer seasons; Women have the responsibility to carry water from the community water points to their respective households; Some families depend on other families for water against payment for the same; Borewell construction activity takes upto INR 60,000 even if there is no water availability. In case water is found in the borewell, the cost of construction goes up to 1.5 lacs INR. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 S. Location Meeting with Topics of discussion No 9. The discussion focussed on the general socio-economic profile of the village in terms of occupation, land group- farmers- holdings, dependence on land and other occupations, infrastructure, etc. Bardawada village This village also supported the fact that the affluent families have encroached more land compared to the families with limited or no land holdings 10. Tehsil Office, Discussion with Patwari of Discussion on the land and encroachment aspects in Badi and Kawai villages; Singoli Kawai and Badi Villages Photographs of maps with Anupreet- to be put together. 11. Badi Village Consultations with The discussion focussed on the general socio-economic profile of the village in terms of occupation, land husband of female holdings, dependence on land and other occupations, infrastructure, etc.; Sarpanch of Badi Discussion on seasonal agricultural practices and the profitability from the various crops grown in the area; Panchayat It has been reported by the husband of the Sarpanch, that about 25% of the village area is under cultivation; Village Consultations The farmers sell their agricultural produce to individual traders and onot in the Government Mandis due to Discussion with flexibility in terms of time of sale, lack of documentation required, preference for getting cash payments, Sarpanch and a few against the less preferred practice of receiving cheques for sale in Mandis; women from the community People from Kawai village reportedly sale through Mandi as they are affluent Approx. 35% households in the village have private land holdings; A lot of people are engaging in encroachment of the Government land and using it for cultivation; There are a lot of men from the village that undertake labour work in stone quarries in and around the village; Gurjar community households possess 15-20 buffaloes and the excess milk is sold in Singoli in a dairy or door to door. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS REFERENCES Final ESIA Report APPENDIX C NOTE ON LAND REQUIREMENT AND PROCUREMENT PROCESS www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 293 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report INTRODUCTION This note was initially prepared to inform the discussion on land procurement across various categories, to help with the planning process, and to provide a clearer understanding for the ESIA and the RAP work. Since it is now being appended to the ESIA (to reflect the intermediate processes that informed the ESIA and RAP development), the figures have been updated to reflect the land procurement in reference to the Final DPRs (Aug 2020) and the updated solar park boundaries at all the eight unit locations, Other than that, the contents and purpose of the document have not been altered. ERM India Pvt. Ltd. (ERM) has been engaged by Rewa Ultra Mega Solar Limited (RUMSL) to undertake an Environmental and Social Assessment (ESIA) and Resettlement Action Plan (RAP) of three solar parks, including internal evacuation infrastructure and associated transmission lines of aggregate capacity of 1500 MW in the Neemuch, Agar and Shajapur Districts of Madhya Pradesh, . As part of the scope of work for the project, ERM is required to review the land procurement process for the project. While the ESIA will provide a detailed understanding of the land requirement for each sub-project, the procurement process and the impacts from the same, this note provides an understanding of the land procurement process prior to the ESIA submission. This note identifies potential areas of concerns prior to the finalization of the land take so as to allow for a discussion on the need for a change in approach or corrective actions, if any. This note will also inform the planning of the data collection for the RAP. Land Requirement for the Project This section provides an understanding of the land requirement for the three solar parks that comprise the project. Table C.1 Land Requirement Summary for the Project Aspect Neemuch Solar Park Agar Solar Park Shajapur Solar Park Capacity of Solar Park 500 MW 550 MW 450 MW No. of Units Unit 1, 2 and 3 Unit 4- Agar; Unit 5- Unit 6 and 7- Moman Susner Badodiya; Unit 8- South Shajapur Geographical Between 24°59'39.78"N and Susner: 23°55'28.07"N Moman Badodiya: Boundaries 25° 0'38.51"N and 76° 2'21.30"E 23°40'43.40"N and 75°13'26.82"E and Agar: 23°44'38.58"N and 76°15'18.53"E 75°14'48.53"E 76° 7'1.26"E South Shajapur: 23°14'12.98"N and 76°13'20.31"E Total Land Area 1092.7 ha 1407.08 ha 987.2 ha Total Government land 968.8 ha 1273.36 ha 860.6 ha Total Patta Land 87.7 ha 133.71 ha 5.2 ha Total Private Land 34.5 ha 99.5 ha Note: Patta land comprises of land assigned to certain (at the time) landless households in the project area by the State Government. Households from landless and constitutionally recognised socio- economic backward www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 294 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report communities (SCs and STs) have been assigned the Patta Land by the GoMP 1. This land cannot be sold as per conditions of the patta though special circumstances may be considered by the District Collector, who can allow its sale. Source: Land Data provided by RUMSL, 19 June 2020 Land Procurement Status This section provides an understanding of the land procurement status for the solar parks. it should be noted that the land requirement for all three solar parks includes government land, private land and patta land though the preference is to use government land only and add private land only if the government land is insufficient. RUMSL has initiated the process for land procurement few years ago and first set of allotment letters were received by RUMSL from Revenue Department, Government of MP (GoMP) in 2017. However, the land procurement process for private and patta land has not been initiated yet. The private and patta land procurement is proposed to be undertaken through the provisions of the MP Consent Land Purchase Policy, 2014. However, this will be initiated for the 3 solar parks only once the final project boundary is available, which will include an assessment of the amount of private and patta land requirement for each location. The following subsections focus on the status of government land allotment for the three solar parks. Government Land Allotment for Neemuch Solar Park (Unit 1, 2 and 3) Government land has been procured through allotments and inter department transfers in keeping with the provisions of the Madhya Pradesh Land Revenue Code and conversion of the forest land as per provisions of Forest Conservation Act, 1980. Table C.2 Dates of Government Land Allotment for Neemuch Solar Park Timeline Allotment Letter Number Area Allotted (ha) Village 17-01-2018 7/A-20(3)/2017-2018 238.68 Bardwada, Kawai and Badi 30-05-2017 26/A-20(3)/2016-2017 439.51 Kawai and Badi Total 678.19 Source: RUMSL 678.19 ha (out of total 1065.65 ha government land identified) is allotted to RUMSL through two allotment letters in the year 2017 and 2018 respectively. Both these allotment letters predate the MP Revenue Code Amendment Act 2018 2. The process for procuring 75.72 ha of patta land and 18.62 ha of private land is yet to be initiated and will be started after finalising land requirements. Government Land Allotment for Agar Solar Park (Unit 4, and 5) Table C.3 provides a summary of the land allotment for the Agar Solar Park which has been undertaken between Nov 2016 and Jun 2019. 1 Special permission needs to be sought from the District Collector to allow the sale of patta land, and this is granted only under s not 2 Aspects of the amendment relevant to the allotment of land pertain to the clarified definition of freehold land holders being , the treatment of completed freehold process as qualifying for this , and all pending matters being treated as cancelled. The amendment also designates levels of the state administration who are empowered to hear matters of dispute. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 295 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report Table C.3 Dates of Government Land Allotment for Agar Solar Park Allotment Date Allotment Letter Number Area Allotted (ha) Villages 28.02.2019 7/A-19(3)/2017-2018 56.33 Bijnakhedi 28.02.2019 6/A-19(3)/2017-2018 70.53 Dudhpura 21.06.2019 31/B-121/2019-20 14.95 Dudhpura 20-06-2019 5/A-19(3)/2017-18 159.25 Karwakhedi 28.02.2019 4/A-19(3)/2017-2018 28.3 Kasaidehriya 20.06.2019 3/B-121/2019-20 197.14 Ladwan 28.02.02019 2/A-19(3)/2017-18 16.83 Madhopur 21.01.2019 1/A-19(3)/2017-18 34.92 Piplya Kumar 04.01.2018 9/A-19(3)/2017-18 60.2 Naharkheda 09.08.2018 9/A-19(3)/2017-18 26.69 Naharkheda 30.11.2016 48/19(3)/2015-16 55.62 Palda 02.01.2018 8/A-19(3)/2017-18 56.99 Palda 02.01.2018 11/A-19(3)/2017-18 161.16 Pipliya Nankar 06.01.2018 10/A-19(3)/2017-18 176.63 Umariya 09.08.2018 10/A-19(3)/2017-18 155.83 Umariya Total 1271.37 Source: RUMSL The entire government land required for the project (1271.37 ha) has been allotted to the project over the period between 2017 and 2019, and 510.6 ha was allotted prior to MP Revenue Code Amendment Act 2018. The land procurement process for the remaining 133.03 ha of private and patta land is yet to be initiated. Government Land Allotment for Shajapur Solar Park (Unit 6, 7, and 8) Table C.4 provides a summary of the land allotment for Shajapur Solar Park which took place between May 2017 and Jun 2019. Table C.4 Dates of Government Land Allotment for Shajapur Solar Park Timeline Allotment Letter Number Area Allotted (ha) Villages 26-05-2017 03/A-19(3)/2016-2017 149.91 Dehripal, Parsula, Kadula, MalyaHedi, Burlay, Jaawdi, Bhandedi, Saagdiya, Baandahedi, Peepalkheda, Dopada, Bijana, Kheriyaema, Kumhariyakhas, Dangicha, Jaaman 11-12-2017 26/A-19(3)/2016-17 618 Dehripal, Parsula, Favka, Jaavdi, Burlay, Chooma, Bijnakhedi, Dhatravada 26-05-2017 02/A-19(3)/2016-17 320.969 Kukdeshwar, Baamniyakhedi, Bordi, Khakri, Majhniya, Rehli, Rulki, Dhanda Pidoniya, Goyla, Aakya Chauhani, Palsaavad Son, Desrapur, Khokriya Tonk, Hanoti www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 296 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report 28-06-2019 03/A-19(3)/2019-2020 88.09 Kukdeshwar, Bamniyakhedi, Bodi, Khakri, Majhaniya, Rehli, Rulki, Tanda Pindoniya, Goyla, Aakya Chauhani, Palsawaad Son, Besrapur, Khokriya Tonk, hanoti, Total 1176.97 Source: RUMSL Of the 1349.2 hectares identified for the project, 1176.97 ha was allotted to the project over 2017- 2019 out of which 1088.88 ha was allotted prior to MP Revenue Code Amendment Act 2018. The land procurement process for the private (99.5 ha) and patta land (5.2 ha) is yet to be initiated. Documentation of the Land Procurement Process This section provides an understanding of the land procurement process followed for the government land allotment for the solar parks. Roles and Responsibilities for Land Parcel Finalization and Procurement The overall land procurement process is being led by RUMSL. In this process, RUMSL is supported by administrative agencies such as the revenue department, third party entities for providing design and environmental and social support. IFC is engaged as a transaction advisor to RUMSL and is also providing overall guidance ensuring that the land take process is in keeping with the applicable reference framework for the project. The following table provides an understanding of the roles and responsibilities of the various agencies involved in the land identification and take process. Table C.5 Roles and Responsibility for Land Allotment/Procurement for the Project Entity Roles and Responsibilities RUMSL is overall responsible for coordination with the various other stakeholders involved in the land procurement process. as well as resolving issues that come up in terms of need for additional land to be identified or the manner in which the E&S sensitivities need to be RUMSL incorporated into the project land requirement. After completion of the process, the formal possession of the land will be given to New and Renewable Energy Department Government of Madhya Pradesh (MPNRED). The land department, includes offices such as the District Revenue Officer (first point of contact for RUMSL), Superintendent of Land Records, village Administrative office, Patwari, village Assistant amongst others. It is headed by the District Collector. This department is responsible for the maintenance of a database (textual, tabular and spatial) of all land records in their jurisdictions, ownership, patta land, records of potential encroachments on government land (though this may not be accurate or confirmed on site), etc. Revenue and Land During the process of land allotment, this department is responsible for processing the land Reforms allotment request, in terms of verifying the land parcels requested, identifying any existing Department, land usage or encumbrances and preparing the report for the Tehsildaar and District Madhya Pradesh are responsible for undertaking the Tarmeem process; which will be discussed in subsequent sections. The District Collector (DC) is the key officer contacted by RUMSL for any land related matters. Application for land allotment is submitted to the DC who then forwards it to the district administration and Land Revenue Department officials for further processing. The DC is the authority for final communication on the decisions made on the land. He has the www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 297 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report Entity Roles and Responsibilities authority to approve or reject allotment requests for any land parcels required for development projects. The DC will also decide/approve (after consultations) how the issue of patta land is to be addressed, in this project (whether there could be a land swap of pattas allotted but where possession has not been taken by the allottee, or other arrangements) The Tehsildar, is responsible for supporting the District Collector in the process of land allotment and functions at the tehsil level. This includes coordinating the process of land verification at the Tehsil level, hearing grievances on the proposed land allotment and making recommendations to the District Collector on the suitability of the allotment. The Tehsildar is also overall responsible for the coordination of the Tarmeem process and handing over the results of the same to the Project, which will be discussed in subsequent sections. The Superintendent of the Land Records (SLR), reports to the District Collector. The SLR maintains a database of all land ownership records in the district (such as khasra numbers, usage of land parcels, ownership, potential encumbrances such as encroachments or disputes, patta allocation etc.) and is the key officer involved with the process of verification and physical demarcation of land for allotment to the Project. Sgurr, a technical consultant engaged by IFC (as transaction advisor) is supporting RUMSL in providing technical guidance and expertise in project boundary finalization, taking into account aspects such as site suitability and adequacy, hydrology, geology, contouring, solar irradiation etc. s also attempted to minimize the E&S risks associated with the project through avoidance measures, such as: Sgurr Energy India 1. Minimizing impact on private land and patta land Private Limited 2. Avoiding clusters of structures or habitations- both formal government recognized abadi area) and encroachments/ squatters (residential) 3. Avoiding water bodies to the extent possible 4. Avoiding large tree clusters Based on these considerations, Sgurr optimized the project boundary and layout in June 2020. This optimized project boundary served as the basis of the RAP. ERM, an Environmental and Social Consultant, has been engaged by RUMSL to undertake an Environmental and Social Impact Assessment (ESIA), Resettlement Action Plan (RAP) and FPIC process for the project. Prior to this, ERM also undertook the Scoping for the proposed project, on Environmental and Social aspects, based on which the project project boundary optimization process. For this purpose, ERM has analysed the drone imagery collected and provided by Sgurr to identify the following environmental and social sensitivities: Individual structures or clusters of structures, especially residential ERM India Pvt Ltd Any visible improvements on land, such as construction of boundary wall or bore well Water bodies Areas potentially under agricultural land use this data, along with the land ownership data and Tarmeem data allows for identification of potential encroachment and squatting (for agriculture) Areas under use for fodder collection, and open grazing Large tree clusters www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 298 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report Entity Roles and Responsibilities This information was then shared with Sgurr through RUMSL, as part of a workshop where certain principles of avoidance were identified with RUMSL, for Sgurr to consider in the project boundary optimization process. This E&S sensitivity identification process and avoidance exercise undertaken has resulted in the reduction of land area as given below, for each Unit 7.5 ha (Unit 1) 14.36 (Unit 2) 1.35 (Unit 3) 56.46 (Unit 4) 20.8 ha (Unit 5) 26.02 (Unit 6) 55.12 (Unit 7) 257.8 ha (Unit 8) IFC is the transaction advisor for RUMSL. IFC is advising RUMSL in implementing this International project in a manner that is consistent with the applicable reference framework (WB OP and Finance IFC PS), in addition to the applicable legal frameworks. Their role includes activities like Corporation discussions on land finalization and avoidance measures. World Bank RUMSL is in discussion with World Bank to provide financial loan for the Project. (1) (1) Reference: DPR, Neemuch Solar Park, July 2020; DPR, Shajapur Solar Park August 2020 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 299 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report Land Procurement Process The following subsections provide an understanding of the land procurement process followed for the government land allotment. Table C.6 Land Procurement Process Timeline Key Activity Activity Details Status Remarks Completed RUMSL (through assistance of Knight Frank) identified potential project areas, with large chunks of unused government land; Identification of This was based on the revenue records, information available in the public domain and consultations 2016- potential project with the revenue and land reforms department 2017 areas by Knight Frank The potential options were discussed in a workshop between RUMSL, World Bank and Knight Frank in 2017 and the proposed project areas were finalized A high-level environmental and social baseline was prepared for the proposed project areas Ongoing The land allotment This activity included the process of application for land allotment by RUMSL, verification at the Tehsil process for and village level, invitation of grievances and recommendations by the revenue and land reforms Government land is department for allotment to send to the District Collector presently ongoing. The process of Also, as part of the allotment of Novemb the revenue and land reforms department: Project boundary government er 2016- optimization exercise, land for the - Ensuring that a threshold level of government land is secured for grazing of livestock (calculated Ongoing a need for new land Project is being for each village at a minimum of 2% of total agricultural land available in the village) given that parcel procurement undertaken these livestocks are a key factor in the village nutrition security and economy (including has also been agricultural production), identified, which - Avoid land under the Nistar1 rights in the village (as noted in the Nistar Patrak) this may also includes government include grazing areas, in addition to easements, cultural areas and other community use areas land. The allotment 1 Under Section 234 of the MP Land Revenue Code (LRC), The District Collector shall prepare a Nistar Patrak for every village embodying a scheme of management of all unoccupied land in the village. The Collector may divert unoccupied land, for exercise of Nistar rights for pasture, grass, bir or fodder reserve (clause b) subject to a minimum of two (2) percent of the total agricultural land of that village. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 300 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report Timeline Key Activity Activity Details Status Remarks - Avoid allotted patta land, process for these new land parcels is - Avoid any land already allotted for other projects or to any other department for different yet to be initiated purposes (like water shed activities, etc.), - Avoid privately owned parcels to the extent feasible. - It should be noted that in certain cases, land was earlier allotted for specific purposes, such as a PanchVan1 in Agar solar park. However, since the land was never used for the intended purposes, the Sub-Divisional officer, through a stipulated procedure, reversed the allotment and community in Susner, it was found that the community was not aware of such a land ( panch van)being allotted and thus never used it for the intended purpose. For the Neemuch Solar Park, 678.19 ha (out of total 967.98 ha government land identified) is allotted to RUMSL through two allotment letters in the year 2017 and 2018 respectively. Both these allotment letters predate the MP Revenue Code Amendment Act 2018. The process for procuring the 75.72 ha of patta land and 18.62 ha of private land is yet to be initiated.. For the Agar Solar Park, 1271.37 ha is so far allotted to the project over 2016-2019 and 510.6 ha was allotted prior to MP Revenue Code Amendment Act 2018. The land procurement process remaining 133.03 ha of private and patta land is yet to be initiated. For Shajapur Solar Park, 1176.97 ha is allotted to the project over 2017-2019 and 1088.88 ha was allotted prior to MP Revenue Code Amendment Act 2018. The land procurement process for the private (10.1 ha) and patta land (191.24 ha) is yet to be initiated. Based on the Completed The potential project boundary and tentative solar park layout was superimposed on the village available boundary and land parcel boundaries data for each project site. satellite 2018 imagery, For this purpose, the land allotment details provided by RUMSL were analysed by Sgurr which preliminary included details of Khasra, land ownership, land use as per government records, the total khasra area layouts were and the area allotted to the project. In addition to this, RUMSL made available the village khasra maps developed, and through MAP IT for the purpose of analysis. 1 Forest Department Land www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 301 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report Timeline Key Activity Activity Details Status Remarks a land area Based on this analysis, the land area statement and total land available for the layout was determined statement was and tentative project boundary maps were prepared. The analysis resulted in identification of existing identified. land ownership of government and private khasras, and identification of sensitivities within the project layout. As part of this exercise, land parcels that had potential patta lands allotted within them or where only a portion of the government owned Khasra was allotted was identified, however, the demarcation of the sub-khasras was not available on the village level maps made available by MAP IT. This was further discussed with RUMSL, IFC and World Bank and the need for a Tarmeem1 process was identified (to survey and mark out the boundaries of the patta land (or sub-khasra), within the khasra map and to match the tabular patta land data. Completed This scoping report ERM India Pvt Ltd was engaged by IFC to undertake an Environmental and Social Scoping also informed the Assessment for the proposed project. preparation of the The Final Scoping report was submitted in March 2019 and provides an understanding of the key ToR for the August environmental and social issues pertaining to the project ESIA/RAP and FPIC Environment 2018- process and Social As part of the scoping report, certain recommendations in terms of exclusions and avoidance were March also made for the project, including avoiding certain settlements/ clusters of structures within the Scoping Report 2019 proposed Neemuch project area; including potential Bhil settlements As part of the scoping assessment, the need for project boundary optimization and preparation of a RAP and undertaking the FPIC process was identified Completed A drone survey for the existing land use and land utilization was undertaken, to get updated Novemb information, in addition to ownership data. Drone Survey er 2019- The results from this drone survey were used to undertake a contour mapping and undertaking a Conducted and January drainage investigation for the proposed project site. The results of these investigations were used for data processing 2020 the process of project boundary demarcation exercise, and was to be layered with more specific ownership data from the Tarmeem process (below). 1 Tarmeem: ground verification process to confirm land ownership and to demarcate any patta land and/or private land that may have been identified within a government khasra www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 302 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report Timeline Key Activity Activity Details Status Remarks Completed It is understood that In keeping with observations on the land allotment details, RUMSL; through the Tehsildar and the results of the Revenue and Land Reforms Department initiated the Tarmeem process for all three sites. Tarmeem process aar, Tarmeem usually refers to amendments to land were provided on records, revision of land division, land use, land occupancy etc. and can involve multiple specific physical, hand-drawn activities as per the requirements. This process is done by Revenue Department from time to time in maps (that were not - the normal course of action (with or without any project). As an outcome of this process, following can georeferenced) to be achieved: Revisions in the Patwari maps, Khasra books, Digital database, other revenue records, RUMSL, due to preparation of survey reports etc. This process is undertaken by Officials from the Revenue which there were Department, usually inclusive of the Tehsildar, RI, Patwari etc. mismatches in terms of overlaying the Note: Tarmeem results to - The SLR, RI and Patwari who were consulted, say that Tarmeem is a process whereby Revenue the project boundary Department officials (SLR, RI and Patwari) make revisions to the government land records that drawings (done by Decemb include the Patwari maps, survey reports, satellite imagery, khasra books etc.; Sgurr). This exercise er 2019 Tarmeem - In most cases, Tarmeem involves limited or no physical inspection on the ground. has certain February Process limitations, which will 2020 - However, in the case of this Project, whereas after allotment the project could have moved into have to be verified at the land survey already done by the Revenue Department; and the gaps were noted between tabular and spatial stage, prior to formal extent of land parcels on the maps.; Hence, Tarmeem became an important step in boundary possession by finalisation, RUMSL. As per The results of this data were then aimed at allowing for the identification of patta lands within the consultations proposed project boundary and potentially carve out the same; depending upon the overall land undertake with availability DREO, the Patwaris, the land survey was It should be noted that the Tarmeem process did not include an identification of encroachments or undertaken prior to squatting on the project area, as the records of the same are not maintained by the Revenue June 2020 department. ERM is in the process of identifying these potential encroachments and squatting through a process of excluding private and patta land from the area that appears to be under agriculture for the Neemuch site. This process cannot be used in Agar and Shajapur as encroachment for agriculture is reported to be unlikely and is not reported during consultations or during field observations. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 303 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report Timeline Key Activity Activity Details Status Remarks The extent of this encroachment needs to be understood in order to determine any potential impacted squatted government land. These entities (in addition to land owners and users of private and patta land) will be the focus of the resettlement surveys and the entitlement matrix; Note : The village maps being used during Tarmeem are dated 2004 and 2005. The site observations show that there are many village roads that are not reflected on these maps. While some updates may have been made, the boundaries and land parcel profiles may not be updated, and if these are digitized without field verification, the errors will be transferred to the GIS database as well.. Considering these maps are used to for digitization by the Revenue Department on MAP-IT; there is high possibility that they are not updated either. This will reflect in further discrepancies in digitization of the project footprint based on MAP-IT data alone, without field verification. Completed It should be noted that due to certain ERM analysed the drone imagery made available for all three sites, for identifying the following: issues with superimposing the - Any improvements on the land parcels, including structures, boundary walls, tube wells etc. Tarmeem process - Water bodies results to the existing Analysis of - Large tree clusters project boundary February Drone Survey maps, the project 2020 Imagery for E&S - Any land parcels which appeared to be under agricultural land use boundary Sensitivities The results of this analysis was shared with RUMSL and Sgurr and a workshop was held in Bhopal on optimization process 25th February 2020 between RUMSL, Sgurr and ERM to discuss the findings of the drone survey, could not be pose of this workshop was to completed as part of enable for the project boundary optimization process to be conducted based on the information the workshop in available Bhopal and was undertaken separately Development of Not The optimized project April Optimized puts on E&S sensitivities and the drone imagery Completed boundary for 2020 Project analysis, optimized project boundaries for the project areas are being prepared. Neemuch was Boundary submitted on 13th www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 304 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report Timeline Key Activity Activity Details Status Remarks This project optimized boundaries will be discussed between RUMSL, Sgurr and ERM and any final April 2020. The changes needed in the layout will be identified optimized project boundaries for Agar This optimized boundary will then form the common base imagery, to be used by different technical and Shajapur are teams including ERM for the ESIA, RAP and FPIC process pending. As part of this exercise, a certain portion of the proposed project boundary had to be carved out due to (a) incorporation of exclusion and/or avoidance measures; (b) technical feasibility criteria such as slope and contiguity. For the Neemuch site, 5.46 ha was deducted due to the avoidance measures identified and 38 ha was deducted due to technical feasibility issues. Due to this, in order to maintain the project capacity, additional land requirement for the projects has been identified. For the Neemuch site, an additional land requirement of 8.24 ha been identified. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 305 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report Next Steps The following next steps need to be undertaken for the land procurement process, where RUMSL taking final possession of the land required for the Project (government, patta land and private land) after completion of all formalities (including compensation payments) is considered the concluding step General Completion of the project optimization process for Agar and Shajapur solar parks Finalization of project boundaries for all three sites, through a discussion between RUMSL, Sgurr and ERM Initiation of the RAP primary data collection process based on the final project boundary Final hand over of the project land to the concerned developers after the completion of successful of NRED) will undertake the entire land procurement process; including the purchase of private and patta land parcels. RUMSL will have a back-to-back sublease agreement with each of the Solar Project developers that are selected as a part of the tender/bidding process. Once the sublease agreement is signed, the Solar Project developers would be responsible for development of solar project as per the agreed terms of the lease, on the allotted land parcels. Government land Initiation of land allotment process for new land parcels identified for maintaining the unit capacities as part of the optimization process (if any). Presently additional land requirement has been identified only for Neemuch Unit 3, as presently there is a shortage of land for approx. 2 with RUMSL, prior to initiating additional land take, RUMSL is attempting to optimize the existing land available, by either (a) reducing the land per MW in keeping with standards followed in other states such as Kerala and Gujarat (b) adjusting the short fall in Unit 3 area with the excess land available in Unit 2; As part of the optimized project boundary for Neemuch, a large water body towards the south- east corner was included in the project footprint. While the concerned land parcel (with the water body) has been allotted to the project in totality, RUMSL has reconfirmed with revenue department and clarified that the water body is not included in the area for the solar park. However, data available with Sgurr indicates that water body is included in solar park area. This issue needs to be resolved and records (of Project are and boundary) be updated across all datasets for use in the studies. On the issue of encroachments (for agriculture), RUMSL has identified potential limitations with providing any compensation to opportunistic encroachers. According to the discussion with RUMSL, most of the encroachers in the area are opportunistic in nature, and have other land holdings in the village or neighbouring villages. Thus the encroached land is not critical for these encroachers in terms of livelihood or sustenance. One of the key concerns RUMSL had about providing entitlements to these opportunistic encroachers was setting a precedence for other projects in the state. However, RUMSL also acknowledged that there may be certain households who are dependent upon the encroached land for their primary source of livelihood. In such a situation, the entitlements identified in the ESMF and the other applicable regulations will be followed. The profiling on the nature of the encroachments (opportunistic/need based) has been done as part of the RAP survey. The preliminary entitlement matrix prepared by ERM has been revised based on the information collected from RAP surveys. Similar to encroachments, from the review of drone imagery and observations during site visits, a number of squatters (structures for residential or agricultural purposes) have been identified within the proposed project boundary. According to the discussion with RUMSL, most of these www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report structures are likely to be seasonal structures used only during the agricultural season, with the primary residences being located within the main village abadi area. This will be verified during the RAP survey and entitlements will be identified in keeping with the nature of use and consideration. This will be further revised once the RAP surveys are complete There may also be situations where excess land has been allotted for a unit (such as in the case of Agar). In such a situation, RUMSL will identify the final land requirement for the project, based on the purchase process of private and patta land. Once the private and patta land purchase process has been completed, if any excess government land remains, the same will be returned to the revenue department following the due process. Private and Patta Land The procurement of the private and patta land is to be done through the provisions of the MP mutual consent policy 2014. This process will be initiated once the project boundary optimization process is complete. Based on the discussions with RUMSL, it is understood that they are considering the option of a land swap for Patta land parcels wherever the allottee has not taken possession yet (subject to approval by the DC, consent by the allottee and availability of alternate land for the patta). For other patta land that is being used by the allottee, purchase through the mutual consent policy will be preferred. Though the land swap process is considered a lengthy and potentially complex process the option of providing the patta holders an alternate patta land, within the same khasra number will be explored as a first option. Furthermore, the option of acquiring the private and patta land parcels will remain, in case the negotiations through the mutual consent policy fail or in case there is any existing litigation or dispute on the land parcel. The land acquisition process will be in keeping with the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act 2013. The project needs to ascertain the exact steps to be followed for the purchase of private and patta land. Presently there is lack of clarity in terms of whether the first notification under the RFCTLARR 2013 will be issued prior to the negotiations being undertaken with the land owners and patta holders or will the notification be issued only if the negotiations fail. This will also have an impact on the classification of the land transaction in terms of involuntary or voluntary land transaction in keeping with the IFC PS 5. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report APPENDIX D ENVIRONMENTAL MONITORING RESULTS www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report AMBIENT AIR MONITORING Location : Badi Gav Parameters Sr. Date of Sample Week PM10 PM2.5 SO2 NOX CO URL No. No. Monitoring Reference (mg/m³) 1 19-12-2019 72.3 21.3 10.2 24.8 0.84 TC670919000007072P NIL/AA/12/19/294 I 2 20-12-2019 68.9 19.1 19.3 26.4 0.59 TC670919000007074P NIL/AA/12/19/296 CPCB Limits 100.0 60.0 80.0 80.0 2.00 Minimum 68.9 19.1 10.2 24.8 0.59 Maximum 72.3 21.3 19.3 26.4 0.84 Average 70.60 20.20 14.75 25.60 0.72 150 th 90 Percentile 71.96 21.08 18.39 26.24 0.82 th 95 Percentile 72.13 21.19 18.85 26.32 0.83 th 98 Percentile 72.23 21.26 19.12 26.37 0.84 Location : Kawai Parameters Sr. Date of Sample Week PM10 PM2.5 SO2 NOX CO URL No. No. Monitoring Reference (mg/m³) 1 19-12-2019 63.8 20.4 13.1 27.7 0.80 TC670919000007073P NIL/AA/12/19/295 I 2 20-12-2019 70.1 26.9 9.7 23.7 0.82 TC670919000007075P NIL/AA/12/19/297 CPCB Limits 100.0 60.0 80.0 80.0 Minimum 63.8 20.4 9.7 23.7 0.80 Maximum 70.1 26.9 13.1 27.7 0.82 Average 66.95 23.65 11.40 25.70 0.81 150 th 90 Percentile 69.47 26.25 12.76 27.30 0.82 th 95 Percentile 69.79 26.58 12.93 27.50 0.82 th 98 Percentile 69.97 26.77 13.03 27.62 0.82 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report NOISE MONITORING Kawai Location Chaksodijar Badi Gav Bardawada Arniya Village Date 19-12-2019 19-12-2019 19-12-2019 19-12-2019 19-12-2019 06:00 - 07:00 50.0 52.7 58.4 57.9 44.4 07:00 - 08:00 50.3 56.0 57.8 60.0 52.5 08:00 - 09:00 50.5 57.9 58.6 59.2 52.5 09:00 - 10:00 50.5 56.0 59.6 65.4 56.7 10:00 - 11:00 50.8 55.7 59.3 62.4 63.3 11:00 - 12:00 50.8 55.6 57.2 53.1 57.8 12:00 - 13:00 51.0 59.5 63.8 55.7 39.6 13:00 - 14:00 50.3 51.5 60.7 59.0 46.5 14:00 - 15:00 51.3 48.4 57.8 60.3 53.5 15:00 - 16:00 52.0 50.7 52.8 64.0 51.8 16:00 - 17:00 52.0 53.8 50.1 64.4 59.7 17:00 - 18:00 50.2 47.3 54.5 56.3 62.8 18:00 - 19:00 55.8 52.2 56.1 49.9 56.3 19:00 - 20:00 53.8 58.0 57.5 51.2 42.0 20:00 - 21:00 50.7 54.8 57.6 49.3 43.8 21:00 - 22:00 49.7 52.5 57.8 52.6 37.6 22:00 - 23:00 48.5 53.4 57.6 50.7 40.9 23:00 - 00:00 47.8 52.1 57.6 51.4 34.8 00:00 - 01:00 33.7 51.9 57.6 51.3 38.0 01:00 - 02:00 40.7 52.0 57.8 50.1 34.6 02:00 - 03:00 44.5 52.0 57.9 51.1 33.9 03:00 - 04:00 50.0 53.0 58.0 50.9 35.7 04:00 - 05:00 50.3 52.1 58.0 51.8 35.2 05:00 - 06:00 50.3 51.9 58.1 54.2 39.0 Lmin 33.7 47.3 50.1 49.3 33.9 Lmax 55.8 59.5 63.8 65.4 63.3 L 45.49 50.94 54.98 50.28 34.92 Leq Day 51.56 55.05 58.45 60.08 56.61 Leq Night 47.85 52.33 57.83 51.61 37.20 LDN 54.75 58.94 63.96 60.65 55.09 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR PARKS INTRODUCTION Final ESIA Report TRAFFIC MONITORING www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 APPENDIX E FLOOD LIKELIHOOD ASSESSMENT www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 FLOOD LIKELIHOOD ASSESSMENT (FLA) Approach and Methodology The study includes a high-level review of the hydrology and flooding characteristics of the Site and the surrounding areas. The assessment was done using Site Level assessment and desktop analysis. The Site level assessment was conducted by reviewing the data collected during the Site visit and community consultation. Desktop analysis include review of satellite data, geospatial data analysis, thematic mapping based on ArcGIS, and review of secondary available in public domain. Based on this review, a flood likelihood matrix will be developed with the various attributes to which the Site and area is likely to be sensitive to inundation and flooding. Figure E1 illustrates the methodology to perform FLA. Figure E1: Methodology of flood likelihood assessment Risk Categorization ERM has adopted a qualitative risk based categorization to identify potential risks and vulnerabilities associated with flooding, inundation and waterlogging. The risks are defined considering the likelihood of their occurrence and potential severity of the impact broadly following the risk matrix presented in the table below. Risk = Likelihood of an impact occurring x Potential severity of the impact. Probability of Occurrence Low Medium High Potential Impact Low www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Probability of Occurrence Low Medium High Medium High Note: The study was carried out to evaluate and understand the likelihood of flood impact on the Site only. Risk categorization has been adopted merely for providing broad level perspective on the potential for impact from floods / inundation / water logging on the Site and to emphasize specific areas for further evaluation prior to developing Site specific mitigation measures only. Hydrological Setup The natural waterbodies and Site area settings is presented in Figure E2. Some of the salient features of the Site area are described below: The core zone (2 km radius) around the Site is largely occupied by scrubland with agricultural land, forest land, scattered residential settlements and river channels of the Brahmani River and its tributaries. Brahmani River is located at distances of ~1.6 km, ~3.1 km and ~3.3 km to the South of the Unit 1, Unit 2 and Unit 3 respectively. The River flows in west to east direction. S1 flows near the western boundary of Unit-1 (~300 m west of the Unit-1) along the north to south vector through Bardwada village. A minor stream/nalla originates near the southern boundary of Unit-1 and joins S1. A Pond (hereinafter referred t developed using an embankment across this minor nalla as part of a rainwater harvesting and groundwater recharge scheme for Bardwada village. S2 flows between Unit-1 (~160 m to the east) and Unit-2 (~40 m to the west). S2 originates from Kawai Pond located to the west of Unit-2 and flows along the north to south vector via Kawai village. A seasonal stream/nalla S3 flows between Unit 2 and Unit 3. S3 flows along the north to south vector through Badi Village. S4 flows originates in the south-eastern portion of Unit 3 and flows along the north-east to south- west vector. An embankment has been built along S4 to create an artificial pond (herein after referred to as Badi Pond) which lies along the south-eastern corner of Unit-3. All the seasonal streams/nallas eventually drain into Brahmani River. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Figure E2: Natural Waterbodies and Site area settings Topography and Drainage of the Watershed/Catchment Based on the Digital Elevation Model (DEM) developed for the Site from USGS SRTM1 data set, ERM identified key topographic features in the study area such as topographic highs and lows, natural drainage network and delineated the catchment area of the micro-watershed in which the Site is located. SRTM DEM having a 30 m resolution was used for detailed mapping of the micro watershed in which the Site is located. Based on the topography and drainage pattern, it was found that the Site lies in Brahmani River Basin admeasuring 1,510.61 km 2, as presented in Figure E3. The drainage pattern in the Brahmani River basin comprises of two (2) dominant directions: north to south flowing tributaries, and south-west to north-east flowing tributaries. The Site is located at the central portion of the basin and ~30 km north- west from the confluence of Brahmani River with Chambal River at Bhainsrorgarh Village, in Rajasthan. The Site is located along the left bank of the Brahmani River and the predominant gradient in the region is along the north to south vector. 1 https://earthexplorer.usgs.gov/ www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Figure E3: River basin within which Site is located The digital elevation model (DEM) of the study area (5 km buffer around the Site) is presented in Figure E4. The ground elevation was observed to vary from 600 639 m amsl in isolated patches, followed by areas with elevation ranging between 430 -600 m amsl in the northern portion, 430-400 m amsl in the central portion, and 370-390 m amsl in the southern portion. Continuous gradient of 6.3 m/km, 7.1 m/km and 7.3 m/km were observed to be along the north to south vector in Unit-1, Unit-2 and Unit-3 respectively. Figure E4: Topographic map of the Site and surrounding area www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Most of Unit-1 area falls in the elevation range of 390-400 m amsl. South-western and south-eastern portions of the Site lie along Barwada Pond and S2 respectively, and are the lowest points varying between 390-400 m amsl within Unit-1. The topographical map for Unit 1 is shown in Figure E5. Figure E5: Topographical map of Unit 1 Unit-2 area falls in the elevation range of 390-400 m amsl. South-eastern portion of the Site lies along S3, which is also the lowest point varying between 370-390 m amsl. The topographical map for Unit 2 is shown in Figure E6. Figure E6: Topographical map of Unit 2 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Similarly, Unit-3 area falls in the elevation range of 370-400 m amsl, with south-western portion comprising of areas near S4 and Badi Pond and south-eastern portion were the lowest points varying between 390-400 m amsl within Unit-3. The topographical map for Unit 3 is shown in Figure E7. Figure E7: Topographical map of Unit 3 The site-specific micro-watersheds were delineated and are presented in Figure E8. The Site units fall under four (4) distinct micro-watersheds which are described below: Unit-1 falls into three (3) micro-watersheds namely WS-1, WS-2 and WS-3, Unit-2 falls into two (2) micro-watersheds namely WS-3 and WS-4, and Unit-3 falls under one (1) micro-watershed namely WS-4; WS-1, WS-2, WS-3 and WS-4 admeasures 25.04 km2, 3.18 km2, 20.8 km2 and 28.80 km2 respectively; Several natural nallas/streams were observed to be flowing through the Site Units or its immediate vicinity which intercept most of the runoff from the area; and The flow lines show the flow pattern followed by the surface runoff when the watershed receives rainfall. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Figure E8: Hydrology map for the micro-watersheds Slope Map As per the slope map, the major portion of the study area (5 km buffer around the Site) was observed to be very gently sloping (0 5% slope) and scattered pockets of gently sloping (5 - 10 %). Steep and very steep slopes were observed in the northern portion along the ridges which for the northern boundary of the micro-watersheds. The Site and its immediate surroundings were observed to have very flat to gentle slopes with slopes varying between 0 10%. Based on the topography and slope logging and inundation during rainy season which may be attributed to very gentle slopes. The general slope of the study area was observed to be from north to south. The Slope map is presented in Figure E9. Based on the topography and slope map, most of the areas within the Site appear to be Medium www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Figure E9: Slope map of the Site area and the river basin Analysis of Historical Satellite Imagery ERM analysed the historical satellite imagery of the Site and its surrounding area to identify any events of flooding or inundations. For assessing potential for impacts from flood, inundation and waterlogging at Site, ERM reviewed satellite imagery of Site and surrounding area as available from Google Earth Pro from 2009 till present. Review of historical satellite imagery do not indicate any major developmental activity or significant change in land use. Historical satellite imagery of monsoon season for Unit 1, Unit 2 and Unit 3 are shown between Figure E10 and Figure E13. In unit- 1, low lying area with stagnant water was observed near proposed sub- station 1. Within Unit-2, low lying area with standing water was observed mainly towards the central portion. Badi Pond and Stream 3 were observed within the Unit 3 area. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Figure E10: Historical satellite imagery for Unit 1 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Figure E11: Historical satellite imagery for Unit 2 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Figure E12: Historical satellite imagery for Unit 3 (Badi Pond) www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Figure E13: Historical satellite imagery for Unit 3 (Stream 3) www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR HYDRO-METEOROLOGY PARKS Final ESIA Report Hydro-meteorology Per the Central Ground Water Board (CGWB) Publication 1 (District Brochure, Neemuch District, 2013), the climate of Neemuch district is generally dry, except during the southwest monsoon season. The year can be divided in to four (4) seasons; Winter commences from middle of November and lasts till the end of February. The period from March to about first week of June is the summer season, with May being the hottest month of the year. The southwest monsoon starts from middle of June and lasts till end of September. October and middle of November constitute the post monsoon or retreating monsoon season. The normal maximum temperature recorded during the month of May is 39.80 °C, while the minimum during the month of January is 9.80 °C. The normal daily mean monthly maximum temperature is reported as 31.60 °C and daily mean minimum temperature is 19 °C. Summer is the driest period of the year. The relative humidity generally exceeds 87% in the month of August. Annual Rainfall Pattern Southwest monsoon (i.e. June to September) is considered the most predominant and important climatic feature in Neemuch District and more than 90.5% of the annual rainfall is received during monsoon season. Per CGWB publication, the normal annual rainfall of the District is 797.96 mm. The long term data for annual rainfall indicates that the annual rainfall in Neemuch District during 1980-2018 was 824 mm. The lowest annual rainfall of 394 mm was received in year 2002 and maximum rainfall of 1,352 mm was received in year 2006. However, as per the community consultations, no flooding was reporte Neemuch District during 1980-2018 was shown in Figure E14. Figure E14: Annual rainfall at Neemuch district (1980-2018) Source: India Meteorological Department (IMD) Monthly Rainfall Pattern The monthly variation of the rainfall for Neemuch District was studied for the period of 2014-2018 using the India Meteorological Department district-wise average monthly rainfall data. Details are provided in Table E1. 1 http://cgwb.gov.in/District_Profile/MP/Neemuch.pdf www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR HYDRO-METEOROLOGY PARKS Final ESIA Report Table E1: Monthly rainfall pattern for the period 2014-2018 Year Month Annua l Jan Fe Mar Apr May Jun Jul Aug Sep Oct Nov Dec b 2014 1 0 0 0 0 0 248.1 368.3 208.9 4.3 0 0 830.6 2015 8.3 0 29.3 0 0 83.2 465.3 152.8 2.7 0 0 0 741.6 2016 2.3 0 0 0 0 88.1 222.8 678 86 36.1 0 0 1113.3 2017 1.3 0 0.7 0 0 121.8 386.2 182.3 107 0 0 1.7 801 2018 0 0 0 0 0 143.5 355.2 295 264.7 0 0 0.3 1058.7 Source: IMD, All values in mm. The monthly rainfall variation observed for Neemuch District for the period (1980-2018) is shown in Figure E15. It is evident that May-September months receive substantial monsoon rains. Figure E15: Monthly variation of rainfall at Neemuch district (2014-2018) Source: IMD, All values in mm Maximum Daily Probable Rainfall (25, 50 and 100 Year Return Period) 1 Sub-Zone - , maximum daily probable rainfalls for different return periods for the study area are presented in Table E2. Table E2: Maximum daily probable rainfall at the study area Return period in years Maximum daily probable rainfall in mm 25 < 220 50 < 240 100 < 280 Source: CWC (http://cwc.gov.in/sites/default/files/chambal20subzone201b.pdf) 1 http://cwc.gov.in/sites/default/files/chambal20subzone201b.pdf www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONSULTANCY SERVICES FOR ESIA FOR THREE SOLAR HYDRO-METEOROLOGY PARKS Final ESIA Report Flooding Events Consultations Based on consultation with residents of settlements near Site, it was found that: Brahmani River breached its banks in the years of 2019, 2016, 2010 and 1994 due to excessive rains causing widespread inundation in settlements along the river and SH 9A which is the primary access to the Site; The extent of flooding due to overflow of Brahmani River along its left bank has never exceeded beyond SH 9A. The SH 9A is located ~ 1.3, ~2 km and ~2.5 km south of the unit-1, unit-2 and unit-3; During September 2019, Brahmani River overflowed its banks due to backflow associated with high water levels in Chambal River. Therefore, the seasonal streams draining the Site area were not able to quickly discharge into Brahmani River. Minor effects of backflow were reported in the Site area and ponds. Typically, the seasonal streams/nallas and embankment ponds (built as part of groundwater recharge scheme) along these nallas are dry throughout the year except during monsoons. No history of widespread flooding/ inundation due to overflow from nallas and/or embankment ponds was reported on-Site. However localized inundation in low-lying areas within Site was reported; and The Site and surrounding areas were not reported to be susceptible to flooding due to water levels breaching danger marks in Gandhisagar and Rana Pratap Sagar Dams built across Chambal River. Photographs from Site consultations are shown in Figure E16. Figure E16: Photographs from Community Consultation www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Secondary Data (Flood Zonation and Hazard) In order to understand the flood likelihood in the study area and its potential impact on operations at the Site, ERM has considered the following potential areas of concern: Flooding from seasonal streams flowing through the Site units; Flooding from Brahmani River; Flooding from Chambal River; Flooding from Gandhisagar and Rana Pratap Sagar Reservoirs built across Chambal River; and Waterlogging, and inundation at Site and surrounding area; and In order to evaluate the areas of concern, ERM has reviewed flood likelihood from following perspective: 1. Based on Graphical Models and Maps/Reports from Secondary Sources; 2. 1-D Mapping of Potential Inundation; and 3. Historical Satellite Imagery. Flood Review based on Secondary Sources Several secondary data sources and maps were reviewed to understand the vulnerability of the Site to flooding due to various storm events and scenarios. These are presented below: Secondary Data Analysis of Flood Prone Area Map District Disaster Management Plan, Neemuch As part of the assessment, District Disaster Management Plan for Neemuch District 1 report prepared by MP School of Good Governance and Policy Analysis was reviewed. Per the report, floods and droughts are the major natural hazards of the district. Flood prone areas in the district due to overflow from Gandhisagar Dam (40 km south-east of the Site, along Chambal River) have been marked out (in red) as shown in the Figure E17. Per the map, the Site does not fall under the flood prone area. 1 https://cdn.s3waas.gov.in/s334173cb38f07f89ddbebc2ac9128303f/uploads/2019/07/2019070330.pdf www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Figure E17: Flood affected area of Neemuch district Source: District Disaster Management Plan, Neemuch District Secondary Data Analysis of Flood Risk Map - WRI Aqueduct 1 developed by World Resources 2 Institute (WRI) in collaboration with several research partners was used to ascertain the flooding risk calculated using 50 years of data spanning from 1960 to 2014 for the study region. WRI Aqueduct defines riverine flood risk as the percentage of population expected to be affected by riverine flooding in an average year, accounting for existing flood protection standards. Higher values indicate greater proportion of the population is expected to be impacted by riverine floods. Riverine flood risk are classified into five (5) categories based on probability of flooding as: Low: flooding probability is 0 to 1 in 1000; Low-Medium: flooding probability is 1 in 1000 to 2 in 1000; Medium-High: flooding probability is 2 in 1000 to 6 in 1000; High: flooding probability is 6 in 1000 to 1 in 100; and Extremely High: flooding probability is more than 1 in 100. 1 https://www.wri.org/resources/data-sets/aqueduct-global-maps-30-data 2 Delft University of Technology, Deltares, Utrecht University, Institute for Environmental Studies (IVM), International Food Policy Research Institute (IFPRI), PBL Netherlands Environmental Agency, and RepRisk. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Figure E18 Low to Medium . Figure E18: Flood hazard map of river basin (WRI Aqueduct) Source: WRI-Aqueduct Water Risk Atlas 3.0 (https://www.wri.org/resources/data-sets/aqueduct-global-maps- 30-data) Secondary Data Analysis of Flood Hazard Map - UNEP/GRID-Europe For the purpose of this assessment, Global estimated risk index for flood hazard dataset 1 developed by United Nations Environmental Programme (UNEP) was reviewed. As the name suggest, this dataset includes an estimate of the global risk induced by flood hazard. Unit is estimated risk index from 1 (low) to 4 (extreme). This product was designed by UNEP/GRID-Europe for the Global Assessment Report on Risk Reduction (GAR). It was modelled using global data. Figure E19 hazard map. Patches of flood hazard risk ranging from medium to extremely high were observed along the periphery of major watershed particularly in east, west and south. However, within the 1 https://preview.grid.unep.ch/index.php?preview=dataandevents=floodsandevcat=5andlang=eng www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Figure E19: Global estimated risk index for flood hazard map - UNEP Source: UNEP/GRID Europe (http://ihp-wins.unesco.org/layers/geonode:fl1010irmt) Secondary Data Analysis of Flood Hazard Map - FM Global The Global Flood Map is prepared by FM Global1 using historical data, hydrology and hydraulic scientific data accounting for variable external factors such as rainfall, evaporation, snowmelt and terrain. The Global Flood Map currently displays two (2) hazard flood zones via a 90 x 90 meter grid namely: High Hazard (Pink): Locations in a 100-year flood zone have at least a 1 percent chance of experiencing a flood each year; and Moderate Hazard (Yellow): Locations in a 500-year flood zone have at least a 0.2 percent chance of experiencing a flood each year. Figure E20 map. Per the map, the Site is not prone to High or Moderate flood risk. 1 https://www.fmglobal.com/research-and-resources/nathaz-toolkit/about-global-flood-map www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Figure E20: Flood hazard map (FM Global) Source: FM-Global Flood Hazard Map (https://www.fmglobal.com/research-and-resources/nathaz-toolkit-and- map/flood-map) Secondary Data Analysis of Flood Hazard Frequency and Distribution Map Data Basin Global Flood Hazard Frequency and Distribution is a 2.5 by 2.5 minute grid derived from a global listing of extreme flood events between 1985 and 2003 (poor or missing data in the early/mid 1990s) compiled by Dartmouth Flood Observatory and georeferenced to the nearest degree. The resultant flood frequency grid was then classified into 10 classes of approximately equal number of grid cells. The greater the grid cell value in the final data set, the higher the relative frequency of flood occurrence. Figure E21 illustrates the approximate Site location superimposed on the flood hazard frequency and distribution map developed by Data Basin. Per the map, the Site and its surroundings is not prone to flooding. Figure E21: Flood hazard frequency and distribution map (Data Basin) Source: Data Basin Global Flood Hazard Frequency and Distribution (https://databasin.org/datasets/e5190023c8194691b5b233df41955417) D Mapping of Potential Inundation In order to simulate the inundation and water logging at the Site, ERM used ArcGIS ® to develop 1-D inundation for flood event in Brahmani River that occurred in Aug-Sep 2019 were reported maximum www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 water levels. Based on community consultation, it was reported that the maximum water/flood level at Brahmani River Bridge (~2.7 km south of the Site Units) for the flood event was ~391 m amsl. All topographic levels were extracted from SRTM DEM, the flooded areas reported in the map were areas where the terrain levels were below to corresponding water level. No obstructions/barriers were considered for mapping. All levels reported in meters above mean sea level. The modelling outputs of the 1-D mapping of potential inundation is presented in Figure E22. Figure E22: Inundation map for maximum water/flood levels for flood event in Aug-Sep 2019 Please note that the flood depths and area of inundation are based on secondary data and 1-D mapping, and may not represent the actual figures. Also, the mapping does not consider the inundation due to rainfall run-off from the upper catchment. These factors are considered to be critical for understanding the risks to the Site due to flooding and the High Flood Levels. Also, the topographic (elevation) data for the mapping was extracted from readily available SRTM, and is of a coarse resolution. Based on the 1-D mapping, no inundation was observed on any Site Unit. As per the inundation mapping results and secondary data collected, the Site is to flooding from Brahmani River. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Likelihood of a Flooding Event Based on the above-mentioned findings, a likelihood analysis of potential flooding event in and around the Site has been undertaken. The same has been presented in the Table E3 below. Table E3: Likelihood of flood evaluation Likelihood Attributes High Medium Low Site Setting Unit-1 is in close proximity of S1, S2 and Bardwada Pond, Unit-2 is in close proximity of Kawai Pond, S2 and S3 and Unit-3 is in close proximity of Badi Pond, S3 and S4; The Site Units are located along the left bank of Brahmani River. Brahmani River is located at distances of ~1.6 km, ~3.1 km and ~3.3 km to the South of the Unit 1, Unit 2 and Unit 3 respectively; Site Units are located ~30 km north-west from the confluence of Brahmani River with Chambal River; Two major dams namely Rana Pratap Sagar (~35 km south-west of the Site units) and Gandhi Sagar (~50 km south-west of the Site units) are built across Chambal River at the upstream of the Site. Watershed Characteristics The Site lies within the Brahmani River Basin. The Site is located at the central portion of the basin and ~30 km north-west from the confluence of Brahmani River with Chambal River at Bhainsrorgarh Village, in Rajasthan. The Site is located along the left bank of the Brahmani River and the predominant gradient in the region is along the north to south vector; The Site units is located in a rural setting surrounded primarily by scrub land followed by forest land, agricultural land, residential settlements and water bodies. Historical Flooding and Inundation Events Per community consultation, it was found that Brahmani River breached its banks in the years of 2019, 2016, 2010 and 1994 due to excessive rains causing widespread inundation in settlements along the river and SH 9A which is the primary access to the Site; The extent of flooding due to overflow of Brahmani River along its left bank has never exceeded beyond SH 9A (~ 1.3, ~2 km and ~2.5 km south of the unit-1, unit-2 and unit-3); During September 2019, Brahmani River was overflowing due to backflow associated with high water levels in Chambal River. Therefore, the seasonal streams draining the Site area were not able to quickly discharge into Brahmani River. Minor effects of backflow were observed in the Site area and ponds. Per community consultation, no history of widespread flooding/ inundation due to overflow from Brahmani River, nallas and/or embankment ponds was reported on-Site. However localized inundation in low-lying areas within Site was reported. Hydro-meteorological Data Average annual rainfall for period of 1980-2018 for Neemuch was 824 mm with the highest annual rainfall of 1,352 mm recorded in 2016; Maximum daily probable rainfall for 25, 50, and 100 year return periods in Neemuch District are <220 mm, <240 mm, and <280 mm respectively; Hydrological and Geomorphological Data Catchment Analysis www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Likelihood Attributes High Medium Low The Site and its immediate surroundings were observed to have very flat to gentle slopes with slopes varying between 0 10%. In the Site area, the general slope of the Site area was observed to be from north to south. Continuous gradient of 6.3 m/km, 7.1 m/km and 7.3 m/km were observed to be along the north to south vector in Unit-1, Unit-2 and Unit-3 respectively. Most of Unit-1 area falls in the elevation range of 390-400 m amsl. South-western and south-eastern portions lying near Barwada Pond and S2 respectively were the lowest points varying between 390-400 m amsl within Unit-1. Unit-2 area falls in the elevation range of 390-400 m amsl. South- eastern portion along the S3 were the lowest points varying between 370-390 m amsl. Similarly, Unit-3 area falls in the elevation range of 370-400 m amsl. South-western portion comprising of areas near S4 and Badi Pond and south-eastern portion were the lowest points varying between 390-400 m amsl within Unit-3. Based on the topography and slope maps, the Site area does not logging and flooding during rainy season which may be attributed to very gentle slopes. Secondary Data Review Flooding and Inundation Per the District Disaster Management Plan Neemuch District, the district is prone to floods. It was found the Site is not prone to flooding due to overflow from Gandhisagar Dam (40 km south-east of the Site, along Chambal River). Per the global estimated risk index for flood hazard map developed by UNEP/GRID-Europe, the Site is not prone to flooding; Per the global flood hazard map developed by FM Global, the Site is not prone to high or medium flood risk; Based on Aqueduct Based on global flood hazard frequency and distribution map developed by Data Basin, the Site and its surroundings is not prone to flooding. Based on the observations from the above-mentioned table, it appears that the overall likelihood of flooding event and its impact in and around the Site may be considered as . Conclusions and Recommendations Conclusions Based on the observations from the above-mentioned table, it appears that the overall likelihood of flooding event and its impact in and around the Site can be considered to be . The main high probability attributes are as follows: The Site Units are located along the left bank of Brahmani River. Brahmani River is located at distances of ~1.6 km, ~3.1 km and ~3.3 km to the South of the Unit 1, Unit 2 and Unit 3 respectively. The Site Units are located ~30 km north-west from the confluence of Brahmani River with Chambal River; Unit-1 is in close proximity of S1, S2 and Bardwada Pond, Unit-2 is in close proximity of Kawai Pond, S2 and S3 and Unit-3 is in close proximity of Badi Pond, S3 and S4; Per community consultation, it was found that Brahmani River breached its banks in the years of 2019, 2016, 2010 and 1994 due to excessive rains causing widespread inundation in settlements along the river and SH 9A which is the primary access to the Site; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 The extent of flooding due to overflow of Brahmani River along its left bank has never exceeded beyond SH 9A. The SH 9A is located ~ 1.3, ~2 km and ~2.5 km south of the unit-1, unit-2 and unit-3; During September 2019, Brahmani River was overflowing due to backflow associated with high water levels in Chambal River. Therefore, the seasonal streams draining the Site area were not able to quickly discharge into Brahmani River. Minor effects of backflow were observed in the Site area and ponds. Per community consultation, no history of widespread flooding/ inundation due to overflow from Brahmani River, nallas and/or embankment ponds was reported on-Site. However localized inundation in low-lying areas within Site was reportedPer community consultation, it was found that Brahmani River breached its banks in the years of 2019, 2016, 2010 and 1994 due to excessive rains causing widespread inundation in settlements along the river and SH 9A which is the primary access to the Site; The extent of flooding due to overflow of Brahmani River along its left bank has never exceeded beyond SH 9A (~ 1 km south of the Site); During September 2019, Brahmani River was overflowing due to backflow associated with high water levels in Chambal River. Therefore, the seasonal streams draining the Site area were not able to quickly discharge into Brahmani River. Minor effects of backflow were observed in the Site area and ponds. Per community consultation, no history of widespread flooding/ inundation due to overflow from Brahmani River, nallas and/or embankment ponds was reported on-Site. However localized inundation in low-lying areas within Site was reported. Per the District Disaster Management Plan Neemuch District, the district is prone to floods. It was found the Site is not prone to flooding due to overflow from Gandhisagar Dam (40 km south-east of the Site, along Chambal River). Per the global estimated risk index for flood hazard map developed by UNEP/GRID-Europe, the Site is not prone to flooding; Per the global flood hazard map developed by FM Global, the Site is not prone to high or medium flood risk; ding hazard zone; Based on global flood hazard frequency and distribution map developed by Data Basin, the Site and its surroundings is not prone to flooding. As per the 1-D mapping where maximum water levels at Brahmani River Bridge corresponding to Aug-Sep 2019 flooding event were mapped over the DEM, it was found that the Site is not prone to flooding from Brahmani River. Considering the above mentioned attributes, the Site is moderately susceptible to flooding. Recommendations Based on the broad level assessment, following measures are recommended to protect the assets at Undertake a flood risk assessment to estimate the High Flood Level (HFL) at the Site. This will help the Client in estimation of the risks of flooding and inundation to the Site. Installation of solar panels and other critical infrastructure above the HFL will greatly reduce disruptions and lossed to the Plant; Enhance structural stability of banks of all seasonal streams such as S1, S2, S3 and S4 which are in close vicinity of the Site units and provide robust erosion protection to withstand flood water; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Storm water drains must be designed in line with the natural topography and eventually drain into the natural seasonal streams in the Site area; the natural seasonal streams; Provide sluice/ flap gates at the SWD outfall to prevent backflow during a backflow event; Make provisions for pumping infrastructure within the Site to ensure rapid evacuation of water in case of high flow/backflow associated with ponds and seasonal streams ; Implement an effective flood monitoring and disaster management system in place for effective mitigation of floods at a Site level; Coordinate with the district and local disaster management cells to update on flood early warning notifications www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 APPENDIX F ESMP- MANAGEMENT PLANS 4. Waste Management Plan 5. Water Management Plan 6. Occupational health and Safety Plan 7. Disaster Management and Emergency Response Plan 8. Construction and Labour Management Plan 9. Gender Action Plan 10. Stakeholder Engagement Plan www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 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 for the proposed Project has been developed. This has to be updated by the Solar Project Developer (SPD)/EPC contractor before start of activity. Objectives The construction and operation 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: Inventorisation 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; Suggestion of options for waste handling and disposal during construction and operation phase of the project Establish compliance to various national waste management related regulations Establish an appropriate training programme for contractors, workers and other stakeholders Define the roles and responsibilities for implementing the measures Scope This plan shall be applicable to the Solar Project Developers or EPC contractors engaged by RUMSL for the construction and operation and maintenance phase of the proposed project. The elements of the plan will be directly implemented by the Developers and contractors hired by the Developers while overall management and responsibility will lie with RUMSL. The Plan also identifies the individuals currently assigned to the various roles designated in this Plan. Type of Waste and Source The table below provides the list of type of waste likely to generate at site during construction and O&M phases. Table E1 Details of Type of Waste S. Waste Type Source No Construction Phase Non Hazardous Waste 1. Domestic solid waste Temporary site office, storage area, labour activities 2. Construction debris Construction activities within Solar Park including construction of access road, substation, storage yard etc. 3. Packaging waste containing wood, Packaging material from solar panels, cables and cardboard and other recyclables. accessories 4. Sludge from Septic Tank Site Office and labour camp 5. All non-recyclables waste Construction activities 6. Plastic waste Packaging material 7. Biomedical waste First aid kits kept at construction site and site office www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 S. Waste Type Source No 8. Broken solar panels and other Solar Park, PSS and Site Office electronics waste (E waste) 9. Batteries Solar Park, PSS and Site Office Hazardous Waste 1. Used oil/waste oil, lubricants and oil DG set, construction machinery contaminated rags 2. Bio medical waste First aid centre Operation Phase Non Hazardous Waste 1. Domestic solid waste and office waste Site Office 2. Metal Scrap Site Office and PSS 3. Damaged PPEs Site Office and PSS Hazardous Waste 1. Used oil/waste oil, lubricants and oil Maintenance activities at site contaminated rags 2. Broken solar panels, batteries (dry type Site office and PSS or wet type), electronics Regulatory Context The regulatory context for waste management in India has been provided in Table F2. Table F2 National Regulations for Waste management Waste Stream Regulation Requirements for the waste generator(s)- (SPD/EPC Contractor) Construction Construction and Waste generator shall be responsible for collection, segregation of and Demolition Demolition Waste concrete, soil and others and storage of construction and demolition Waste Rules, 2016 waste generated, as directed or notified by the concerned local authority in consonance with these rules; Waste generator shall ensure that other waste (such as solid waste) does not get mixed with this waste and is stored and disposed separately; Waste generator shall keep the construction and demolition waste within the premise or get the waste deposited at collection centre so made by the local body or handover it to the authorised processing facilities of construction and demolition waste; Waste generator shall ensure that there is no littering or deposition of construction and demolition waste so as to prevent obstruction to the traffic or the public or drains; In case, quantum of C&D waste generating at site is estimated 20 tons or more in one day or 300 tons per project in a month, the Waste Generator shall segregate the waste into four streams such as concrete, soil, steel, wood and plastics, bricks and mortar and shall submit waste management plan and get appropriate approvals from the local authority before starting activities. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Waste Stream Regulation Requirements for the waste generator(s)- (SPD/EPC Contractor) Solid Municipal Solid Waste Waste generated at the site should be segregated into biodegradable Waste Management and non-biodegradable wastes; Rules, 2016, as amended Horticulture and garden waste generated within site should be stored separately and disposed as per the directions of the local body; and Waste should not be thrown, burned or buried on streets, open spaces, outside the site premises or in drains/water bodies. Hazardous Hazardous and Waste generator should be responsible for safe and environmentally Waste Other Wastes sound management of hazardous waste; (Management and Hazardous and other wastes should be sold to an authorised actual Transboundary user or disposed authorized disposal facility; Movement) Waste generator should take steps while managing hazardous and Rules, 2016, as other wastes to contain contaminants, prevent accidents and limit amended consequences to human beings and the environment; Waste generator should provide persons working in the site with appropriate training, equipment and information necessary to ensure their safety; Waste generator should make an application to the State Pollution Control Board to obtain an authorization for managing hazardous and other wastes; Waste generator should maintain a record of hazardous and other wastes managed by him/her in Form 3 of the HW Rules; An annual return containing the details of the waste generated should be submitted through Form 4 of the HW Rules on or before the 30th day of June following the financial year to which the return related; Waste generator may store the waste for a period not exceeding ninety days; During transportation of hazardous waste, the waste generator should provide the relevant information as shown in Form 9 of the HW rules; If waste has to be transported across state borders for disposal then an NoC is required from both State Pollution Control Boards; The waste generator should prepare copies of the manifest of hazardous and other wastes before transportation and as given in Form 10 and provide a copy to the transporter, State Pollution Control Board and retain a copy; and When an accident occurs at a facility handling hazardous waste, the operator should intimate the State Pollution Control Board through telephone or email about the accident and subsequently send a report. Electronic E-waste Bulk consumers of electrical equipment should be channelized Waste (Management) through collection centers or dealers of authorized producer or Rules, 2016, as dismantler or recycler or through a designated take back service amended provider; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Waste Stream Regulation Requirements for the waste generator(s)- (SPD/EPC Contractor) Bulk consumers should maintain records of e-waste generated and make these records available to the State Pollution Control Board; E-waste containing radioactive material should not be mixed; and Bulk consumers should provide annual returns to the State Pollution Control Board before the 30 th day of June following the financial year to which the return relates. Plastic Waste Plastic Waste Waste generator should take steps to minimize generation of plastic Management waste and if generated, then segregate plastic waste from municipal Rules, 2016, as solid waste; and amended Plastic waste should not be littered and handed over to urban local body or gram panchayat or approved agencies, registered recyclers or waste collection agencies. Battery Waste Batteries Batteries should not be disposed in any manner other than (Management depositing with dealer, manufacturer, importer, assembler, registered and Handling) recycler, reconditioner or at designated collection centres; and Rules, 2001, as amended Bulk consumers should file half-year return to the State Pollution Control Board. Bio-medical Bio-Medical The bio-medical waste shall be segregated into containers or bags at waste Waste the point of generation in accordance with Schedule I prior to its Management storage, transportation, treatment and disposal. Rules, 2016 Obtain (one time) authorisation from the prescribed authority under BMWM Rules, 2016 Maintain record pertains to quantum of category wise bio-medical waste generated and treated Waste Handling, Management & Disposal Construction Phase All wastes produced from the Project activities on site will be temporarily stored in designated waste storage areas. All wastes that cannot be reused or recycled will be collected by approved waste contractors and transferred to an appropriately licensed waste management facility for treatment and disposal. Following steps will be taken to manage the waste generation during construction phase: Fuel will be stored on site in temporary aboveground storage tanks and will be stored in a locked container within a fenced and secure temporary staging area; Trucks and construction vehicles will be serviced off site; All concrete mixing be undertaken on impermeable plastic lining to prevent contamination of the soils and surrounding areas; Food waste and other refuse are to be adequately deposited in sealable containers and removed from the kitchen frequently to avoid accumulation; The use, storage, transport and disposal of hazardous materials used for the project will be carried out in accordance with all applicable regulations; All hazardous waste to be disposed off to MPPCB approved vendors; Material Safety Data Sheets (MSDS) for all applicable materials present on site will be readily available to on-site personnel; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 The construction debris will be placed in appropriate on-site storage containers and periodically disposed of by a licensed waste contractor; The construction contractor will remove refuse collected from the designated waste storage areas at the site at least once a week; and Empty fuel containers will also be stored at a secured area designated for scrap and sold to authorized vendors. All packaging material will also be collected at the storage area and sold to scrap dealers. Operation Phase Damaged cells would need to be characterized and managed as hazardous waste. Following measures to be taken for management of waste: Developers need to have buy back agreements for defunct solar panels; A designated area needs to be demarcated within the premises for storage of defunct and broken solar panels with restricted access and on impervious surface; MNRE had prepared a concept note for storage and disposal of used solar panels. The recommendations such as recycling of glass, storage of discarded panels in cover shed etc. shall be adopted in the Project; (1); All fuel storage should be equipped with secondary containment and spillage trays; All used oil is required to send off to MPPCB approved vendors and recyclers; and Transportation of defunct solar panels is required to be undertaken as per the procedures specified by the Manufacture of Solar Panels. Handling of Broken Solar Modules generated due to cleaning and other maintenance activities Impact Mitigation Measure Land Contamination (Soil Broken or damaged solar panels are required to be shifted to a designated Quality) area in scrap yard to avoid any type of land contamination. The designated area should be isolated and to be established on an impervious surface. A photograph is to be taken of the broken panel at the site to cater to Insurance settlement claims Proper PPE are provided to the workers handling the broken solar panels. Risk on Health of Workers The workers at site are also on regular basis apprised about the potential health risks associated with handling of solar panels. Roles and Responsibilities Site Supervisor (SPD/ EPC Contractor) Site Supervisor will be responsible for the following activities Management of onsite waste generation associated with construction works to help avoid excessive generation where practicable; Maintaining all records of waste type which are construction waste and debris, hazardous waste; Liaising with Madhya Pradesh Pollution Control Board (MPPCB) approved vendors for disposal of hazardous waste generated; Renewal and Management of Buy Back Agreements for defunct solar panels with the Manufacturers; EHS Manager (SPD/ EPC Contractor) (1) http://164.100.94.214/sites/default/files/webform/notices/DraftBluePrintAntimony.pdf www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 The following responsibilities are entrusted to the EHS Manager: Demarcation of area within the module area for keeping of segregated wastes; Labelling of the drums containing hazardous wastes like used oil; Maintaining of receipts for hazardous waste management records; Notifying the Site Supervisor of any activity that may generate a large amount of waste to allow appropriate controls to be put in place to manage waste generated; and Ensure safe transportation of defunct solar panels as per specified procedures. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 WATER MANGEMENT PLAN The construction and operation & maintenance activities will require water. A Water Management Plan has been prepared for the Project to support the ESIA process. The Plan was developed to meet the objectives of water management during the construction and operation of the Solar Park. Plan is based on the assessment of impacts on water resources, quality, which would occur during the site preparation and operation phase of the Project. Objectives The Water Management Plan aims to ensure that water consumption during the project life cycle do not result in unacceptable impacts on the water resources and surrounding community. It focuses on the strategies to be used to monitor the water quantity, conservation measures, and recycling of water within the Project. The objective of this Water Management Plan (WMP) is Monitoring water consumption in the Project during construction and O&M activities; Delineate mitigation/management measures to be implemented during construction and O&M phases; Establish compliance of National Standard for Discharges Establish an appropriate training programme for contractors, workers and other stakeholders Define the roles and responsibilities for implementing the measures Scope This plan shall be applicable to the Solar Project Developers or EPC contractors engaged by RUMSL for the construction and operation and maintenance phase of the proposed project. The elements of the plan will be directly implemented by the Developers and contractors hired by the Developers while overall management and responsibility will lie with RUMSL. The Plan also identifies the individuals currently assigned to the various roles designated in this Plan. Water Resources Surface Water The study area is drained by Brahmini River and its tributaries. The Project site is devoid of any surface water body such as lake, dam, pond or river. Brahmini River flows about at distances of ~1.6 km, ~3.1 km and ~3.3 km to the South of the Unit 1, Unit 2 and Unit 3 respectively. A water body is located adjacent to Unit 3 in SE direction. Ground Water The principal source of water in the study area is groundwater. During community consultations in Project villages, a total of 200- 250 dugwells and 300-400 tubewells were reported in Badi, Kawai and Bardawada villages. General depth of the dugwells was reported in the range of 80-100 feet (24- 31 m). General depth of tubewells was reported in the range of 450-800 feet (137- 245 m). Approximately 90 % of the dugwells and tubewells were reported with only seasonal water availability influenced by the rainfall. Only the tubewells located in the proximity of surface water bodies were reported to provide water to the community throughout the year. Water Requirement The tables below provides details with respect to water requirement at site during construction and O&M phases. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Table F3 Details of Water Requirement for the Project S. Particulars Water Requirement No Construction Phase 1. Domestic Purposes 80-100 KLD 2. Construction Activities 250-300 KLD Operation Phase 1. Cleaning of Solar Panels 308 KLD 2. Domestic Purposes 10 KLD 3. Landscaping 7 KLD 4. Firefighting and Miscellaneous 32 KL The water requirement for the Project will be met through tanker water supply during construction phase. Whereas, during O&M phase, ground water will be used for domestic purposes and solar panel cleaning activities. Waste water Generation Wastewater will be generated from the following sources: Construction Phase - Sewage: site office, labour camp. - Surface runoff from site Operation Phase - Sewage: site office - Wastewater from solar panel cleaning activities The domestic wastewater generated from the site will be collected through septic tank and followed by soak pit. Regulatory Context The regulatory context for water management in India has been provided in Table below. Table F4 National Regulations for Water management Regulation Requirements The Water (Prevention and Control This Act provides for the prevention and control of water pollution of Pollution) Act, 1974 and its and maintaining or restoring good water quality for any amendment, 1988 establishment. Any waste water discharge shall be within the discharges limits prescribed by CPCB. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Regulation Requirements Guidelines/Criteria for evaluation of Permission from CWGB shall be taken prior to any ground water proposals/ requests for ground abstraction for construction and O&M activities. water abstraction by CGWB The Project site falls under Jawad Block which is categorized as Critical by CGWB. As per guidelines, groundwater withdrawal may be permitted subject to Undertaking of ground water recharge measures. The withdrawal should not exceed 100% of the recharged quantity. The recharge should be implemented within the premises and/or same water shed/assessment unit. Detail project proposal shall be included along with the application for NOC. Impact Avoidance and Impact Mitigation Conserving Water Resources Construction Phase - Optimum use of water during sprinkling on roads for dust settlement, washing of vehicles, concrete mixing for foundation etc.; - Regular inspection for identification of water leakages and preventing wastage of water from water supply tankers, camp area. - Construction labour deputed onsite to be sensitized about water conservation and encouraged for optimal use of water; - Operation Phase - Feasibility of dry cleaning of solar panels shall be examined; - Use of water-efficient technologies for cleaning the solar panels and domestic consumption nodes; - The surface runoff from during solar panel cleaning shall be diverted to a settlement tank for settlement of suspended solids. The overflow shall be treated in water treatment unit and recycled in the Project. - Optimising water usage in the SCADA building by application of water conservation measures such as sensor based taps, low flush urinals etc.; - Maintain logbook for water consumption; - Use of water from multiple sources to avoid dependency on one particular source (groundwater or surface water). This also includes tapping of rainwater received during the monsoons for the long-term and uninterrupted operations. The Project should implement principles of water stewardship to ensure water security not just for the site, but also for other stakeholders within the watershed. Some of the water stewardship frameworks/ standards that can be adopted are UN Global Compact's CEO Water Mandate or AWS Standards. Identify stakeholders directly impacted by the groundwater use at the Project site and develop long- term stakeholder engagement plan particularly focused on stakeholders near site to develop positive perception towards Project and its operations. Rain Water Harvesting The ground water status in Jawad block has been declared as critical area. In order to comply with CGWB guidelines for ground water abstraction, ground water recharge is mandatory in the Project. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 RUMSL shall plan to provide rainwater harvesting provision at site. For this purpose, rainwater harvesting pond shall be provided at site. In addition, groundwater recharge shall be undertaken within the Site to replenish the shallow aquifer zones. Piezometers to be installed to monitor the groundwater level changes in the aquifer trapped by the abstraction wells at Project site. Water Quality Ensure proper cover and stacking of loose construction material at site to prevent surface runoff and contamination of receiving water body; Open defecation and random disposal of sewage will be strictly restricted; Planning of toilets, soak pits and septic tanks, waste collection areas away from natural drainage channels; Provision of number of toilets across with easily accessible location as the project site is spread across large area of 3 units; Use of licensed contractors for management and disposal of waste and sludge; Labourers will be given training towards proactive use of designated areas/bins for waste disposal and encouraged for use of toilets; Provision for impervious storage area, especially for fuel & lubricant, hazardous waste, etc. will be made onsite; and Spill/ leakage clearance plan to be adopted for immediate cleaning of spills and leakages. Other Management Aspects Inventory of Water Consumption and Pollution Sources Preparing an inventory of water consumption during construction and O&M activities and all pollution sources from the Project activities is essentially the first step towards managing the impacts. The Management Plan will involve preparation of an up to date inventory of all areas of water consumption and wastewater discharge sources based on the latest Project activity related information. This inventory will helps in formulating the following management approaches: Source reduction Resource recovery options Recycle options Optimal treatment strategies and technologies Post-treatment, resource recovery and recycle options Ultimate disposal considering the local environmental sensitivities The inventory database of discharge sources shall be kept as a living document and updated as and when any new sources are cited at any point in time of the Project period. Any intermittent water requirement and discharge sources shall also be identified and included in the inventory. Responsibilities and Accountabilities EHS Manager The EHS Manager of SPD/EPC contractor will be responsible for: Implementing the mitigation measures mentioned in this management plan; Maintain a database which will record the water consumption quantities and waste water generation at different locations; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Monthly review of water consumption and waste water generation in the project; Conducting regular audits around the Project site to inspect water management practices; Conducting regular audits for rainwater harvesting; Review conditions of storage location and records related to hazardous wastes as per the conditions of authorization All employees and sub-contractors will be provided with environmental awareness training through a site induction process. All employees and contractors will have a responsibility to manage operations in an environmentally responsible manner and report any visible emission/ discharge/ accidental spillage. All pollution related environmental incidents will be reported to the EHS manager. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 OCCUPATIONAL HEALTH AND SAFETY PLAN The section below presents an overview of the potential occupational health and safety risks on the proposed project. It defines the various risks involved during the construction and operation phase of the project. The occupational health and safety plan (OHSP) will address the following: Evaluation and Identification of hazards; Elimination and removal of hazards; Control of Hazards which cannot be eliminated; and Recovery from accidents. Purpose and Scope This plan provides guidance with respect to occupational risks (for both construction and operation stage) and aims to achieve the following: Identification of hazards, associated risks and control measures for each activity; Defining responsibilities to ensure effective implementation of health and safety (H&S) risk control measures; Avoid and/or minimise the impacts on worke project activities; Provide and maintain safe working procedures and operations for workers; and Reduce human injury and damage to property and environment in case of an emergency. Definitions Competent Person: any person having the knowledge, training and experience specific to the work or task being performed. Confined Space which by its small size and confined nature can readily create or aggravate a hazardous exposure. Emergency: An unforeseen occurrence, a sudden and urgent occasion for action First aider: A person who has received training and who holds a current first aid certificate from an organization or employer whose training and qualification for first aiders are approved by authority. Hazard: A source, situation or act with a potential for harm in terms of: ill Health damage to property, plant, ships etc. production losses or increased liabilities Hazardous Substance of being explosive, flammable, poisonous, corrosive, oxidizing, irritant, or otherwise harmful is likely to cause injury. Health and Safety Plan: A documented plan which addresses hazards identified and includes safe work procedures to mitigate, reduce or control the hazards identified. Hot Work operations. Incident: An event or occurrence occurring at work or arising out of or in connection with the activities of persons at work, or in connection with the use of plant or machinery. Risk: the probability that injury or damage will occur Safe: free from any hazard www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Roles and Responsibilities Site Supervisor (SPD/EPC Contractor) Following tasks will fall within his/her responsibilities: Monitor site activities on weekly basis for compliance; Supervise the performance of the work being carried out within the project boundary; Conduct internal audits of the construction site against the ESMP; Confine the construction site to the demarcated area; and Keeping a check on operation and maintenance services of solar project components required during operation phase. EHS Manager (SPD/EPC Contractor) Responsibilities of an EHS Manager shall include the following: Ensure that the operations are in compliance with EHS requirements at all times; Conducting HS&E Audits on regular basis & advice management for necessary action; Maintaining first aid facilities and personal protective equipment as demanded by the nature of the work/Material Safety Data Sheets; Review of investigation of all type of accidents & reporting to Site Supervisor; Training of workers and ensuring that they are issued with adequate instructions and creating awareness of safe work practice among them; suitable solutions; and Participate in the preparation of, all Safety instructions, procedures and activities. Safety Officer(s) The developer shall ensure appointment of safety officer(s) for employees and workers working at site, to: Review the effectiveness of health and safety measures; Identify potential hazards and potential major incidents; Examine the causes of incidents in collaboration with his employer,; Investigate complaints by any employee /workers relating to that their health or safety on the site; Inspect the site with a view to, the health and safety of employees, at regular intervals; Participate in any internal health or safety audit. First Aider Initial emergency response resuscitation and stabilization of critically ill or injured personnel; First Aid of non-emergency medical conditions; Implementation of site health plans and preventive medicine activities including first aid training of employees and workers; and Undertake regular health and hygiene inspections. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Workers Use the correct tools and equipment for the job; Use Safety equipment and protective equipment/clothing supplied, e.g. Safety helmets, shoes, harness, goggles, etc.; and Report all defects in plant or equipment to health and safety representatives. Risk Assessment Contractor shall before the commencement of any work on site and during construction work, ensure to undertake risk assessment by a competent person. Such an assessment shall as a minimum : Identify the risks and hazards to which persons may be exposed to; Analyse and evaluate the identified risks and hazards; Document a plan of safe work procedures, including the use of any personal protective 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 is an important step in protecting workers. It helps to focus on the potential risks in a particular workplace. Workers and others have a right to be protected from harm caused by a failure to take reasonable control measures. Training Site Supervisor shall 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. Procedures to identify training needs to be established and adequate safety training to be provided to all the employees/ workers on site. 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. HSE trainings proposed for the project to include: Induction training on HSE Tool Box Training or pre-task briefings, highlighting hazards and the method of dealing with them Special Job Hazard Training including entry into confined space and other hazardous environment Hot work; Working at height; Electrical safety; Fire Safety First Aid Emergency Response Use of PPEs www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Documentation and Record Keeping Site Supervisor 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: Hazard Identification Record; Risk Register; Legal Register; Licenses, Certificates, Permits; Control Methods including process control and machine design, safe work procedures, in-house work rules; Work Permit System; Training Reports; Drill Reports; MoM of HSE meetings; Inspection and Audit Records; and Medical and Health Surveillance Records Communication and Information Dissemination Supervisor(s) should communicate and inform any persons affected by the risks about: The nature of the risks involved; and The control measures or safe work procedures to be taken to address the risks involved. Safe Work Practices Construction and operation of the Solar Park involves many on job hazards which needs to be identified and eliminated or minimised to an expectable level in order to achieve a safe and healthy work environment. Following safe working practices should be established for site works (not limited to): Lockout/Tagout (LOTO) Crane and Hoist Safety Electrical Heat Stress Personal Protective Equipment Lockout/Tagout (LOTO) LOTO refers to specific practices and procedures to safeguard employees from start-up of machinery and equipment, or the release of hazardous energy during service or maintenance activities. Many workers face the greatest risk of injury if lockout/tagout is not properly implemented. Solar energy equipment can generate electrical energy and may be connected to electrical circuits. Workers may be exposed to electrical hazards from solar panels, PSS/ SCADA inverter room activities and from electrical circuits. LOTO is required to be implemented while working in PSS, SCADA and inverter room. While installing or servicing solar panels, employers should assure that workers cover the solar panels, in addition to protecting workers from electrical circuits. Workers performing servicing or maintenance of solar panels may be exposed to injuries from the unexpected energization or release of stored energy in the equipment. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 The following are some of the significant requirements of a Lockout/Tagout procedure required under a Lockout/Tagout program. Only authorized employees may lockout or tagout machines or equipment in order to perform servicing or maintenance; Lockout devices (locks) and tagout devices (tags) shall not be used for any other purposes and must be used only for controlling energy; Lockout and Tagout devices (locks and tags) must identify the name of the worker applying the device; All energy sources to equipment must be identified and isolated; After the energy is isolated from the machine or equipment, the isolating device(s) must be locked out or tagged out in safe or off position only by the authorized employees; Following the application of the lockout or tagout devices to the energy isolating devices, the stored or residual energy must be safely discharged or relieved; Prior to starting work on the equipment, the authorized employee shall verify that the equipment is isolated from the energy source, for example, by operating the on/off switch on the machine or equipment; Lock and tag should not be removed from the machine until the work is completed; and Only the authorized employee who placed the lock and tag must remove his/her lock or tag. Electrical Solar energy workers while working in PSS, SCADA and inverter room are exposed to potential electrical hazards present in their work environment, which makes them more vulnerable to the danger of electrocution and arc flash hazards. Workers may be exposed to electric shocks and burns when hooking up the solar panels to an electric circuit. Workers must pay attention to overhead power lines and stay at least 10 feet away because they carry extremely high voltage. Fatal electrocution is the main hazard, but burns and falls from elevations can occur while installing solar panels. Another hazard is from using tools and equipment that can contact power lines. Heat Stress Solar energy workers often work in very hot weather where hazards include dehydration, heat exhaustion, heat stroke, and death. Employers should monitor employees and workers should be trained to identify and report early symptoms of any heat-related illness. Heat Stroke occurs when the body's system of temperature regulation fails and body temperature becomes abnormally high. If a worker shows signs of possible heat stroke, medical treatment should be obtained immediately. Workers suffering from heat exhaustion should be removed from the hot environment and given fluid replacement. They should also be encouraged to get adequate rest. Personal Protective Equipment (PPE) Using personal protective equipment is often essential, but it is generally the last line of defence after engineering controls, work practices, and administrative controls. Solar energy employers must assess their workplace to determine if hazards are present that require the use of protective equipment. Solar energy workers can be exposed to many hazards that may require the use of safety glasses, hard hats, gloves, respirators, or other personal protective equipment used to protect against injuries and illnesses. Workers exposed to potential electrical hazards must be provided with appropriate electrical protective equipment, and workers must use them. Electrical protective equipment must be maintained in a safe and reliable condition. They must be periodically inspected or tested for their workability. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 General Working Conditions Housekeeping Work areas should be maintained in a neat and orderly condition; Scrap material, such as rags, bolts and wedges should not be allowed to accumulate in the site area; Spills of oil, grease, paint and other slippery substances should be cleaned up immediately; Walkways should be kept clear of tripping hazards at all times; All personal protective equipment required for a procedure must be worn; Maintain a free access to all safety equipment including firefighting equipment, electrical panels and boxes, etc.; Proper barricades, safety rings and safety wires should be used. Barricades must be properly lighted for visibility; Operating equipment, tools or machinery without proper guards and/or signalling devices is prohibited; Observe all warning signs in the yard; and Before leaving the job, always check the area for any sparks or smouldering materials. First Aid All work areas must be provided with adequate first aid facilities with a trained first aider during working hours; and Developer(s) must provide or ensure that there is provision of adequate and appropriate facilities for enabling first aid to be rendered to their employees if they are injured or become ill at work. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 EMERGENCY RESPONSE AND DISASTER MANAGEMENT PLAN The primary objective of formulating Emergency Response and Disaster Management Plan (ERDMP) is to undertake immediate rescue and relief operations and stabilize the mitigation process as quickly as possible. A site specific ERDMP shall be prepared by SPD/EPC Controller for the site. The basic concept of the plan is to allow for smooth coordination of activities during an emergency. All employees and contractors shall be familiar with the plan. This plan shall be reviewed and amended when needed to ensure that all parties concerned are furnished with up-to-date information. The site supervisor with support of EHS team shall carry out exercises of part of the emergency plan at a regular interval as deemed necessary. The lesson learnt from these exercises shall be documented and used during the updating of this emergency response plan. Objectives The key objectives of the Plan are to: To localize the emergency and if possible eliminate it; To avoid confusion, panic and to handle the emergency with clearly defined actions; To reduce the incidence and severity of injury during mining operations; Identify the designated personnel and responsibilities for dealing with emergencies on and off- site; To take remedial measures in a quickest possible time to contain the incident and control it with minimum damage; and To mobilize the internal resources and utilize them in the most effective way. Identification of Hazards and Emergency Categorization Identification of all the hazards and risks associated with each activity which may lead to an emergency and anticipate the actions to be taken before or after the emergency arises. This section identifies the hazardous areas and activities in both construction and 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 have been identified at the construction site: Fuel storage areas Kitchen arrangement in labour camps Electrical installations improper laying of cables Scaffolds Emergency Situations The possible emergency situations identified for the construction and operation phases of the Project are as listed below: Fire and Explosion Leakage of fuel from storage areas; and Short-circuit at campsite/Project site. Mechanical and Electrical Hazards Structural Collapse; Accidentally dropped object; Loss of stability; and www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Electrocution. Occupational Hazards Outbreak of Disease / Illness/injury; Handling of chemicals; Accidents due to vehicle movement/ vehicle collision; and Vandalism. Other emergencies Flooding; Earthquake; Cultural Conflict; Terrorism; Bomb Threat. Categorization of Emergencies Level 1 (Minor Emergencies) 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, EHS Manager of RUMSL will be notified. Some typical incidents are: Vehicle collision (involving no loss of life); Medical Evacuation (not very serious cases); Minor localized fires. Level 2 (Serious Emergencies) 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 construction activity/ project operations or have cascading effect. For such type of incidents Site Supervisor 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; Terrorism; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Bomb Threat 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. Codification of Sirens Following codes of siren are proposed during emergencies: ON SITE EMERGENCY (ALERT) for evacuation - 120 seconds Continuous Whelming Sound EMERGENCY CONTROLLED - 30 + 30 + 30 seconds sound with an interval of 5 seconds each Emergency Facilities Emergency Control Centre (ECC) For the purpose of handling emergency, separate emergency control centre should be established. All communications to and from should originate from this control centre. The site office has been identified for establishment of ECC. All the key personnel such as Site Controller/ Incident Controller Officers, Senior Personnel would be located here or have access to the ECC. The ECC will also coordinate with offsite District Emergency Operation Centre (DEOC). Infrastructure at Emergency Control Centre Emergency control centre should therefore contain the following: A copy of on-site emergency plan; A copy of evacuation plan; An adequate number of internal and external telephones lines; Layout of fire-fighting system including locations of fire extinguishers with their type, Location of assembly points; Information on additional sources of water; List of important telephone numbers such as Police, Fire Brigade, Hospitals, and other outside Emergency Services, etc.; List of key Personnel with addresses and telephone numbers; List of Personal Protective Equipment; First Aid box; Alarm Control system. Assembly Areas and Evacuation Routes Safe assembly areas shall be identified and marked and employees to be instructed to gather at the assembly area during emergencies. The evacuation routes/plans shall be displayed at all strategic locations across the site. Emergency Equipment The following 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; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Inventory and locations of respective emergency equipment shall be displayed at project office building, construction areas 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 Project 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 Skin creams for treating burns Anti-histamine cream for insect bites and stings Fire Fighting Equipment The fire extinguishers and sand buckets will be provided at critical areas such as fuel storage area, waste storage area, labour camps, kitchens, 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 site 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. Stretchers, and general first aid materials for dealing with burns, burns, fractures etc. would be maintained in the Medical Centre as well as in the ECC. A range of medicines should be maintained in the ECC/ Medical Centre. Other emergency medical equipment as suggested by local administration for COVID pandemic should be provided and maintained. Apart from first aid facilities, external facilities would be augmented. Checklist of name of medical personnel, medical facilities available in the surrounding area to be prepared and updated. Incident Management System Emergency Response Team The Emergency Response Team (ERT) shall be set up for construction phase and shall be revised for commencement of plant operations. Each personnel identified as part of the ERT shall be designated specific roles and responsibilities for handling emergency situations. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 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 co-ordinating additional equipment, personnel, and other external resources for the direct response effort. Following Emergency Response Team (ERT) is proposed: Site Controller: The site supervisor would be designated as site controller during emergency. Incident Controllers/Disaster response coordinator: Health and safety team responsible for different activities would be designated as incident controller/disaster response coordinator. All incident controllers shall report to site controller. Emergency Coordinators: Emergency coordinators would be appointed who would undertake the responsibilities like fire fighting, rescue, rehabilitation, transport and support services. For this purposes, security in-charge, personal department, essential services personnel would be engaged. Site Supervisor The Site Supervisor or personnel nominated by him shall be the Site Controller and responsible for overall management. The following tasks will fall within his/her responsibilities: Assess the magnitude of the situation Maintain a continuous review of possible development and assess in consultation with Incident Controller and other Key personnel Review monthly and annual incident reporting Review disaster response drill outcomes and work with EHS Manager and safety officers to identify necessary improvements Appoint a Disaster Response Coordinator tasked with responding to emergencies Overall coordination during emergency Communication with the District Disaster Management Authority and other external agencies Issue authorised statements to news media, and ensure that evidence is preserved for inquiries to be conducted by statutory authorities EHS Manager EHS Manager will be part of Incident Controller team. The duties of an EHS Manager shall include the following: Direct all operations within the affected areas with the priorities for safety of personnel, minimise damage to the property and loss of materials Pending arrival of Site Controller, assume the duties of his post and, in particular Direct the shutting down and evacuation of areas likely to be adversely affected by the emergency Provide advice and information to the Fire squad & Security Officer and the local fire service as and when they arrive Ensure that all non-essential workers/staff of the areas affected are evacuated to the appropriate assembly points, and the areas are searched for casualties To set up communication point and establish contact with Emergency Control Centre www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Distribution of the DMP to all parties with responsibilities in implementing the plan (including contractors); Review monthly and quarterly reports of accidents/incidents and reviews of contractor practices; Training and Planning mock drills; Receive all notifications of incidents/accidents and ensure proper response is being followed including reporting and review. Safety Officer Safety officer will be part of Incident Controller team. Responsibility of Safety Officer includes: Support the EHS Manager as required in disaster response planning and in development of training and management plans to ensure environmental concerns are addressed; Provide regular incident reporting; Schedule monthly inspections and audits and resolve issues identified; Schedule emergency response training sessions for relevant staff; Prepare monthly incident reports. Emergency Coordinators Ensure they are easily recognizable to their colleagues/visitors and the emergency services during any evacuation; re-enter the site; Keep an updated list of employees and visitors on site and carry the name list with them during evacuation; Ensure all occupants have evacuated the area where the incident has taken place (including people in rest rooms, site office rooms etc.); To be fully trained in the provision of first aid. Employees/Workers All persons employed or under service contract (e.g. contractor, transporter etc.), who witnesses or cause an incident are responsible for immediate reporting of the incident to his/her supervisor. Emergency Response Procedure Effective command and control starts 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. Emergency procedure to be followed in the event of any emergency are provided below: www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Emergency Procedure If a person finds someone injured, he shall immediately tell his shift Incharge about Medical the accident; Emergencies The shift Incharge shall inform the ECC and First Aid Team about the injury and location of accident. On receiving the information, First Aid Team should go to the accident site immediately; First Aid team shall provide the first aid to the injured person and make necessary arrangements for taking him to the hospital, if required; After this, First Aid Team shall report the ECC and make entries in the register Medical emergencies can be classified as life threatening or non-life threatening. If there is any doubt, assume that the emergency is life threatening. The Incident controller must be notified; Fire Personnel in the immediate vicinity of the fire, including the designated Evacuation personnel must be immediately notified; All persons located in the area in which the fire is located must be evacuated. Evacuation must be carried out as per the Evacuation Procedure; The fire must be contained with the correct extinguisher only by those trained to do so; Those requiring assistance must be assisted and first aid must be rendered only by those trained to do so; Those confined to an area where there is smoke, must move under the level of the smoke and cover their nose/mouth. The Incident Controller must be notified; Building Collapse Personnel in the immediate vicinity of the collapsed building move away from the building to a safe location - there could be a secondary collapse; Enter and rescue others only by those trained to do so; If you know the identity or location of someone who is trapped, notify emergency personnel; All persons located in the area must be evacuated. Evacuation must be carried out as per the Evacuation Procedure. Actions during earthquake Earthquake Keep self and other calm; Do not rush to doors or exit; Keep away from loose articles/ furniture; and Protect yourself by staying under the rental of an inner door, in the corner of a room, under a table. Action after an earthquake Keep calm; Expect aftershocks; If there is a fire, try to put it out. If required call the fire brigade; If people are seriously injured, do not move them unless they are in danger; Do not enter badly damaged buildings; and Do not go near damaged structures. Further Action All person to assemble at assembly area; Attendance of everyone present including direct and non-direct staff and visitors; Rescue management to be initiated, if required additional help to be sought from authorities; and RUMSL management to be briefed about the situation. The Incident Controller must be notified; Flooding All personnel onsite, including the designated Evacuation Personnel must be immediately notified; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Emergency Procedure All equipment must be safely shutdown and all electrical equipment must be isolated. During monsoon season, all emergency supplies to be kept handy at ECC and assembly point, such as flashlights, portable battery operated radios, extra batteries, emergency food and water, essential medicines, first aid kits etc.; ECC should keep track on rainfall intensity and local weather forecast during the monsoon season; The site controller should get into communication with DEOC and informing about the current situation at the site; The onsite Emergency Response Team to help the Government Relief team in guiding them about the site and rescuing the people in the affected areas Actions to be taken in response to terrorism include: Terrorism Run to a safe place, if there is nowhere to go; Turn your phone to silent and turn off vibrate. Barricade yourself in if you can Call for police help, when it is safe to do so. Further actions: Help others with first aid, if it is safe to do so; Tell the police what all you saw. Bomb Threat Actions taken in response to such a threat should be prompt and assure the safety of all. While a bomb threat may be a hoax, all such threats should be treated seriously. Procedure is as follows: Do not touch anything electrical equipment including turning lights on or off. Do not take a phone off the hook or replace it. Do not use radios or cellular telephones. Do not move anything that looks out of place. If a suspected bomb device is found, take note of the location, but do not touch it. Notify the police regarding the whereabouts of suspected bomb device. Once it is determined that a bomb threat has been made, the Safety Office will coordinate evacuation of the area. Evacuation Procedure All staff must be aware of the possible escape routes prior to the emergency situation. Always assure safety of the assembly point prior to evacuation. The procedure associated with an evacuation event is detailed below: The Disaster Response Coordinator will give instruction or the alarm sound to evacuate specific assembly areas; All staff appointed as Evacuation Officers must assist with the evacuation; All personnel onsite must follow the instructions of the Evacuation Officer; Personnel must follow the directional pointers to the nearest assembly points; Evacuation must be undertaken in accordance to the emergency lay out plan; Mobile employees must be the first to be evacuated followed by the frail and the injured; Evacuation personnel must work in pairs where possible to assist one another lifting injured employee (if any); Mobile employees who are struggling or appear unsure must be assisted; Personnel must evacuate by walking briskly and must not run; Evacuating personnel must stay calm and must not panic. Panic can spread and cause unnecessary chaos; Evacuating personnel must always keep left along the evacuation routes; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 In the case where the emergency situation results in fire or smoke, evacuating personnel must consider crawling, as this may be better than walking; Visitors that are not familiar with the evacuation procedure must be assisted; A daily record of staff and visitors must be kept; The task of the professional Emergency Services must not be obstructed; If necessary, a search / check for all unaccounted personnel must be undertaken before leaving the area; The evacuation officer must be the last one to leave the area; All personnel onsite must report directly to the allocated assembly point; Personnel must not leave the assembly point until it has been deemed safe to do so. Post Emergency Analysis and Evaluation When the emergency is over, the Emergency Response Team will carry out a detailed analysis of the causes of the accident, evaluate the influence of various factors and minimize them for future. At the same time, the adequacy of the Disaster Preparedness Plan will be evaluated and shortcomings will be rectified for subsequent improvement of the plan. 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; All n acts, hazards and sub- Site Supervisor within a reasonable time. All accidents and incidents will be immediately reported to the EHS Manager, and requisite forms completed. Co-ordination with External Agencies Site Supervisor shall coordinate with the following departments: Fire brigade; Police department; Hospitals/ Ambulance Services; Utility departments (electricity and water); Technical departments such as Madhya Pradesh State Pollution Control Board, Factory Inspectorate etc. Local Authorities and District Administration www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 District Disaster Control Room, Neemuch Training and Education Major emergency procedure should be laid down clearly and convincingly to everyone on site particularly Key Personnel. For this purpose, on site training and mock drills should be conducted periodically and documented. The duties and responsibilities of each person and the emergency procedure to be followed by him should be very clear. Procedure for Mock Rehearsal Mock drills on Disaster Management shall be conducted twice in a year as preparedness exercise. Inform all the employees about mock drill; Fix the date for mock drill; Observers (senior personnel) will not be involved in the exercise. They will monitor the Mock drill; Emergency Siren / alarm will be raised; After hearing the Siren /alarm, Emergency procedure will be followed as mentioned in the Onsite Emergency Plan; Observer will note down the activities with respect to the time and identify any gap Verification and Monitoring The EHS Manager has been tasked with the responsibility for auditing the project and implementation of emergency response procedures associated with all phases of the project. Reporting and monitoring requirements for the ERDMP will include: Monthly inspections and audits; Quarterly report of accidents/incidents; Reporting at the time of any incidents; Bi-annual disaster response drills; and Annual reporting on trainings. Disaster response drills and reporting maintained by the EHS Managers will provide information regarding required revisions to training or the disaster response actions. Each incident reported will be reviewed and investigated upon occurring. Actions will be identified where possible to improve the Training All employees and contractors will be trained in disaster response procedures within one month of their start-date. The EHS Manager shall distribute the ERDMP (together with the associated Evacuation Plan) to all parties in charge of ensuring the plans implementation. All relevant information in the DMP shall be communicated to employees and contractors. This information shall include information on potential emergency risks/threats, appropriate first person response/contact to incidents/emergencies and notification procedures. All site personnel, including contractors, are to be trained in the appropriate responses for possible disasters. The training is mandatory and is to be conducted on a regular basis. The frequency and timing of training is to take place at least quarterly. Awareness programs for community should also be arranged to apprise them about the potential emergencies that can arise in construction and operation phase. Training is to include, but not limited to the following: www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Basic Fire Safety and Rescue; Basic Life Safety and First Aid; Emergency Evacuation and Response; and Medical Emergencies District Disaster Management Plan District administration of Neemuch district has developed a Disaster Management Plan providing multi-level planning as advocated by the Madhya Pradesh State Disaster Management Authority (MPSDMA) under DM Act of 2005 to help the District administration for effective response during the disaster (available at https://neemuch.nic.in/en/disaster-management/). District Disaster Management Authority (DDMA) The District Disaster Management Authority (DDMA) is formed to act as the district planning; coordinating and monitoring body for any disaster. The DDMA comprise of Collector (as Chairperson), Supdt. Of Police, Chief Medical Officer, Superintending engineer (PWD), Chairman Municipal Board, CEO District Panchayat and Chairperson of the Zila Parishad. Roles and Responsibilities of DDMA Make and keep revising the DDMP periodically. Coordinate National, State and district disaster Management Plans and ensure its implementation. Identify various Disaster prone areas in the district and plan for mitigation and relief for various Disasters. Ensure the Mitigation, Prevention and Relief step are being followed by local bodies and provide timely instructions to them to prepare plans of mitigation, prevention and relief. Coordinate in various line departments. Auditing districts capability of Disaster Management and increase the capacity as and when required. Provide training to various officers, employees and volunteers for Disaster Management. Increase public awareness towards DM. Convey early warning to public and maintain communication infrastructure, maintain it and increase its capability as and when required. Ensure that all line departments have a disaster plan. Provide consultations and help to all government and nongovernmental organizations that are part of DM. Provide technical help to line departments. Provide instructions to all concerned parties in case of a disaster or chances of a disaster for immediate mitigation and relief to full capacity. Instruct departments to follow standards set for mitigation. Identify places that can be used as places for temporary shelters or safe houses in case of a disaster. Keep and maintain an inventory for the equipment necessary for relief work. Provide training and mock drills to concerned parties and enco relief work during disasters. Except above implement the steps as instructed by SDMA and DDMA. Have meetings as and when required www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 CONTRACTOR AND LABOUR MANAGEMENT PLAN Objective The contractor and labour management plan has been developed with the objective of defining the procedures to manage and regulate the standards of labour and working conditions for the labourers hired through Solar Plant Developer or contractors (and in case they are being hired directly by RUMSL). The Neemuch Solar Park will be developed by RUMSL and individual Solar Projects within the park will be developed by Independent Solar Project Developers (SPD). These Solar Project Developers will hire contractors and sub-contractors, who will be responsible for all on-ground activities for the project; however Project proponent will monitor the progress of the project on regular basis and will be responsible to oversee that the labour conditions. In the context of the Project, Neemuch Solar Park requires a management plan that could provide guidance and become monitoring tool to assess and align the labour and working conditions of the contractors with the applicable regulatory as well as World Bank ESS 2 requirements. Scope This plan applies to the construction, operational and decommissioning phases of the project. This plan will be applicable for all the contractors and their workers that are going to be engaged in the above mentioned three phases of the project. The scope of the present labour management plan has been broadly categorised into two components: Aspects for Ensuring Proper Labour Management There shall be a well-documented set of policies defined for the project and the workforce to be engaged for it. The indicative set of policies to be developed is enlisted below. Human resource Policy Working Relationship Policy Working Conditions & Terms of Employment Policy Non-Discrimination & Equal Opportunity Retrenchment Grievance Mechanism Child Labour Forced Labour Occupational Health & Safety Non-Employee Workers Setting up and management of Labour Camp Setting up and management of labour camp has been dealt with separately as they are considered to be an integral part of any construction project involving influx of migrant workers travelling alone or with their families including the children in some of the cases. Following are the major steps in the process: Site Selection and construction Facilities at the labour camp including safety, amenities etc. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Usage and maintenance; Dismantling and reinstatement of labour camp occupied land. Applicable Legislations There is a wide array of central and state level regulations which cover almost every aspect of the labour related issues. These acts are further supplemented by the rules, notifications and standing orders of the respective state governments. Some of the aspects like the minimum wage rates are also updated from time to time and shall need to be tracked for recent and most updated developments. Acts and regulations pertaining to the migrant workers assume much more importance especially in the Indian context, wherein migrant workers (especially from certain states like UP, Bihar, west Bengal & Orissa etc.) constitute a huge section of the building and construction industry, or for that matter any form of labour intensive industry. The plan therefore, captures almost all the existing laws and regulations pertaining to the management of labour issues in the country. National & State legislations regarding Contractor labour relationship There are several laws and rules governing labour issues in India. The local legislations likely to get triggered for the contractor labour relationship are The contract labour (Regulation and abolition) Act, 1970 and Rules The child labour (Prohibition and Regulation) Act, 1986 The Bonded Labour (Abolition) Act 1976: The Trade Union Act, 1926: Minimum Wages Act, 1948 The Payment of Wages Act, 1936, amended in 2005. The E.P.F. and Miscellaneous Provisions act, 1952 Public Provident Fund Act, 1968 Payment of Gratuity Act, 1972 Employees State Insurance Act, 1948 (ESI) Employer's Liability Act, 1938 (as amended). The Industrial Employment (Standing Orders) Act, 1946 (as amended). The Industrial Disputes Act, 1947 (as amended). Payment of Bonus Act, 1965 and Amendment Act No.43 of 1977 and No.48 of 1978 and amendments The Personal Injuries (Compensation Insurance) Act, 1963 (as amended). Factories Act 1948. Shops and Establishment Act Interstate Migrant Workers Act 1979 Maternity Benefit Act 1961 Equal Remuneration Act 1976 Building and Other Construction Workers Act 1996 Rules include: Industrial Disputes (Central) Rules, 1957 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Minimum Wages (Central) Rules, 1950 Payment of Bonus Rules, 1975 The Personal Injuries (Compensation Insurance) Rules, 1972 Standing Orders Rules 1946. References and Recommended further reading For the purpose of detailed reading on best practices related to the labour management, some of the regulations/ guidance notes which can be further referred are: The Building and other Construction Workers (Regulation of Employment and Conditions of Service) Act, 1996 and Central Rules, 1998 made thereunder stipulates that all establishments employing more than ten (10) workers will have to meet the provisions of the act and rules made thereunder; For engaging twenty or more labour on contract on any day the Contractor shall also abide by the provisions laid down in the Contract Labour (Regulation & Abolition) Act, 1970. Under this Act, the Contractor shall secure a license from the Labour Commissioner after certification from the Employer (RUMSL). The contractor shall maintain all wage, attendance, PF, leave registers as applicable under the Act and shall keep them available for any inspection by the Employer; Similarly the provisions of Interstate Migrant Workmen Act 1979 shall become applicable in case 5 or more interstate migrant workmen are engaged by the Contractor; Child labour prohibition Act shall be universally applicable to the Contractor which prohibits employing of any workmen/labour below the age of 14 years. In addition compliance to labour laws like payment of wages, payment of PF, equal remuneration, hours of work, overtime, weekly holiday etc. shall be observed by the contractor as per applicable laws; and Chapter 6 of The Building and other Construction Workers Act and Chapter 28 of Central rules stipulate the basic welfare measures that are to be provided by the employer or establishment. Similarly Chapter 5 of Contract Labour Act stipulates the basic welfare measures. The stipulations shall be reviewed and followed. Contractor and Labour Management- Specific issues The challenges that the project is likely to encounter during construction and operational phases regarding the maintenance of labour standards could be: Lack of defined terms of employment for some worker or labour by sub-contractors might be possible; Likelihood of child labour at varying scale, particularly during development/construction phase on account of migrant labour; Discrimination in remuneration between male and female labour or between local & outside labour; and Inappropriate living arrangement in labour colony or workers colony; Conflict with local population. The section below describes in detail the challenges as well as the suitable measures to manage these challenges. However, the contractors would not be expected to limit their action plan against the suggestive measures. Defined Human Resource Policy, working conditions and terms of employment www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Management Plan The contractors will be required to take following mentioned measures to regulate and manage the workforce engaged during construction as well as the operational phase of the project. Adequately cover the contract labourers that will be engaged in the construction phase of the project within the HR policy; Maintain consistency with the applicable labour laws; The Policy should be commensurate with the size and type of workforce; Policy should be clear and in a language understandable to workers; Procedure to make provisions of the policy very clear to each worker at the outset of joining; (1) (2) Working condition and terms of employment should be documented and communicated properly to all workers; Wages and benefits must be clearly communicated and understood by the workers; Provide all workers with a contract in a language understood by them; Routinely provide workers with a clear record of wage calculation and deduction; On-going internal verification that all workers are receiving wages and benefits as prescribed by law; Ongoing communication and training on legal labor rights and company personnel policies; Worker representatives meets regularly with HR and company management; Training on minimum legal benefits for all workers, including contractors, and employment agencies; Cooperation with local labor ministries. (1) Working condition is defined as the conditions in the workplace and treatment of workers. Condition in workplace includes the physical environment, health and safety precautions, and access to sanitary facilities. Treatment of workers includes disciplinary practices, reason and process for termination of workers and respect for workers personal dignity. (2) Terms of employment includes wages and benefits, wage deduction, hours of work, rest days, overtime arrangements, overtime compensation, medical insurance, pension, leave for illness, vacation, maternity and so on. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Table F5 Aspects for Ensuring Proper Contractor and Labour Management SN. Guiding Principles Desired Actions Special Remarks and Suggestions Monitoring Indicators 1 Human resource Policy RUMSL & its contractors Centrally organize all policies The contractors will be required to put in Complete review of all policies will have a documented and procedures; place a well-defined and documented and procedures policy and procedure Human Resource policy at the outset of Identify and record Review of management- related to Human the project in order to ensure efficient responsible person and last worker committee meeting resources. and fair management of workers date modified; minutes engaged in the overall process of work. RUMSL its contractors Conduct an annual review of In case the contractor has existing HR Communications (memos, will inform workers of their all policies and procedures; policy, the same can be made letters, etc.) to workers, rights under national applicable for the workers to be suppliers, contractors and labour and employment Prominently display policies engaged for the project. multi-stakeholder groups law and procedures in all local languages, especially which Interviews with management Policy must be clear and the staffs and workers and workers understandable to all understand; workers Interviews with external Appoint a person responsible stakeholders for monitoring policies and Budgets related to procedures related to labour implementing labour policy law implementation; Training curricula and logs Implement standardized routine training 2 Working Relationship Policy RUMSL & its contractors Provide all workers with a The working relationship policy can be a Contracts for all workers will document and contract in their native separate document or it can be Policies and procedures communicate working language integrated with the HR policy. The related to worker contracts and conditions and terms of working relationship policy will Provide documented training wages employment to all workers essentially ensure on contracts, wages, benefits Communication and training Wages and benefits must and deductions for all workers Coverage of each category of workers on wage calculation, including be clearly communicated including direct workers, contract Routinely provide workers local laws and understood by all workers and supply chain workers who with a clear record of pay workers will be engaged in operation; Payroll records, time sheets www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 SN. Guiding Principles Desired Actions Special Remarks and Suggestions Monitoring Indicators calculations in the form of Consistent with regulatory requirements Piece rate or performance pay wage slips on labour as per the national and state calculations verified against labour regulations: minimum wage Worker interviews 3 Working Conditions & Terms of Employment Policy If there is a collective On-going internal verification Defined Terms of Employment and Collective bargaining bargaining agreement, that all workers are receiving procedure for sharing the same with agreement (if one exists) RUMSL & its contractors wages and benefits as each new worker in a transparent Worker contracts will respect its terms prescribed by law manner; and Policies and procedures RUMSL & its contractors On-going communication and Procedure for establishing and updating related to wages, benefits, must provide reasonable training on legal labour rights records of employment relationship hours and leave working conditions and and company personnel conditions. terms of employment, at a policies Wage calculations as they minimum complying with relate to local laws Worker representatives the various local laws as meets regularly with HR and Worker and external described in this plan company management stakeholder interviews Training on minimum legal National law as it relates to benefits for all workers, wage and benefit minimums including contractors, and Employment and termination employment agencies records 4 RUMSL & its contractors Clear communication to The purpose of forming a trade Documented policy regarding workers on their rights to union/workers organisation is to create a collective bargaining rights to form and to join collective bargaining platform for collective bargaining to Minutes and records from protect the interest and rights of the Allow workers to raise collective bargaining sessions, workers with regard to working RUMSL & its contractors workplace related issues; reviews or other actions conditions and the terms of employment. cannot interfere with or Regular training on worker- The contractors will have to abide by the Procedure for workers to discriminate against manager communications Indian regulations on provision for trade select worker representative workers who choose to union and the workers should not be organize www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 SN. Guiding Principles Desired Actions Special Remarks and Suggestions Monitoring Indicators Worker representatives Regular meetings of restricted by the contractors to form without management must have access to management and worker trade union, if they wish. interference management representatives The construction phase is likely to Interviews with workers, NGOs Worker organizations are Periodic documented engage migrant labour and is expected and trade unions expected to fairly communication with local to be over in one-two years after getting Collective bargaining represent the workforce unions and NGOs started. During this phase, the labourers agreements should be provided a suitable mechanism to raise their grievances and Grievance mechanism genuine work related issues, alternatively allow them to create a platform for collective bargaining. During operational phase of the project, contractors will be required to consider following mentioned measures to ensure freedom of association for workers and provide them an alternate grievance mechanism The contractors shall have clear communication with the workers on their right to form trade union and collective bargaining; There will be regular trainings on worker-manager communications There will be regular meetings of the workers 5 Non-Discrimination & Equal Opportunity People should be hired, Clearly define anti- The contractors will be required to make Discrimination policy and promoted and discrimination policy in hiring, employment decisions on the principle related employment policies compensated solely training, promotions and of equal opportunity and fair treatment and procedures compensation and will not discriminate with respect to www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 SN. Guiding Principles Desired Actions Special Remarks and Suggestions Monitoring Indicators based on their ability to do Regularly review worker and aspect of the employment relationship Company policy and the job manager demographics like recruitment and hiring, procedure to address and compensation, working conditions and manage discrimination issues All workers should have Develop long term terms of employment, promotion etc. when found equal access to training, remediation plan to address tools and opportunities for past discrimination Contractors however will have to give Comparative demographics of advancement preference to the project affected people workers and managers Provide regular training to during the recruitment process as part of All workers should be free workers and managers Documentation of handled the R&R policy which has a provision for from harassment by discrimination cases Establish confidential and employment to one member of each management or other secure communication affected family. Diversity training curriculum workers channels for workers to reach and attendance log Positive discrimination managers may be allowable in cases Interviews with workers and where it protects Actively promote a managers, including those disadvantaged or harassment-free workplace who may be likely to be excluded groups and discriminated against provides them special Interviews with local NGOs opportunities and trade unions Hiring, promotion and termination records Local laws related to discrimination Hiring of the local residents/ PAFs in the various jobs 6 Retrenchment RUMSL and its Solar Policy and procedure for The contractors may be asked to Policy and procedure related Plant developers will workforce reduction, including prepare such a lay off plan especially if to workforce reduction, develop and implement a worker selection the local community is engaged as severance and transition plan to mitigate the labourers, as most of the migrant Analysis of alternatives to Analysis of alternatives adverse impact of labourers are shifted to other sites for workforce reduction employed for workforce retrenchment if it work by the contractor itself. reduction. Engage workers in discussions with workers www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 SN. Guiding Principles Desired Actions Special Remarks and Suggestions Monitoring Indicators anticipates a large related to workforce reduction Procedures for selecting number of layoffs as early as possible workers impacted by The plan will incorporate Communication to all workers workforce reduction non-discrimination about why and how the Documentation of prior principles and include the reduction will take place instances of workforce input of workers, their reductions Discussions with local NGOs organizations, where about how the community Minutes from management appropriate, the impact of workforce reduction meetings and discussions government could be minimized Communications with workers related to workforce reduction Communications with external stakeholders and community groups 7 Grievance Mechanism RUMSL & its contractors Establish clear policies and For a healthy work environment, Documented policy and will establish a procedures for grievances contractors should create an procedure for worker transparent process for atmosphere where workers feel safe grievances Communicate the grievance workers to express expressing their concerns and the process to all workers in a Worker and manager concerns and file grievances are settled mostly through clear, understandable manner interviews grievances Provide on-going training to the need to lodge the complaint. Training curriculum and log on There will be no retaliation all workers However there should be a formal grievance handling or discrimination against grievance redress mechanism which is those that express Document all grievances and Communications to workers, simple and secure; free from fear of grievances the resulting actions supervisors and managers retaliation; responsive and fair, and RUMSL & its contractors Make worker representatives allow workers to file anonymous Records of complaints lodged will treat the grievances a key part of the process complaints as well. The grievance and actions taken on seriously and take mechanism system should not impede grievances appropriate action the aggrieved to access to court in case Employment and termination he/she is not satisfied with the outcome records RUMSL & its contractors derived from the formal system. grievance mechanism does not replace other www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 SN. Guiding Principles Desired Actions Special Remarks and Suggestions Monitoring Indicators channels as defined by For an effective grievance redress law or collective system, the contractors will have to bargaining agreements Establish clear policies and procedures for grievances based on above outlined principles; Communicate the grievance process to all workers in a clear, understandable manner; Document all grievances and the resulting actions; and Make worker representatives a key part of the grievance redressal process. 8 Child Labour RUMSL & its contractors Write clearly defined policies The migrant contract labourers may be Policies and procedures for will not employ workers and procedures for age expected to bring their family along age verification in hiring under the minimum age verification make them during the construction phase of the Interviews with workers, local for employment as publicly available project. The family might also children, trade unions and defined by national law accompany the labourer to their Develop remediation plan for NGOs (.i.e. below 18 years of workplace thus enhances the possibility use in cases where children age) of child labour at varying scale. Further Visual observation are unknowingly employed during the operational phase of the Workers between the Pay records, medical records, project, the possibility of adolescent minimum age and 18 will Labour policies and birth certificates, panchayat workers (between 14 to 18 years) not be employed in procedures (ex: child certificate entering into hazardous working dangerous work or work presents false ID) conditions cannot be ruled out. that interferes with their Engage with local education or development The contractors will need to adopt stakeholders to develop suitable proactive mechanisms to The Indian regulation proactive plans to address prevent child labour in any form. Some recognises a person as a child labour issues of the measures in this regard could be child who has not Communicate child labour as follows; completed his/her 14 suppliers years of age. The World and contractors and provide Bank ESS 2 requirements www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 SN. Guiding Principles Desired Actions Special Remarks and Suggestions Monitoring Indicators say that company cannot them with the training and Identify the types of activities during the employ workers under the tools to address the issue entire project operation that could have minimum age (completed a possibility of child labour; 14 years in Indian context) and workers between the Clearly defined policies and procedures prescribed minimum age for age verification; and 18 years may be Visual observation and verification employed in non- thereupon; hazardous working Develop remediation plan for use in conditions with certain cases where children are unknowingly terms and conditions. employed despite the clear policy and procedure of contractors on no-child labour. 9 Forced Labour RUMSL & its contractors Any involuntary work which is performed Employment contracts in all will not employ forced freedom in employment under threat of force or penalty, is appropriate languages labour contract considered as forced labour. It can be in Contracts with employment or form of bonded labour, indentured Workers have the right to Provide employment recruitment agencies labour or similar labour arrangement, retain their personal contracts to all workers in slavery or slavery like situation. There Payroll records, timesheets documents and money their language - direct or can be a possibility of forced labor by and wage deduction contracted Workers are free to leave sub-contractors or petty contractors calculations the workplace after work Define and enforce policy during the construction or operational List of permanent workers and regarding use of employment phase of the project; however the Workers have the right to contracted workers at RUMSL agencies and expectations likelihood of forced labour is expected to resign facility be negligible for the regular workers If employment agencies are during operational phase in view of Worker IDs used, audit relationship hiring system structures in place and an Interviews with all workers, between the agency and the adequate HR management department. employment agencies and workers external stakeholders Provide training for all workers to explain their rights Interviews with security guards www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 SN. Guiding Principles Desired Actions Special Remarks and Suggestions Monitoring Indicators Pay all job related training and equipment expenses 10 Occupational Health & Safety RUMSL & its contractors Structuring an OHS team and RUMSL and its Solar Plant developers Visual observation will take all reasonable an OHS accountability is expected to have its own system. Exposure to hazardous agents precaution actions to framework (including Either the MDO/ contractor will have to monitoring log protect the health and production area) safety of workers or in case it has its own, it needs to be Manager and worker Conducting a comprehensive reviewed by RUMSL, before the starting interviews Ensure that workers are job safety or job hazard of the work during construction or not exposed to analyses Accident and medical operations. unnecessary or treatment logs Developing a Corrective OHS unreasonable risks at the Some examples of things to be done Action Plan based on the Equipment maintenance logs workplace, dormitories include: likelihood and severity of the etc. Fire and safety drill logs consequence of exposure to Integrity of Workplace Structures Implement an OHS the identified hazards reachable, easy to clean, fore resistant, Health and safety risk analysis management system floors Health and safety inspection Proper equipment design, consistent with logs with test results maintenance and procedures, Workspace and exits unobstructed, international standards such as: Designing machines clearly marked, consider disabilities Government health inspection such as OHSAS 18001. Fire Precautions reports Systematically assess all eliminate trap hazards of the OHS risks, Amenities- toilets, potable water, lighting Training curriculum and logs Turning off, disconnecting, conducting a isolating, and de-energizing Safe Access even pathways, falling comprehensive job safety (Locked Out and Tagged Out) objects, railings or job hazard analyses. machinery with exposed or First Aid- training implement preventive and guarded moving parts or protective measures being serviced Fresh air supply according to the order of Physical Hazards- Working at heights, Marking and checking all priority: Eliminating the Vibrations, Electrical, Ergonomics, energized electrical devices, hazard, Controlling the illumination cords and lines with warning hazard at its source, signs PPEs Minimizing the hazard, Providing appropriate www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 SN. Guiding Principles Desired Actions Special Remarks and Suggestions Monitoring Indicators personal protective Implementing proper Communication- Induction orientation, equipment monitoring systems of training Document, investigate hazardous agents and proper and report all accidents control measures (eliminating and occupational risk, PPC, PPE) diseases. Investigate and identify the root causes of all accidents with working time loss, and implement appropriate corrective actions Note: This can be done through the involved contractors also. 11 Non-Employee Workers of RUMSL RUMSL will extend the Provide employment Contracted labour contracts in previously discussed contracts to all workers in all appropriate languages indicators to contractors their language - direct or Contracts with employment or hired directly or through contracted recruitment agencies employment agencies. If employment agencies are Payment records, timesheets RUMSL will not use used, audit relationship and wage deduction contracting as a means of between the agency and the calculations for contracted circumventing labour workers workers rights and laws. Provide training for all Listing of direct employees Employment and contracted workers to explain and contracted workers at recruitment agencies will their rights be monitored to verify Include contracted workers in their adherence to labour Interviews with managers, grievance process access rights and laws. employment agencies and and training external stakeholders www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 SN. Guiding Principles Desired Actions Special Remarks and Suggestions Monitoring Indicators Interviews with contracted workers - directly contracted and through agencies www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 The requirement of workers accommodation stems from the type of workforce that will be required during the construction and operations phase of the project. RUMSL & its contractors will have to adopt the following approach to handle the issues of workers accommodation and it should be dealt step by step in following manner: Assessment of the type and number of workers who will be requiring accommodation facility; Impact assessment of workers accommodation on local community and accordingly plan mitigation measures; Identify applicable regulatory requirements on establishment of workers colony; and Determining the standards to apply to the location of facilities, the construction of housing and provision of facilities Managing accommodation. Apparently local working population of the project area cannot meet total project workforce requirement, therefore it is likely that workers from outside will need to be recruited. Given the remote location of the project, the outside workers will require adequate accommodation arrangements. Types of workers requiring accommodation arrangement can be classified in following categories: Migrant labourers during construction phase Supervisors and executives of the contractors engaged in construction phase Regular workers, supervisors and executives during operational phase. Housing standards for workers accommodation Labour Colony: The contractors would be recommended to prepare temporary accommodation facilities for the construction labourers preferably within the lease boundary, away from existing local community so as to leave minimum possible adverse impact upon local community. The standards that are to be maintained for labour colonies will be: Allocation of minimum space per person or per family; Adequate sewage and garbage disposal systems; Adequate sanitary and washing facilities, ventilation, cooking and storage facilities and natural and artificial lighting; If the contractors are required to provide accommodation for single labour or labour separated from their family, following standards should be suitably applied; A separate bed for each worker; Separate accommodation for families and bachelors; Adequate sanitary conveniences; Common dining rooms, canteens, rest and recreation rooms and health facilities, where not otherwise available in the community. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 381 Further as per the Building and Other Construction Workers (Regulation of Employment and Conditions of Services) Act 1996, the contractors will have to provide temporary accommodation facilities to the construction laborers free of cost and as soon as construction work is over, the employer at his own cost will remove/destroy the temporary structures and restore ground in good level and clean conditions. Workers Colony The contractors will have to abide by all applicable rules and regulations pertaining to the design and construction of the building as well as facilities to be provided therein while planning for the accommodation arrangements for the workers. Further a suggestive guideline for workers accommodation arrangement based on international standards is prescribed below. Table F6 Standards for Workers Colony Standards Parameter Requirements as well as Monitoring indicators Location Reasonable distance from Project Site Adequate Transportation arrangement Drainage Proper drainage system Avoid accumulation of stagnant water Ventilation Adequate ventilation and air conditioning system Natural lighting available Artificial lighting available Water Adequate and convenient water supply Drinking water meeting national and WHO standards Regular monitoring of drinking water Waste water and solid waste Proper discharge of waste water and sewage Establish Sewage Treatment Plant (STP) if required Solid waste management system Pest control mechanism Bachelor Accommodation Separate bed for each worker Minimum space available Storage for personal belongings Separate storage for PPEs Family Accommodation Adequate space Other suitable housing facilities described in this table Toilet facilities Adequate number of toilets Convenient location Constructed of good materials Easily cleanable Kept in working condition Separate for male and female except for family accommodation Bathrooms and other sanitary Made of anti-slip hard washable materials facilities Adequate number of bathroom and hand wash facilities Kept in working condition Convenient location. Separate for male and female except for family accommodation Adequate supply of cold and hot running water www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 382 Standards Parameter Requirements as well as Monitoring indicators Canteen and cooking arrangement Adequate space Constructed of good and easy to clean material Option for separate cooking Adequate space for separate cooking Hygiene in canteen/dining halls and cooking facilities Adequate facilities for cleaning, disinfecting and storage of cooking utensils and equipment Adequate food waste disposal Laundry Provide laundry facility Nutrition and food safety Appropriate level of nutrition value Consideration of religious and cultural background of workers in food selection Workers could have choice of food Medical facilities First aid facility Own dispensary Recreational, social and market Community centre for social gathering facilities Market complex Provide possible recreational facilities like tennis court, swimming, park etc. Considering the current pandemic situation, RUMSL is recommended to follow the SOPs on COVID 19 below. The Site team and EHS personnel shall closely monitor and take the responsibility of proper implementation of the given below SOP. Box F.1 SOP on CoVID 19 Pandemic CoVid 19 SOP to be followed in Labour Camps The speed of CoVid workers as well as that of members of the public with whom workers may come into contact. To better understand physical & economic risks to workers, RUSML should ensure that these considerations are properly integrated into the emergency response plan. A brief and non-exhaustive overview of prevention and response measure has been provided below though the understanding and medical advice is being updated frequently, and the measures must be updated to the most recent advice, including central, state and district level guidelines: Providing information about CoVid 19 to engaged staff & workers at site level This process will include awareness campaigns, training or the establishment of specific communication channels. No practice of discrimination against or stigmatization of person affected, or his family; Encourage workers to stay at home, in-case they report symptoms of CoVid 19. o In this case, a RUMSL shall ensure a separate accommodation facility for the affected/ or CoVid symptomatic person; Awareness about proper cough hygiene should be given, also a proper use of soap, frequent hand wash, sanitizers should be given; Staff & workers to strictly follow social distancing at work place; o Shall ensure that workers maintain a safe distance of 2 meters at workplace, limit gatherings and work in shifts, up to large extent; Cleaning and dis-infecting protocols should be extended to food preparation facilities, kitchen staff should be strictly prohibited if they discover any symptoms of CoVid; o Shall improve ventilation or air- filtration, when not in open space. The accommodation facilities provided, should be ensured to have proper ventilation and air-filtration facility; Usage of PPEs at workplace; o This involves usage of gloves, mask, facemask etc. at workplace. Especially when they are working in a large number during construction phase. Proper disposal of PPE kits at daily basis should be monitored; Responsibilities and Accountabilities The overall responsibility of the aligning the contractor labour relationship as well as maintaining labour standards as per the regulatory and international standards would be vested with the Human www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 383 Resource department of the key contractors. These key contractors would also be held responsible for regulating labour issues of their sub-contractors or petty contractors. The role of RUMSL will be limited to periodic monitoring and provide direction in case of any deviation from the standards. RUMSL will also be empowered to take strict steps against contractors in case any serious violation of labour issues like child labour, bonded labour and so on is observed in monitoring process. However, the overall responsibility of ensuring the compliance to the standards rests with RUMSL, and to ensure that contractors are abiding by the same. RUMSL will therefore need to put especially some staffs dedicated to the labour management and OHS issues: 1. Supervisor (S&C); 2. EHS specialist 3. EHS supervisors Contractors of RUMSL will put in similar corresponding staff for the direct implementation of the labour management plan: 1. Dedicated Health & Safety supervisors 2. Dedicated labour officer 3. Dedicated supervisor for HR, HR policy and working conditions, wages & labour related issues. Within 30 days from the appointed date, the Contractor shall prepare and submit 4 hard copies and 1 at addresses specific activities that will be undertaken to minimize the impact on the local community, Camp Management Plan addresses specific aspects of th mandatory and repeated training and awareness raising for the workforce about refraining from unacceptable conduct toward local community members, specifically women; informing workers about national laws that make sexual harassment and gender-based violence a punishable offence which is prosecuted; introducing a Worker Code of Conduct as part of the employment contract and including sanctions for non-compliance (e.g., termination), manual scavenging, engagement with local residents, child labour, non-discrimination, harassment of co-workers including women and those belonging to SC and STs and other minority social groups; contractors adopting a policy to cooperate with law enforcement agencies in investigating complaints about gender-based violence; training programs on HIV/AIDS and other communicable diseases; shment and demand for affordable housing for this additional workforce in terms of rentals, hostels, apartments, etc.; and complaint handling Mechanism at the project level. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 384 Monitoring and Evaluation RUMSL will put in place a robust mechanism for the purpose of monitoring and evaluation of the Labour management practices for its project. The monitoring would not only help keeping track of labour related management practices on ground, but also to improve the existing identified gaps which will require to be addressed while meeting the need to comply with the regulatory and International standards. RUMSL will ensure setting up of both internal and external monitoring systems to assess the progress and evaluate the performance on the labour management practices. Internal Monitoring Internal monitoring of the labour management implementation will be done by the Social and Community Supervisor of RUMSL in case the labour officer is not appointed; however preferably a labour officer will be appointed. The labour officer will coordinate with the EHS officer and representatives from the sub coordinator part to conduct internal monitoring from time to time. Internal monitoring will also be done through regular submission of the reports from the sub-contractor side on various monitoring indicators as mentioned in tables above . Apart from daily or weekly reporting, monitoring will also be carried out on quarterly basis to assess the performance on the various labour related issues. The findings of these internal monitoring and will be documented and brought before the advisory committee for review and guidance. External Monitoring/Evaluation External monitoring of the labour management practices being carried out under the project will be done independently by a third party at the end of each financial year to monitor the labour management practices. External monitoring will also be based on various monitoring indicators as mentioned earlier. Allocation of finances The sub-contractor will be responsible for the financial allocation of resources to implement the contractor and labour management plan. Sub-contractors for the various aspects of the project will be responsible for incorporating the cost of implementing the construction and labour management plan at the bidding stages itself. RUMSL and is contractors in their quotation request from the contractors will be responsible for putting up the requirements from its contractor regarding the labour management plan. The cost of the labour management plan will therefore be already included in the bidding document, especially with regard to provision of the health and safety PPEs, safety managers and construction of the labour camp as required. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 385 GENDER IMPACT ASSESSMENT AND ACTION PLAN Background This gender assessment intends to outline the gender situation in the Study Area and specifically in the Project villages. It also aims to identify the socio-cultural factors contributing to the gender issues that are relevant to the project, to analyze and evaluate the potential gender mainstreaming opportunities that can be adopted by the project during the course of its operation. This gender assessment is largely based upon the stakeholder consultations conducted by ERM during site visit in the month of November 2019, supported by Census 2011, which assists in presenting the current social context in the area. that the Government of India has charted. Some of the key such initiatives are enlisted below. Principles of Gender Equality are enshrined in the Indian Constitution; The Indian Constitution not only grants equality to women but also empowers the State to adopt positive discrimination in favour of women; In terms of Legal Provisions, the crimes directed specifically against women are characterised as Crimes against women and identified under Indian Penal Code. Legal Regulations supporting Gender Mainstreaming There are various Gender focussed legal regulations in India and the same are presented below. Equal Remuneration Act, 1973 provides for payment of equal remuneration to men and women workers for the same work of similar nature without any discrimination. In order to ensure social security to the workers including women in the unorganised sector, the Government has enacted ct 2008. The Maternity Benefit Act, 1961 and The Maternity Benefit (Amendment) Act, 2017 regulate employment of women in certain establishments for a certain period (26 weeks) before and after childbirth and provides for maternity and other benefits. The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act (POSH), 2013 has been enacted, which covers all women, irrespective of their age or employment status and protect them against sexual harassment at all workplaces both in public and private sector, whether organised or unorganised. Additionally, India has also ratified various international conventions and human rights instruments committing to secure equal rights of women. Key among them is the ratification of the Convention on Elimination of All Forms of Discrimination against Women (CEDAW) in 1993. Understanding Gender role in Society Gender roles in household activities The consultations suggest that in a household, women from most social and caste groups, take equal ownership and responsibilities of working on agricultural fields owned by the household, taking care of domestic chores of cooking, cleaning, fetching water from community water points to their respective houses, caretaking of children and elderly as well as tending to livestock owned by the family. Men are largely responsible for management of financial resources, sale and purchase of goods, etc. and their contribution to domestic chores of cleaning, cooking, caretaking is limited. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 386 Gender roles in Livelihoods and Economic activities The occupational profile of the community is detailed in Section 4.4.7 options comprise working as cultivators, agricultural labours, construction labours, etc. The men are also understood to migrate for employment to nearby cities and town for work, either alone or with families. There have not been any cases reported for women working as construction labourers or in any enterprise outside their respective villages and are largely engaged as agricultural labourers in the fields owned by their families (unpaid labour work) and in agricultural fields of other against payment of daily wages. The women from Rajput community are a little different from the rest, as they are only responsible for household chores and have restrictions on their movement outside the house. On the agricultural fields, women are involved in cutting, sowing, threshing, watering, and collecting fuel wood. The women engaged as agricultural laborers are paid an amount of INR 100-200 per day where as men are paid INR 200-300. The tasks that are taken care of by men include sale and purchase of agricultural inputs, sale of crops in markets and Mandis and other farm based activities. Gender roles in livestock management Women take care of domestic activities linked to livestock management, comprising stall feeding of livestock, cleaning of livestock and their sheds, preparation of dung cakes, milking, etc.; but are not responsible for grazing of livestock outside the household premises. Male members of the household are responsible for livestock grazing near the villages, sale and purchase of livestock, livestock feed and by products. Gender profile in Asset ownership The exposure of women outside the realms of their villages is understood to be limited in general. There are no women Self Help Groups reported to be active in the project villages, in the village consultations. The ownership of land and assets by women is also understood to be minimal and in cases where women own land legally, the management of the same in terms of sale, purchase or usage is largely decided by men, with limited or no consultations with women. The proceeds from sale of land and its usage is also usually discussed within households but the final decision on usage of money is taken by male members of the household. The men have more social exposure, access to cash and linkage to banking services, understanding of financial and legal instruments, etc. which makes them the natural decision making authority in a household on aspects linked to assets or financial matters. Women are restricted in their movement outside villages due to socio-cultural practices and safety issues and in spite of being equal contributors to the household and agricultural fields (which largely forms unpaid work); have less access to cash and resources for discretionary spending. The societal norms also play a role in this scenario where education of male child is given importance over female, thereby limiting their exposure and their role to caregivers and in charge of domestic responsibilities. Women Headed Household There are certain women headed households in the project villages; however in most cases these Women Headed families are provided financial support and security by other members of the family, as part of the prevalent joint family and living systems. However, certain independent women headed households have to fend for themselves, by working as labourers on agricultural fields. These Women headed households (both joint as well as independent) face additional risks of not being included in negotiations, or other key meetings due to prevailing cultural norms and may not therefore receive the benefits and advantages compared to those who do participate. Thus they www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 387 become a little more vulnerable in cases of sale of land for the project, where there is a chance that the proceeds from sale of land do not reach them. Role in decision making The men lead in the decision making process at the household and community level, although the participation of women is understood to be crucial, especially at the household level. According to the consultations undertaken, the women are reported to have limited say in the financial decision making or land transactions; however, in aspects such as agricultural activity and the education of the children, women are reported to take more decisions than men. Women of most caste groups do not actively participate in community and village level meetings, which are primarily led by men. Even in the case of Badi, where the Sarpanch was a woman, (as the seat of the Sarpanch (village head) was reserved for a woman), all key activities were undertaken by her husband, known as the Sarpanch-pati. Gender Lensing of Socio-economic impacts of the project The detailed social baseline for the project is presented in Section 4.4 of ESIA and the understanding land data provided by RUMSL, there are 6 female private land owners and 12 female Patta land owners out of 48 private land owners and 73 Patta land holders linked to the land identified for the project. Out of the private and patta land identified for the project, the combined ownership by women (Private +Patta land) is 5.2% in Badi village, while 26.4% in Kawai and 14.2% Bardawada villages. The potential social impacts that can be caused by the project on the receptors can be broadly categorized as the following. Reduction of Land-holdings and loss of agricultural income to the Private and Patta Land Holders, agricultural labourers, etc. Reduced availability of Government land that is currently being used by the community as Common resources like grazing land for livestock, collection of firewood by women, for access and easements to their assets, religious trees or structures, etc. Reduction in/absence of income from the Government land that is encroached/ squatted upon by local residents for agriculture, fodder lots, etc. Community Health and Safety related impacts; Impacts on Community Resources like Water, Roads, Forests and temporary use of land during construction phase; and Positive Impact due to short term availability of Employment Opportunities (largely during construction stage) and some new employment creation during Operations phase. The receptors of these socio-economic impacts comprise both of male and female residents in the project area, whereas in the general nature of operations, the mitigations are implemented in a gender-agnostic manner. In cases where the land from Women Headed households are procured, there is a chance that the household is rendered landless and thus special assessment of the situation needs to be done. The impact on Women due to project activities is detailed in Section 6.4.8, which comprises the mitigation measures as well as assesses the Impact significance. The detailed Gender Action Plan has been devised for implementation of the action items identified, which is presented in Table below. The mitigation measures that will be derived on Gender aspects during RAP and LRP surveys, shall also be guided by this Gender Action Plan. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 388 Table F7 Gender Action Plan Action Items Timeline Responsibility Means of Verification for Potential Risk in Risk Mitigating Measures achievement of Targets achievement of Targets Loss of Land Related Impacts Ensure that the land sellers inform Ongoing till RUMSL along with Tehsil Review of Sale Deed NA Public disclosure of the and disclose the sale of land completion of land Administration timelines, with a focussed parcels for the project to their household, including women procurement village level to disclose land procurement activities and time lines It is recommended that the Ongoing till RUMSL along with Tehsil Review of Bank account There might be an Put across this proceeds from the sale of land completion of land Administration ownership documents prior existing bank account requirement during the should get deposited in a joint bank account with the spouse, if procurement to release of payments initial stages of land feasible and the key member of related discussion. the family will be Require the presence of reluctant to make the the spouse at the time changes of hand-over of the cheque or sale agreement papers. If the land is purchased from a Within 6 months of RUMSL Review of Sale Deeds and NA Liaise with the bank branch Woman Headed household, then initiation of bank account name and to ensure against misuse. special provision for confirming the bank account use (by the women construction access by actual holder. Financial literacy training and not other family member) programs should be needs to be done to ensure conducted for women in the against fraud project area and specifically for the ones belonging to PAHs. As part of the livelihoods Within 6 months of RUMSL Allocation of grazing land Lack of use due to Assist in creation of a village restoration plan, development of a initiation of parcels and providing distance issue of the level committee with fodder intensification program and creation of fodder lot for ease of construction demarcated access routes to parcel and power representation from project, access and availability of fooder relations in the village for smooth functioning and and firewood near project villages www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 389 Action Items Timeline Responsibility Means of Verification for Potential Risk in Risk Mitigating Measures achievement of Targets achievement of Targets the same; disclosure of the may prevent women decision making over access same to women groups from lower castes in and control of such accessing such land collective/common resources Employment related impacts During planning and Ongoing till RUMSL, Sex disaggregated data Reduced Organize separate women consultations or FGD with construction phases, all construction phase EPC contractor of attendees shall be participation of community consultations shall representative (during the documented in records women due to socio understand their perspective have a target of at least 50% construction phase) of Stakeholder cultural norms; and provide project updates female participation, or, Project operator Consultations; Silent presence of Require sign-off on key women only consultations in (operations phase) Photo documentation women during information disclosure, and all the Project Villages of and signatures of consultations due to community decisions Bardawada, Kawai and Badi attendees cultural norms of through the construction to ensure that women are not women not phase only involved and aware but speaking up in a also have the opportunity to village gathering in participate in decision-making. front of men. Organize separate women consultations or FGD with understand their perspective, if the women do not express opinions as part of larger groups Ensure that the contract Within 3 months RUMSL Review of sex Contractor considers it is Advertisements for job hard to source women agreements with contractors from Plan disaggregated pay vacancies for women contains clauses on implementation, upto sheet records of each should be posted at key requirement for contractors to completion of month; locations near the hire at least 20% women as construction related project area, comprising staff and workers for the activities bus stops, Government www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 390 Action Items Timeline Responsibility Means of Verification for Potential Risk in Risk Mitigating Measures achievement of Targets achievement of Targets project and ensure equal pay Cross verification of the schools, Government for women for same nature of select workers on hospitals, dispensaries, work as added as clauses in periodic basis. etc.; the contract agreements for Talk about the potential the contractors. job opportunities for women during community consultations and get a feedback on the women with required key skills that are interested. Undertake a profiling of the Within 6 months of RUMSL along with SPDs Need Assessment Sustainability of the CSR Clear communication on Report; programs might be an objective and duration various social groups in the initiation of Monitoring of progress issue, in terms of long of CSR programs; Study Area, to understand the construction related term benefits of action plan Selection of individual needs and concerns activities Implementation partners of the various women that can provide belonging to different social linkages to livelihood groups and design community programs that are development, community sustainable. investment and CSR programmes in light of the same, to ensure that benefits also target women Contractor shall provide safety Ongoing upto RUMSL along with Visual observations/ audits Contractor may site Include these provisions gear and protective equipment to financial constraints completion of Contractors as part of contract keep both men and women workers safe on the job construction agreements with activities contractors to set expectations initially www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 391 Action Items Timeline Responsibility Means of Verification for Potential Risk in Risk Mitigating Measures achievement of Targets achievement of Targets Provide segregated toilet and Ongoing RUMSL along with Site visits and site maps Contractor may site Include these provisions sanitation facilities for men and should include separate Contractors financial or logistical as part of contract women with reliable water supply, male and female toilets proper lock and lighting. constraints agreements with contractors to set expectations initially Ensure that a crèche is Prior to RUMSL along with Physical verification Contractor may site Include these provisions established if the women engaged commencement of Contractors financial or logistical as part of contract at the project are 50 or more, as per provisions of Maternity Benefit construction constraints agreements with (Amendment) Act, 2017 activities and contractors to set ongoing till expectations initially completion of construction The staff and workers recruited for Start of Construction RUMSL Records of Trainings in None foreseen NA the project, including the EPC and phase activities and terms of number of staff O&M contractors and their sub- ongoing on monthly and workers trained in contractors shall undergo periodic basis each session; trainings on Prevention of Sexual Photo documentation of Harassment as per the corporate training session POSH policy of the project (developed by RUMSL), which will be applicable for the project. Additionally train the staff and workers on provisions of GRM that are applicable for them and ways to use the GRM for the project www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 392 STAKEHOLDER ENGAGEMENT PLAN Background Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July 2015 as a 50:50 joint venture (JV) company between Solar Energy Corporation of India Limited (SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL). Its primary objective is to develop and facilitate development of large scale solar power projects in the state of Madhya Pradesh. RUMSL is planning to develop three Solar Parks in Madhya Pradesh and their associated internal evacuation infrastructure and Transmission Lines. This Stakeholder engagement plan is developed as part of the Environmental and Social Impact Assessment report for proposed 500 MW Neemuch Solar Park. The proposed 500 MW Solar Park is proposed to be developed on allotted 1092.7 Ha of land area spread across three villages namely, Badi, Kawai and Bardawada of Singoli Tehsil of Neemuch District in the state of Madhya Pradesh. The Solar Park is divided into three units (Unit 1, Unit 2 and Unit 3) and lies between 24°59'39.78"N and 25° 0'38.51"N latitude and 75°13'26.82"E and 75°14'48.53"E longitude. An ESIA has been prepared for this site (Units 1, 2 and 3) and this document, is a management plan for stakeholder engagement activities. Objective and Scope of Stakeholder Engagement Plan This document presents the Stakeholder Engagement Plan (SEP), which is applicable all activities proposed to be undertaken for the Neemuch Solar Park, as well as other stakeholder engagement that is conducted by the Solar Power Park Developer (RUMSL), the private Solar Project Developers (SPD) or other parties contracted by RUMSL, that engage with the key stakeholders identified as part of this Plan. The main objective of this document is to guide stakeholder consultations across various stages of the project, while meeting the requirements of the applicable reference framework for the Project. Overall, this SEP will enable stakeholder engagement to be undertaken in a systematic and meaningful manner, where the various stakeholder groups are able to express their individual views, opinions and concerns, while allowing the Project to appropriately respond to them. The objective of the Stakeholder Engagement Plan are as follows: Identification of the stakeholder groups in the project location and analysis of their profiles, interests, issues/impacts and concerns relevant to the project; Identification of specific measures to allow meaningful engagement with different stakeholder groups identified in a manner that is transparent and accessible and using culturally appropriate communication methods with a specific focus on the stakeholders with high influence/impact ; Facilitate adequate and timely dissemination of information to the stakeholder groups in a culturally appropriate manner; Provide systems for prior disclosure/dissemination of information and consultation including seeking inputs from affected persons, incorporation of inputs, as applicable, providing feedback to affected persons/groups on whether and how the input has been incorporated; and Providing a mechanism for documentation of the activities undertaken and the reporting and monitoring of the same. Scope The Stakeholder Engagement Plan document applies to the entire project lifecycle (planning or pre- construction, construction and operations phases) and shall be considered as a live document that shall be updated regularly, as required. This stakeholder engagement plan (SEP) will be used and updated by the www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 393 project proponents and its various teams (internal as well as contracted), performing various tasks linked to the project, comprising ESIA, RAP and FPIC processes, through interactions with various stakeholder groups like Tehsil level officials, Revenue Inspector, Patwari, officials from RUMSL, etc. Methodology The stakeholder engagement plan is guided by the Stakeholder Engagement strategy developed for internal use at ERM, to ensure consistency in the message and communication being undertaken with the identified stakeholders, by all teams that are involved in ESIA, RAP and FPIC/IPP preparation. During the environmental and social impact assessment consultations process, ERM conducted various activities as part of the development of the public consultation program to determine the relevant stakeholders. From the ESIA field-consultations, ERM has identified approximately key stakeholders groups and categorised them as Primary and Secondary stakeholders, based on the nature and extent of impact of project and influence of stakeholders on the project, as presented in Table F8. There may be cases where additional stakeholder categories are identified during the RAP-LRP and FPIC/IPP survey processes, and/ or the profile of these stakeholder groups (Primary or Secondary) altered based on detailed assessment from impacted entities by the project. The details of these engagement activities and key points of discussion are captured in Appendix B of the document. Furthermore, the surveys for the Resettlement Action Plan and Livelihoods Restoration Plan (RAP-LRP) and FPIC/IPP preparation are planned July 2020 onwards in the project villages of Bardawada, Kawai and Badi, which will primarily comprise the following stakeholder categories. Separate meetings with women and men may be help, as required: Private Land Owners; Patta Holders; Users of the affected land categories, including agricultural labour, encroachers etc.; Indigenous Groups present in the Project villages; Other groups or institutional entities that are identified at the time of detailed RAP surveys. Applicable Reference Framework This Stakeholder Engagement Plan is prepared as per the requirements of the following regulations and standards: Relevant environmental, land labour and other relevant policies, laws, regulations and rules of the state of MP, and the Government of India; World Bank Environmental and Social Management Framework for Solar PV Park, February 2017; and IFC Performance Standards, 2012 www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 394 Stakeholder Mapping Stakeholder Identification and Categorisation A stakeholder is defined as 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. During the ESIA process, a stakeholder identification and prioritization was conducted for identifying the key stakeholders of the project, while keeping in mind the nature of the project and its setting. Furthermore, consultations were conducted with these identified stakeholders through a participatory approach. The table below presents the key stakeholders of the project. Table F8 Stakeholder Group Categorisation Stakeholder Groups Primary Stakeholders Secondary Stakeholders Community Private Land Owners from Bardawada, Fence Line Communities from Kawai, Badi villages other villages in the vicinity Patta Holders from Bardawada, Kawai, Non- Badi villages who have procured the patta based on a verbal agreement with based on verbal agreements without due the original (and registered) patta paperwork holders. Squatters and Encroachers Agricultural Labourers Graziers Vulnerable Social Groups in other villages in the vicinity Contractors Potential unskilled labourers to be engaged for the construction phase of the project Owners of land required for temporary occupation or use Local Community from Project villages. Institutional Gram Panchayats of Dhardi (for Local Political Groups Stakeholders Bardawada village) and Badi (for Kawai Civil Society/ Local NGOs and Badi villages); Singoli Tehsil officials Government Regulatory Authorities comprising the Bodies/Regulatory following: - MP Pollution Control Board; Authorities - Central Pollution Control Board (CPCB) - Ministry of Environment Forest and Climate Change (MoEFCC) - Local Fire Authority; - Ministry of Road Transport and Highways - State Transport Authority; - District Collector and Revenue Department; - Central Electrical Authority through C.E(P&D) Jabalpur; - Department of Telegraph Communication, Govt. of Madhya Pradesh; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 395 Stakeholder Groups Primary Stakeholders Secondary Stakeholders - Department of Panchayati Raj, Madhya Pradesh; - Labour Department; - Wildlife Warden, State Forest Department; - District and State Forest Department, MoEFCC. District Administration 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 stakeholder group and urgency/likelihood of the impact associated with the particular stakeholder group in the project context. The magnitude of stakeholder impact/influence is assessed taking the power/responsibility and proximity 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 on a scale of low, medium and high. The overall significance of the stakeholder group is assessed as per the matrix provided in table below. Table F9 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 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. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 396 Table F10 Stakeholder Analysis Relevant Profile/ Status Impact/Influence of the project Impact/Influence of Expectations, Opinions Key Overall Stakeholders on this Stakeholder Group the Stakeholder Concerns of Stakeholders Rating of Group on the project Stakeholder Influence Primary Stakeholder Private Land Owners Private Land Owners The project will be set up on The stakeholder Concerns regarding land High and Patta Holders comprise of those 35.488 ha. of private land being procured by the Project, from Bardawada, households, whose land and 87.734 ha Patta land on the project is because there has been Kawai, Badi villages parcels are falling within parcels across the three pertinent to significant cost and effort land footprint of the solar villages; smooth land expended in the preparation park. The dependence on land for availability and its of the land for making it Patta holders comprises of agriculture and livestock in support is key for cultivable; households that were the area is high, as depicted the smooth Adequate payment for the assigned land (Patta), by in the Census data and functioning of the land being procured for the dint of their landlessness (or reported during consultation; project related project activities, including for other vulnerabilities), in The purchase of land for the activities in the those without any formal 1950s- 60s to 80s, under project development area. recognized ownership various schemes. activities will affect this documents, who may have The criteria and terms for stakeholder group leading to allotting Patta land were reduced land holdings; verbal agreement; different as this was done at Additionally, if this Minimal disturbance to the different times, for different stakeholder group is community with regards to purposes. The Tehsil office provided with an alternate access issues, pollution, reported that these land parcel, the quality of health and safety risks and documents were lost over alternate land parcels and influx of migrant workers time and are not available; the effort and investment This Stakeholder group may This group is dependent on required to make it fit for expect income generating their land parcels for their cultivation, is also of key activities or employment as livelihood needs; concern, as there are certain construction labourers, This includes the land rocky patches of land masons, drivers, etc. during owners in the RoW of the existing in and around the the construction phase of the Transmission Line routes project area. Project. for the project. The exact number of land owners for the project is not currently known. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 397 Relevant Profile/ Status Impact/Influence of the project Impact/Influence of Expectations, Opinions Key Overall Stakeholders on this Stakeholder Group the Stakeholder Concerns of Stakeholders Rating of Group on the project Stakeholder Influence Encroachers/ This stakeholder group This stakeholder group has The influence of this The key concern of this Medium occupiers/ comprises of households been using the land for stakeholder group on stakeholder group is of losing squatters (for that have illegally livelihood activities; though the project is the land parcels which they agriculture) encroached/occupied does not have legitimate moderate, considering have been using for Government Land, which claims or ownership of the they do not have legal agriculture; was lying unused, in the land. In fact, they are well rights on the land; This group reports that they project area and around. aware of their illegal status; however there have have spent considerable Encroachment of The project would be set up influence in the village amount of effort and money to Government land is a on the encroached land and by virtue of their make the land cultivable and general practice in the area, would lead to disruption of economic power (they all this effort will be wasted where certain households economic activities and are all land owners after the project comes on this start using Government land incomes to these and employers of land; for agriculture, even without households, and those agricultural labour). Additionally, their concern is any legal ownership of the employed by them on these They have previously for the proportion of land land parcel. lands (usually seasonally). held agitations and parcels under their It has been reported that the protests as they do possession which are practice of encroachment is not want to part with undeclared; usually undertaken by the their encroached land The Revenue inspector and relatively well-off parcels, given that his team, which undertook the households, that already they have made land mapping exercise did not own land; several improvements note the encroached land When the encroachment to it and made this parcels and thus this related practices are land productive. stakeholder group is identified by the concerned that they may not Government officials, this receive any compensation; group is willing to pay fines This Stakeholder group may against the use of expect income generating Government land; however, activities or employment as in such scenario, the construction labourers, Encroachers do not disclose masons, drivers, etc. during the exact encroachment the construction phase of the and only declare a fraction Project. of the actual encroached land to, in tier understanding, get some sort of sanction to continue to informally occupy and use the land. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 398 Relevant Profile/ Status Impact/Influence of the project Impact/Influence of Expectations, Opinions Key Overall Stakeholders on this Stakeholder Group the Stakeholder Concerns of Stakeholders Rating of Group on the project Stakeholder Influence This practice helps them to make official records of their dependence on the land, simultaneously saving the fines for the actually encroached land, which would be significantly higher. To make it productive, most occupiers have made improvements to the land, including installing bore wells and improving the soli quality through use of manure and repeated cultivation and tilling. Agricultural This stakeholder group The land procurement for The influence of This Stakeholder group may Low Labourers comprises of those the project will be impacting this group on the expect employment as households that have their income sources, project is limited, construction labourers, marginal or limited land thereby leading to a given that they do masons, drivers, etc. during holdings and members of deterioration of the not have any the construction phase of the their families work as household income. legal claims on Project. Agricultural labourers in the the land; land parcels falling in the This group can be area identified for project used during the across all three categories- construction private land, patta land (that phase of the is being cultivated), and project as encroached land under unskilled labour agriculture with priority hiring and may additionally be included in Livelihood Restoration initiatives; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 399 Relevant Profile/ Status Impact/Influence of the project Impact/Influence of Expectations, Opinions Key Overall Stakeholders on this Stakeholder Group the Stakeholder Concerns of Stakeholders Rating of Group on the project Stakeholder Influence Graziers people The Government land in the The procurement of The influence of The key expectations of this Lows from the Project Project Footprint is reported Government land that is this group on the stakeholder group is to allow villages who use the to be used by the being used shall reduce the project is limited, for provision of 2% grazing government land as community for grazing of amount of land available for given that they do land in the project area for open grazing area livestock of nearby villages. grazing near the project not have any livestock grazing; for their livestock There are approx. 2200 villages; legal claims on Easements shall be provided livestock (comprising cows, This land procurement may the land; through project design buffaloes, sheep and goats) also lead to impact on Livestock forms elements to have minimal in the three project villages. easement or access to other an important part impact on this stakeholder The livestock ownership in areas available for livestock the Project villages is higher grazing. nutritional and amongst Gurjar community energy source (cows and buffaloes), while and may impact Bhil community is reported availability of food to possess a higher number (milk, meat, etc.) of sheep and goats. during The local community has construction also done boundary phase, to some marking on government extent is affected land, to demarcate grazing badly. areas for an individual household or a group of households, by creating livestock from the village is fed commercially, by charging INR 1000 per livestock per year. Vulnerable social This stakeholder group is The influence of project on The involvement Priority in economic benefits Medium comprised of this group is similar in nature of this and development groups such as groups/households that are as the entire fence line stakeholder group opportunities created by the women headed considered to be vulnerable community, as it is a subset is expected to be project; households, BPL due to their social, political of the same. as part of the Minimal disturbance to the and Landless or economic status in the larger local community in regards to society. community; access issues, grazing land, households For the project, the This stakeholder pollution and influx of migrant vulnerable groups are group should be workers. identified as women & specifically Provisions for women, in women headed households, consulted to order to ensure equivalent www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 400 Relevant Profile/ Status Impact/Influence of the project Impact/Influence of Expectations, Opinions Key Overall Stakeholders on this Stakeholder Group the Stakeholder Concerns of Stakeholders Rating of Group on the project Stakeholder Influence elderly, physically ensure adequate benefits to both genders, to handicapped, landless and provisions in the the extent possible those with less than 1 ha of RAP and LRP for land and families in the the differential Below the Poverty Line impacts expected Category; on this group The impacts on this stakeholder group will be similar to other groups, due to land take, Health and safety, etc.; just that they may get impacted more due to their vulnerabilities, the traditional practices of non- participation in meetings along with men, limited involvement in negotiation process for land sale, etc. Indigenous People While the project is not The influence of project on The involvement Priority in economic benefits High located in a scheduled V this group is similar in nature of this and development area, the local community is as the entire fence line stakeholder group opportunities created by the comprised of ST population. community, as it is a subset is expected to be project; The largest proportion of ST of the same. as part of the Minimal disturbance to the population is in the Project larger local community in regards to Villages of the Neemuch community; access issues, grazing land, solar park. In keeping with pollution and influx of migrant The assessment of impacts the requirements workers. on the ST population due to of the IFC PS 7, the project related land the project will procurements will be require to obtain assessed in detail during Free Prior surveys to be undertaken Informed Consent for preparation of IPP from this stakeholder group prior to the initiation of project activities. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 401 Relevant Profile/ Status Impact/Influence of the project Impact/Influence of Expectations, Opinions Key Overall Stakeholders on this Stakeholder Group the Stakeholder Concerns of Stakeholders Rating of Group on the project Stakeholder Influence EPC/ Construction This stakeholder group The project provides this This stakeholder Continued economic High Contractors, sub- comprises of the EPC group contractor-ship group is critical opportunities and work contractors contractors and other opportunities and steady for the smooth generation; contractors/ sub-contractors flow of income. functioning and Clarity in terms of scope of involved in the Project for timely work, expectations, key various tasks, like access implementation of performance indicators, roads construction, laying the Project; responsibilities and timelines down of Transmission Line towers, civil and electric This group may for the project; works for the power plant, also play an Timely and adequate etc. important role in disclosure of information to the formation of allow the project activities to public opinion be carried out; towards the Fair business opportunities project and contract closure; Undertake project activities in keeping with the contractual agreements and applicable regulations in place. Unskilled labourers This group is comprised of If local labour is used, it will This stakeholder Concerns pertaining to Low to be engaged for skilled and semi-skilled help create goodwill locally group will be wages, benefits, working workers, who will be and the project related critical for the the construction involved in the project on a opportunities would be smooth hours and working conditions, phase of the project contractual basis. shared with the local functioning and etc.; Labour may be local, population.. timely Health and safety involved regional or migrant (from implementation of with the construction phase other regions) and is likely the project; to be comprised of skilled This group may Working hours at the worker and any number of also play an construction site semi-skilled or unskilled important role in Timely disbursement of workers This decision will the formation of wages; public opinion depending on their towards the Access to the GRM requirements. project. established for the project www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 402 Relevant Profile/ Status Impact/Influence of the project Impact/Influence of Expectations, Opinions Key Overall Stakeholders on this Stakeholder Group the Stakeholder Concerns of Stakeholders Rating of Group on the project Stakeholder Influence Owners of land Some of the project The short term leasing of This stakeholder The expectations of this Medium required for components would require land by the project may group is critical stakeholder group is clear temporary short term leasing of land bring in additional income for availability of occupation or use available, largely from from lease, if the land is not land parcels that communication of lease terms Private and/ or Patta land being used for any other are conveniently and amount and timely owners; commercial purposes; located from the payments, as necessary; This requirement would be The project related activities project footprint better understood during the on these land parcels may (based on the Restoration of land to its time of initiation of be for purposes of storage, needs) and are original state, or better, at the construction activity. set up of labour camps, etc. available without time of handing it back to the and may result in change in disturbances or land use due to construction issues during the owners. or storage activities, lease period. contamination issues, etc. Gram Panchayats This stakeholder group is The influence of project on This group has Involvement of this group in Low comprised of Sarpanch, this stakeholder group is the ability to decision making process for (GPs) of Dhardi (for ward member and Gram minimal due to limited influence the the project, especially related Bardawada village) Sewak of Panchayats of control that the project can perception of the to the land taking process and Badi (for Kawai Dhardi (for Bardawada exert on the functioning of community in Involvement in the formulation and Badi villages) village) and Badi (for Kawai this group. regards to the and implementation of the and Badi villages). Project and its community development activities activities for the project; Adequate communication of project information, in terms of timelines of key activities and their potential impacts. Singoli Tehsil/ This group is comprised of The project should be in This stakeholder Developmental activities in High the regulatory authorities at compliance with the group is high in the project area; Neemuch district the tehsil and district level requirements stated and the priority as this Smooth operations of the officials (District that are responsible for land processes governed by this group provides project related activities by Col demarcation, allotment of stakeholder group. the land causing minimal impacts on patta land, for the project Their involvement for demarcation and the community; and for various permits and resolution of patta land permits and Adherence to regulations and licenses pertaining to the related issues will be licenses maintenance of law and order project. essential essential for the The decisions regarding They will be required to functioning of the whether to provide alternate provide support for law and project; order for the smooth and www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 403 Relevant Profile/ Status Impact/Influence of the project Impact/Influence of Expectations, Opinions Key Overall Stakeholders on this Stakeholder Group the Stakeholder Concerns of Stakeholders Rating of Group on the project Stakeholder Influence peaceable functioning, of Noncompliance sale, and how other matters construction activities, and to conditions laid pertaining to patta land may to resolve grievance that down in permits be resolved also require may be escalated to them. issued by this their participation and final group decision. stakeholders group can result in penalties and fines being levied on the Project. Regulatory This stakeholder group is The main concerns of the The ability of the Project comprised of the central, Regulatory Authorities from project to comply regulatory requirements; Authorities at state state and district level the Project Proponents is with the various Timely disclosure of and central levels regulatory authorities; abidance to all applicable applicable rules information and provisioning These authorities influence guidelines, policies and and regulations of updated through the life of the project in terms of laws. may play a role the project establishing policy, granting in the timely This stakeholder group is permits and approvals for implementation also critical for various the project, monitoring and of the project. permits/clearances required enforcing compliance with for the commissioning of the the applicable rules and project regulations. Secondary Stakeholders Fence Line This stakeholder group is The project will use land This stakeholder Adequate provisions of High comprised of the local which is currently being group shall play easements while designing Community population in the three used by this stakeholder a critical role in various project features in villages, coming under the group in accessing their the smooth order to ensure minimal project boundaries that are farms, lakes and other functioning of the access restriction for this not directly impacted by the common areas, grazing their Project. group; Project activities as well as livestock, etc.; Minimal disturbance to this population residing in other Some of the community group due to various villages in the Study area of members also use this land activities of construction, the project; for cultivation (through operation and encroachments) or work on decommissioning phases, including plying of vehicles www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 404 Relevant Profile/ Status Impact/Influence of the project Impact/Influence of Expectations, Opinions Key Overall Stakeholders on this Stakeholder Group the Stakeholder Concerns of Stakeholders Rating of Group on the project Stakeholder Influence the farm lands as for transportation purposes, agricultural labourers, etc. using the roads near these These activities will be villages. disrupted after the project related activities commence on the identified land Local Political This stakeholder group is The project will have minimal This stakeholder The main expectation and Low comprised of the political or no influence on this group is expected concern of the stakeholder Groups parties and local politicians stakeholder group to play a critical group from the project active in the region; role in the includes This group might be active development of the development of the area in the area and may play an the public opinion in keeping with the broader important role in the towards the agenda of the projects and polarisation of public opinion project, especially keeping the constituents and towards the Project. in light of the loyalists of the parties at the current political forefront. environment in the country. Civil Society/Local This stakeholder group The level of influence of project The stakeholder The main expectations and Medium on this stakeholder group is group may play concerns of the stakeholder NGOs comprises of NGOs and Civil limited as it does not affect the an important role group from the project is likely Society Organizations of a functioning of this group. in the to include the development of national, state and local level development of the project, in keeping with who may be active in the area. public opinion for the applicable regulations and the project; with minimal impacts on the Most of the NGOs and CSOs This stakeholder local population, while working in the region are state group may also contributing towards the level NGOs, involved in literacy, be involved in the overall development of the water management, WASH and implementation of area gender equality some of the key the community The interest of this development stakeholder group primarily NGOs and CSOs working in the plans pertains to the roles of the region include the following: project in implementing Water Aid community development Neemuch Gabli Educational activities in the area; & Social Welfare Society Involvement in the formulation Seema Mahila Mandal, and implementation of the Neemuch www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 405 Relevant Profile/ Status Impact/Influence of the project Impact/Influence of Expectations, Opinions Key Overall Stakeholders on this Stakeholder Group the Stakeholder Concerns of Stakeholders Rating of Group on the project Stakeholder Influence Gramya Evam Bal Utthan community development Samiti activities for the project; and Grask Gramin Rojgar Evam Timely disclosure of Samaj Kalyan Samiti Samiti information pertaining to the Dewas project. Guru Shaheb Public Education Society Gurudev Samaj Kalyan Samiti Ashoknagar Gyanmanu Mahila Mandal www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 406 Detailed Stakeholder Engagement Plan Some of the most common tools of engagement are discussions, consultations and meetings. These modes of engagement can be undertaken in the forms of groups or at individual levels. These serve the purpose of allowing the project proponents to gain an understanding of the viewpoint of the other stakeholders involved in regards to the functioning of the Unit/project, the implementation of various provisions in the Project. Based on the stakeholder identification and analysis undertaken, a detailed plan is prepared that guides the engagement process with each stakeholder group, as identified in Table below. The Social and Community Supervisor shall be responsible for maintenance of the records of along with the members that engage with stakeholders during construction and operations phase, along with addition of addition of any new categories identified. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 407 Table F11 Stakeholder Engagement Plan Objective Method/time of Stakeholder Group Teams Engagement Planning Phase Private Land Information sharing regarding the project, including the background of the project and Face to face discussion ESIA Owners capacity of the project; and/or Focus Group RAP Discussion; To understand the key concerns related to the projects; RUMSL RAP-LRP surveys and Understand the socio-economic profile of land owners and the details of income generated consultations FPIC/IPP through agricultural activities in order to arrive at details for compensation for crop damage, etc. Effort required by the land owners to make the land cultivable; and Understanding expectation from the project. Squatters and Understanding the extent of land encroached and legally possessed by the group; Face to face discussion ESIA Encroachers and/or Focus Group Understanding other sources of livelihoods of the household, and dependence of their RAP Discussion during households and others; RAP-LRP and FPIC FPIC/IPP Understand the duration that the land is encroached for and improvements made to it; consultations Understanding expectation from the project. Patta Holders along Information sharing regarding the project, including the background of the project and Face to face discussion ESIA Patta holders who capacity of the project; and/or Focus Group have sold their land RAP Discussion based on verbal To understand the key concerns related to the projects; RUMSL agreement RAP-LRP surveys and Understand the socio-economic profile of Patta land holders, any alternate land parcels or consultations FPIC/IPP alternate occupational profile of household and the details of income generated through agricultural activities in order to arrive at details for compensation for crop damage, etc. Effort required by the Patta land holders to make the land cultivable; Any informal land transaction executed on the Patta land identified for project; and Understanding expectation from the project www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 408 Objective Method/time of Stakeholder Group Teams Engagement Indigenous Groups To understand existing rights, dependence and use Face to face discussion RAP ST community and/or Focus Group To understand the nature and extent of impacts; FPIC/IPP Discussions To ascertain if FPIC is required RUMSL Separate discussions If FPIC is requires, the process to be followed will be contained in the FPIC document and with women, if required must be applied; Agricultural Understanding the dependence on identified private, patta and Government land parcels for Open Meetings; RAP; Labourers and labour work and livestock grazing activities; Graziers Separate discussions FPIC/IPP Evaluation of alternate grazing land proximity and adequacy with women, if required RUMSL and Access routes and easements Solar Power Developers Other sources of livelihoods, if any; Engagement in community development activities; Understanding of expectations from the project. Gram Panchayat Discussion on the Bhil community, regarding the socio-economic status, legal documents of Consultations, ESIA; the community, migration of the community, encroachment on the nearby land done by the meetings (FGD and RAP; community and the voting rights of the community; individual interview) and Discussions; RUMSL; Information given regarding the project, including the background of the project and capacity of the project; Sharing of documents as part of the To understand the key concerns related to the projects; disclosure mechanism; Understand the socio-economic profile of land owners Grievances Redressal Understanding the potential impact of the project on the stakeholder; and Mechanism (GRM); Expectation from the project. For issues concerning Grievances Redressal Mechanism (GRM) www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 409 Objective Method/time of Stakeholder Group Teams Engagement Local Community Information given regarding the project, including the background of the project and capacity Focus Group ESIA; from project villages of the project; Discussion and/or RAP; Open Public Meetings To understand the key concerns related to the projects; FPIC/IPP Understanding the potential impact of the project on the stakeholder; and RUMSL/SPD Expectation from the project; along with EPC contractors and Engagement in developmental activities subcontractors Tehsil Officials Understand the working of revenue department; Face to face discussion ESIA; (Revenue Inspectors and The process adopted for demarcation of land; RAP; Tehsildar) The land transfer process from Revenue department to RUMSL; IPP Discussion over the Patta Land and the ownership of Patta land; and RUMSL along with EPC Different type of land present which are coming under the project footprint. contractors and Minimum Support Price for the crops given to the land owners and to the encroachers subcontractors Encroachment in the area Regulatory On land allocation for Government land by RUMSL; Face to face RUMSL along Authorities discussion; with EPC On understanding of land procurement process followed, by ERM ESIA Team; contractors and Through applications, On maintaining compliance to regulatory requirements; subcontractors; letters, etc. SPD Construction Phase Contractors Information dissemination, including information regarding labour laws, local employment Signed contracts with RUMSL opportunities, safety measures and discussion on grievances; requirement to implement the ESMP For negotiation on contract clauses as per requirements stated in ESIA and Management plans for the project; www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 410 Objective Method/time of Stakeholder Group Teams Engagement EHSS Audits by project proponents Meetings and monthly reporting in the operations phase; Documentation as agreed in the contract Potential unskilled Advertising of job vacancies for the project at village level; Through face to face RUMSL labour to be used discussion at the time oversight for construction During screening of applicants by contractors of RUMSL, in coordination with RUMSL on list of hiring for construction phase of the project of project affected households; SPD and their phase contractors and Induction on Code of Conduct and Grievances Redressal Mechanism (GRM) subcontractors Local Community To identify labour class in the village and site area; Focus Group RUMSL and from project villages Discussion and/or To identify their skill set and adequacy for engaging them in the on-going construction activity, EPC contractor Open Public Meetings i.e. as construction worker, security guard, cook, technician etc.; and other Sub- contractors To understand more about their expectation from project; engaged for construction phase Gram Panchayat To seek permission for labour camps and carry out construction activities; Individual/ Group RUMSL consultations with Gram To understand their expectation from then ongoing construction activity; EPC Contractor Panchayat members To identify and document, if there is any grievance, query or recommendation of Gram Panchayat or local community Operations Phase Gram Panchayat Discussion with Gram Panchayat regarding community development activities; Consultations, RUMSL; (for Community meetings with Gram Development Engagement of Gram Panchayat & local community in identifying the much needed skills to SPDs; Panchayat members Activities and other be developed in youth and local community; and local community, O&M Contractor www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 411 Objective Method/time of Stakeholder Group Teams Engagement Project related To identify the vulnerable community/ family and synchronizing their demand and need with individual meeting/ Grievances) project activities; discussion; To seek cooperation of local community and Gram Panchayat members for smooth and Sharing of documents, timely execution of development activities; ideas pertaining to development activities; Also, to liasion with Gram Panchayat regarding any query, grievance from then ongoing project activities and staff/ security guards. Grievances Redressal Mechanism (GRM); For issues concerning Grievances Redressal Mechanism (GRM) Local community & To identify the occupational pattern of the village; Consultation with local RUMSL; Youth community especially Understand the role and engagement of women in the workforce; SPDs; youth; Understanding the livelihood/ employment opportunities at village level; O&M Contractor Separate consultations To understand, if there is any need based demand from youth especially women/ girls, with school and college regarding skill development, typology of skill development etc. going girls and adult women regarding skill development demand. There is a Grievance Redresaal Mechanism that is developed to receive, record, resolve and track grievances raised by both internal and external stakeholders, as part of the ESIA report (Section 9). The provision of SEP and GRM are also referenced as mitigation measures in the relevant sections of the Environmental and Social Management Plan. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 412 Implementation Arrangements Monitoring and Evaluation Like the other project components, the SEP shall be regularly monitored to ensure that the engagement with various stakeholders are getting properly documented, in order to ensure transparency in communication and decision making processes, wherever applicable. A Social and Community Supervisor shall be appointed by RUMSL, who will be responsible for implementation of the SEP, along with other related plans like Gender Action Plan, Grievance Redressal Mechanism of the project, and identified roles in monitoring of labourers during construction and operations phases of the project. The S&C Supervisor shall play a key role in implementation of the SEP and other plans in construction and operations phases of the project. The S&C Supervisor shall coordinate with other relevant team members of RUMSL and its contractors, SPDs, etc., on maintaining and update of documentation of stakeholder engagement details, across the construction and operations phases. The S&C Supervisor shall additionally be responsible for identifying and tracking training needs, maintenance and update of documentation, reporting and monitoring requirements for the effective implementation of SEP. Budgeting RUMSL shall ensure that proper budgetary allocations are made for the activities related to stakeholder engagement, like meetings, trainings, addressal of needs identified and found reasonable through the stakeholder engagement process. www.erm.com Version: 3.0 Project No.: 0528741 Client: Rewa Ultra Mega Solar Limited 15 October 2020 Page 413 ERM has over 160 offices across the following countries and territories worldwide Argentina New Zealand ERM India Private Limited Australia Panama Belgium Peru Building 10A Brazil Poland 4th Floor, DLF Cyber City Canada Portugal Gurgaon, NCR 122002 China Puerto Rico Colombia Romania Tel: 91 124 417 0300 France Russia Fax: 91 124 417 0301 Germany Singapore Hong Kong South Africa www.erm.com Hungary South Korea India Spain Indonesia Sweden Ireland Taiwan Italy Thailand Japan UAE Kazakhstan UK Kenya US Malaysia Vietnam Mexico The Netherlands The business of sustainability